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Pulp and Paper Sector Survey

Instructions for Part I:

Mill Overview and Subpart S Data

11/16/10

This survey overview document provides instructions for completing Part I of the pulp and paper survey. This 

overview is organized as follows:

A. Part I Introduction ...........................................................................................................................................2

B. Confidential Business Information (CBI)........................................................................................................4

C. How to Submit Your Part I Survey Response .................................................................................................4

C1. Submitting Your Non-CBI Response................................................................................................4

C2. Submitting CBI.................................................................................................................................4

D. How to Complete the Part I Survey.................................................................................................................5

D1. Flow diagrams...................................................................................................................................5

D2. Process data (P&P survey_PI.xls).....................................................................................................6

a. Mill tab ....................................................................................................................................7

b. PI Equip detail tab ...................................................................................................................8

c. PI Permit limits tab................................................................................................................12

d. PI Controls tab.......................................................................................................................13

e. Pulp prod tab .........................................................................................................................14

f. Byproducts tab.......................................................................................................................15

g. Kraft condensates tab ............................................................................................................15

h. CCA tab.................................................................................................................................16

i. Bleaching tab.........................................................................................................................16

j. Paper prod tab........................................................................................................................17

k. HAP additives tab..................................................................................................................17

l. WW tab..................................................................................................................................18

D3. Test data..........................................................................................................................................18

a. PI Emissions test data tab ......................................................................................................18

b. CEMS data spreadsheet (P&P CEMS_PI.xls).......................................................................19

D4. Optional cost data............................................................................................................................21

PART I - ATTACHMENT 1 Emission Units to Include in the Part I Pulp and Paper Survey Response ..................23

PART I - ATTACHMENT 2 Small Business Size Standards....................................................................................25

PART I - ATTACHMENT 3 Part I Emissions Test Data Request.............................................................................26
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A. Part I Introduction

The pulp and paper sector information request applies for pulp and/or paper/paperboard mills that are a “major 

source” or “synthetic area source” of hazardous air pollutant (HAP) emissions that:

(a) Perform chemical wood pulping (kraft, sulfite, soda, or semi-chemical), or

(b) Perform mechanical, groundwood (e.g., thermomechanical pulping (TMP), refiner mechanical pulping 

(RMP)), secondary fiber, and non-wood pulping, or

(c) Perform bleaching, or

(d) Manufacture paper or paperboard products.

As defined in 40 CFR Part 63, subpart A,

“Major source” means any stationary source or group of stationary sources located within a contiguous 

area and under common control that emits or has the potential to emit considering controls, in the 

aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any 

combination of hazardous air pollutants, unless the Administrator establishes a lesser quantity, or in the 

case of radionuclides, different criteria from those specified in this sentence.

A “synthetic area source” is a stationary source which is subject to federally-enforceable conditions that limit its 

potential to emit to below major source thresholds.

Certain mills are not required to complete the pulp and paper sector survey. If your mill meets one of the following 

conditions, then you should complete the form in Attachment 1 of the Survey Overview document and email (or fax) 

it to Bill Schrock at EPA (contact information is provided on the form). Conditions for exemption from all parts of 

the pulp and paper sector survey are as follows: 

 Your mill is not a “major source” or “synthetic area source” of HAP emissions, or

 Your mill was not operational in 2009 (and remains closed), or 

 Your mill does not produce pulp, perform bleaching, or serve as a primary manufacturer of paper or 

paperboard products.

You are required to complete Part I of the pulp and paper sector survey unless you meet one of the three criteria 

listed above for exemption from the survey

This survey is to be completed in a Microsoft Excel spreadsheet file that is divided into several worksheets (“tabs” 

within the spreadsheet). You must complete certain tabs of the survey spreadsheet (depending on the type of mill 

you operate). Table 1 below denotes which survey spreadsheet tabs to complete depending on mill type. Additional 

spreadsheets are provided for submittal of continuous emissions monitoring system (CEMS) data or control measure 

cost information.

Please complete the survey for the facility listed in the Section 114 letter you received in the mail. If you received

more than one Section 114 letter for multiple facilities, you must create a separate survey response for each facility.

If you have not already received or downloaded a copy of the survey spreadsheets, they can be downloaded here: 

https://icr2010.rti.org/Industries/PulpPaper.aspx

Use the 2009 calendar year as the base year for all survey responses (e.g., 2009 emissions inventory, 2009 capacity, 

2009 equipment configurations, etc.), unless another year is specified in the instructions (e.g., for emissions test 

data). 

Part I of this survey asks questions about the emission units listed in Attachment 1 to this document. Part I covers 

essentially all emission units except for chemical recovery combustion sources (which are covered in Part III). 

Section D, How to Complete the Part I Survey, explains how to treat various configurations of emission units (e.g., 

multiple emission units venting to the same stack, etc.) for each survey tab. Attachment 2 contains a listing of small 

business size standards for North American Industry Classification System (NAICS) code Subsector 322, Paper 

Manufacturing. Finally, Attachment 3 of this survey contains a table of emission units and pollutants for which 

existing emission test data are requested under Part I.
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Use the following attachments to the Survey Overview document for reference:

Attachment 2: Regulatory definitions from the kraft pulp mill new source performance standards (NSPS) 

(40 CFR Part 60, subpart BB), chemical recovery combustion source national emissions 

standards for hazardous air pollutants (NESHAP) (40 CFR Part 63, subpart MM), the pulp 

and paper processing NESHAP (40 CFR Part 63, subpart S), and selected definitions from 

the NSPS and NESHAP General Provisions. 

Attachment 3: Acronyms and abbreviations used throughout the survey and associated spreadsheets. 

Table 1. Part I Survey Spreadsheets and Tabs to Complete

Spreadsheet and tab Types of mills that should complete this spreadsheet tab

P&P survey_PI.xls

Mill All mills

PI Equip detail All mills

PI Permit limits All mills

PI Controls Mills with add-on air pollution controls on pulping emission units, bleaching 

emission units, or papermaking emission units.

Pulp prod Mills that produce any type of pulp (including chemical, mechanical/groundwood, 

secondary fiber, including non-wood pulp)

Byproducts Mills that produce turpentine or tall oil byproducts from pulping processes

Kraft condensates Mills that perform kraft pulping

CCA Mills that perform kraft pulping and use the clean condensate compliance 

alternative (CCA)

Bleaching Mills that perform bleaching

Paper prod Mills that produce paper or paperboard products

HAP additives Mills that produce paper or paperboard products

WW Mills with onsite wastewater treatment plants

PI Emissions test data Mills operating emission units for which test data are requested in Attachment 3 to 

this document.

P&P CEMS_PI.xls

CEMS data1 Mills operating CEMS on emission units listed in Attachment 1 to this document.

P&P costs OPTIONAL_PI.xls (Completion of this spreadsheet is optional)

APCD costs Mills that installed selected air pollution controls (see section D4)

Equip change costs Mills implementing selected process or equipment changes (see section D4)

1

Separate tabs are included for different pollutants and for CEMS cost.
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B. Confidential Business Information (CBI) 

The U.S. Environmental Protection Agency’s (EPA's) procedures for handling confidential business information 

(CBI) are described in the letter (and attachments) accompanying the pulp and paper information collection request 

(ICR). If you believe that providing any specific information to us would reveal a trade secret, please identify this 

information clearly in your spreadsheet response by shading the spreadsheet cell containing the CBI with red 

highlight and indicating in the red block at the top of each spreadsheet tab that the tab contains CBI. Also, please 

clearly label any flow diagrams or other attachments submitted with your survey that contain CBI. However, please 

do not label your entire response as CBI if only a portion includes trade secrets. The EPA is likely to follow up with 

a request for validation of CBI claims for mills claiming large amounts of information as trade secrets, especially 

information that is readily reported by other mills without such claims.

C. How to Submit Your Part I Survey Response 

If your response to this information collection request includes data with a claim of CBI, you should follow the 

instructions in this section to ensure the protection of your data. Please note that if you submit CBI, you will be 

separating your data into two portions and sending your data to EPA using two different mailing addresses. 

C1. Submitting Your Non-CBI Response

Follow these instructions for the non-CBI portions of your survey response (or for responses that are entirely nonCBI.)

After you have completed and reviewed your survey response, sign and date the certification form in Attachment 4 

of the Survey Overview document. Remove the CBI components from your survey as instructed in section C2. Save 

the Excel spreadsheet(s) containing the non-CBI portions of your completed response, non-CBI flow diagrams, 

emission test reports, and any other electronic non-CBI attachments on the flash drive you were provided with your 

section 114 letter (or on a CD or DVD). Assemble any non-CBI hard copy attachments to your survey (such as the 

signed certification form, hard copy flow diagrams, test data, wastewater emissions modeling reports, etc.). Mail the 

non-CBI flash drive (or disk) and any non-CBI hard copy materials in one envelope to EPA at the address specified 

below by the specified response deadline in the Section 114 letter. (Note: If the spreadsheet/diagrams/attachments 

contain CBI, use the address for Mr. Morales provided in section C2 of this document.)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (E143-03)

Attn: Mr. Bill Schrock

109 TW Alexander Drive

Research Triangle Park, NC 27711

EPA recommends sending your non-CBI files via Registered U.S. Mail using return receipt requested, Federal 

Express, or other method for which someone must provide a signature upon receipt.

C2. Submitting CBI

Follow these instructions for any portion of your survey response that contains CBI. 

Please create a separate CD or DVD containing a version of your spreadsheet response with only the CBI portion of 

your data (i.e., only the red highlighted data in the survey spreadsheet). Include on the disk any flow diagrams or 

pages of other attachments to your survey response containing CBI, with the CBI portions of the diagrams/pages 

clearly marked (e.g., highlighted or circled). Clearly mark the disk with the words “Confidential Business 

Information.” Send only these CBI files under separate cover to:
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U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (C404-02) 

Attn: Mr. Roberto Morales, Document Control Officer

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711

For the security of your data, EPA recommends sending your confidential files to Mr. Morales via Registered U.S. 

Mail using return receipt requested, Federal Express, or other method for which someone must provide a signature 

upon receipt.

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA. E-mail 

and facsimile are not secure forms of communication and should never be used to transmit CBI.

D. How to Complete the Part I Survey 

Your survey response will consist of flow diagrams, test reports, and completed Microsoft Excel spreadsheets. 

Separate Excel spreadsheet files are provided for completion (P&P survey_PI.xls; P&P CEMS_PI.xls; P&P costs 

OPTIONAL_PI.xls). You must complete certain tabs of the P&P survey_PI.xls spreadsheet file (depending on the 

type of mill you operate) as shown in Table 1 above. The P&P CEMS_PI.xls spreadsheet file is to be completed if 

you have continuous emissions monitoring data to supply. The P&P costs OPTIONAL_PI.xls spreadsheet file is an 

optional spreadsheet file that can be completed to supply control measure cost information helpful for EPA’s 

regulatory analyses.

D1. Flow diagrams

Please provide a process flow diagram (or diagrams) showing the equipment listed in Attachment 1 (to both survey 

Parts I and III). No additional diagrams are requested in Part III, so please include chemical recovery combustion 

sources in the diagrams submitted in response to Part I. 

Readily available block flow diagrams (e.g., such as those used for permit applications) will suffice. Electronic or 

hard copies are acceptable. You need not prepare any new flow diagrams. It is acceptable to hand-mark changes on 

an older diagram that may no longer be completely reflective if current operations. Examples of diagrams that 

would be helpful for EPA are as follows:

Chemical recovery area. A diagram showing each chemical recovery furnace/combustion unit, black 

liquor oxidizer (if used), smelt or ash dissolving tank, causticizing equipment, lime kiln/calciner, and liquor 

storage tanks or ponds would be helpful.

Pulping process. A diagram showing the equipment in all pulping lines, including the digester area, pulp 

washing lines, evaporator lines, and oxygen delignification systems, would be useful. The diagram could 

show any brown stock washers, hoods, filtrate tanks, vacuum pumps, screens, knotters, deckers, stock 

chests (including open stock chests, pulp storage tanks), thickeners, and weak black liquor storage tanks. 

Deckers, screens, knotters, stock chests, and pulp storage tanks following the last stage of pulp washing 

and/or those located prior to the paper machines are also of interest. 

Black liquor gasification. If black liquor gasification is used, a diagram and description of the system,

including any combustion controls or add-on controls used to reduce air pollutants, would be helpful. 

Wastewater treatment plant (WWTP). A flow diagram of each WWTP showing each wastewater 

handling/treatment unit would be useful. 
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D2. Process data (P&P survey_PI.xls)

In this portion of the survey, you are asked to add data to the various tabs in the P&P survey_PI.xls spreadsheet. 

Many of the instructions you need for completing the survey tabs are included in the “Instruction” row of each tab in 

the P&P survey_PI.xls spreadsheet. However, more detailed instructions for selected tabs are provided below to 

account for common situations and to provide information on how the data will be used by EPA. Each survey tab 

includes fields with pull-down menus for common entries. Use these pull-down menus whenever possible, or write 

in information if your selection is not contained in the pull-down menu. 

Several IDs are requested throughout the pulp and paper survey response spreadsheet(s), including: 

 NEI Site ID

 Emission Unit ID

 Collection system ID

 Bleaching line ID (if needed)

 APCD_ID

The NEI Site ID and Emission Unit ID should correspond with the IDs used in the NEI update (Part II of this 

survey) where such IDs exist. If no NEI Site ID already exists (e.g., in cases where no previous NEI data exists for 

your mill), then you should use “NEW_____” for the NEI Site ID where the blank is your mill’s zip code, as this 

will (in all likelihood) provide a unique identifier for your mill. If Emission Unit ID(s) for selected process units do 

not already exist in the NEI data set, then you may use any Emission Unit ID you choose (for example, the ID used 

in your permit), and this same ID should be used throughout all parts of the survey. You will specify the Collection 

system ID and APCD_ID in the PI Equip detail and other spreadsheet tabs. The Bleaching line ID would be used in 

the Bleaching tab, if needed, for plants with multiple bleaching lines.

Why does EPA need process data?

Facility and equipment details are being requested to inform the technology review of the pulp and 

paper NESHAP and NSPS and to provide information on means of reducing residual risk. While the 

NEI update (requested in Part II of this survey) provides EPA with data related to emissions release 

points (e.g., mass emission rate and stack exit parameters used for risk analysis and tracking 

nationwide trends), the technologyl review of the NESHAP and NSPS considers emission unit and 

control equipment details specific to the processes employed and matches these details to emissions 

levels that are achieved (e.g., emission concentrations). Applicability of the NESHAP and NSPS 

compliance options depends on the specific process equipment. 

How detailed must my diagram(s) be? 

The EPA will use the diagram(s) to aid in understanding the general mill flow and any unique 

characteristics in the mill layout. It is not necessary to show every single vent of every emission unit 

on the diagrams. However, the diagram should provide enough information such that it is clear how

emissions are collected and controlled. For example, if all digester vents are routed to a low-volume, 

high-concentration (LVHC) collection system, then it is not necessary to show each individual 

digester vent when one line drawn from a digester “block” to the LVHC collection system is 

informative.
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Follow the instructions below and in the “Instruction” rows of the spreadsheet to complete the survey tabs. Refer to 

Table 1 of this document to determine which tabs you must complete depending on the type of mill you operate.

a. Mill tab 

Complete the columns following the instructions provided in the “Instruction” row. Your response in the Mill tab 

will consist of one row of data. These data will be used by EPA to characterize your facility and identify applicable 

regulations. 

What if I do not know or have the information to answer a survey question? 

There may be survey questions that you do not know the answer to, or for which information is not 

readily available. The following codes may be used: 

Unknown (UK): If you do not have the requested information, cannot obtain the information 

without extraordinary effort, and cannot provide a reasonable estimate, then you may enter

“UK” for unknown. 

Not Applicable (NA): If a question is not applicable to your operations, then you may enter 

“NA” for not applicable.

Survey respondents are reminded that their certification of the accuracy of their response includes a 

certification that any identification of information as "unknown" or "not applicable" is accurate. 

Further, survey respondents providing an excessive number of responses as “UK or “NA” are likely 

to receive scrutiny and follow-up inquiries from EPA related to their survey response.

A Note About Identification Numbers (IDs)

The different parts of the pulp and paper survey include the following IDs: 

 NEI Site ID

 Emission Unit ID

 Collection system ID 

 APCD_ID

It is imperative that you use the same IDs to describe the same facility, equipment/emission unit, and 

emission release point throughout all parts of this survey. These ID codes will be used to link the 

various pulp and paper data base tables together into a functional and informative data base to be 

used for regulatory analyses. You may choose your own IDs (e.g., based on Emission Unit IDs 

already included in the NEI, IDs from existing process flow diagrams, IDs in your air permit, etc.), 

but the IDs you choose must be consistent throughout your survey response. If you wish to avoid 

follow-up calls regarding your survey data, please make every effort to ensure that your IDs match 

throughout the spreadsheet(s) and in each part of your survey response. For example, any Emission 

Unit ID or APCD_ID you create/specify in Part I should also be used when referring to the same 

piece of equipment in Parts II and III for this survey response.

Also, please be sure that no extra spaces or characters are included in the ID cells. For example, 

Emission Unit ID “DIG1” is not read the same as “DIG-1” or “DIG-1_” by data base software.
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Size of entity. Attachment 2 to this document contains a listing of North American Industry Classification 

System (NAICS) codes and small business size standards for NAICS subsector 322. For private 

businesses, small entity is defined for each NAICS code of the owning entity based on number of 

employees and/or company revenue. The parent company number of employees is used for the pulp and 

paper subsector (322). Note that the “number of employees” is calculated according to the Small Business 

Size Regulations codified at 12 CFR 121.06, where all individuals employed on a full-time, part-time, or 

other (e.g., temporary) basis are counted equally. 

Paper or paperboard processes/products. Enter the total number of operable paper machines located at the 

mill in 2009 (including any machines that were temporarily idle due to economic conditions in 2009) in the 

“Total number of paper machines” column. Enter the total paper/paperboard machine capacity as of 2009 

in the "2009 total paper/paperboard capacity (air dried short tons/year)” column. Note that capacity 

represents the paper/paperboard production capability of the operable machines and may be greater than 

2009 actual production. Nominal production capacity will suffice. Next, enter the total 2009 capacity to 

produce each paper grade across all paper machines (again, including machines temporarily idle in 2009).

Paper/paperboard capacity utilization. You are asked to provide the decimal percentage utilization for 

paper/paperboard production at your mill for the survey base year (2009). In addition, because 2009 was 

characterized by short-term production curtailments at many mills due to the U.S. economic situation, you 

are asked to provide a 5-year average capacity utilization. For example, suppose a mill has 3 paper 

machines but one of these machines was shut down due to economic reasons for half of 2009. The capacity 

utilization could be figured as follows: 

A B C D E F

Paper 

machine

Nominal 

production 

capacity 

(air dried 

st/day) 

Maximum 

production 

days/yr

Actual 

production 

days/yr

2009 

capacity, air 

dried st/yr

(= A x B)

2009 actual 

production, air 

dried st/yr*

(= A x C)

2009 decimal 

percent 

utilization*

(= E / D)

#1 400 360 340 144,000 136,000

#2 500 360 355 180,000 177,500

#3 200 360 175 72,000 35,000

TOTAL 1,100 396,000 348,500 0.88

st = short tons (1 st = 2000 pounds)

*The EPA recognizes the potential for actual production or actual utilization by machine to be considered 

as sensitive information (e.g., to be CBI). Therefore, EPA is asking that you report the overall decimal 

percent utilization aggregated across all machines instead. 

b. PI Equip detail tab 

All mills are asked to complete the PI Equip detail tab. This tab asks for information for each individual emission 

unit. The purpose of this tab is to provide EPA with equipment-specific details needed for the Agency to review the 

technology-based standards (i.e., nationwide numbers of equipment, configuration of controls, pertinent equipment 

details, and regulatory compliance options used).

The types of emission units listed in Attachment 1 that you operate should be included in the PI Equip detail tab. 

Essentially, you are requested to provide information for most of the equipment at your mill in Part I (except for 

chemical recovery combustion sources which are covered in Part III). However, if you operate chemical recovery 

combustion sources that burn pulp mill non-condensable gases (NCGs) or stripper off gases (SOG), then you will 

need to identify these combustion sources as the air pollution control device (APCD) in the PI Equip detail tab.

Columns A through AO of the PI Equip detail tab ask generic questions for all emission units listed in Attachment 

1. The columns to the right of column AO request design and operating details for specific types of emission units 
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(e.g., digesters, strippers, etc.). The table below summarizes the different types of equipment for which specific 

questions are included in the PI Equip detail tab.

PI Equip detail tab 

columns

Description of information requested

A-AO Equipment, controls, and Federal rule applicability for each emission unit and collection 

system.

AP-AR Digesters

AS-AW Pulp washers

AX-AY Knotters, screens, and deckers

AZ-BB Evaporators

BC-BE Oxygen delignification

BF-BO Strippers

BP-BS Pulp storage and liquor storage

BT-BW Liquor storage ponds

BX-CA Causticizing equipment

CB Fuel-fired equipment (e.g., boilers, thermal oxidizers, direct-fired dryers, etc.)

CC-CD Equipment incinerating NCG or SOG

CE-DM Primary and supplemental fuels for fuel-fired equipment (e.g., for boilers, thermal 

oxidizers, direct-fired dryers, etc.) 

DN-DT Emission unit startup and shutdown.

Data are requested for each emission unit (and need not be broken out by individual emission points for a given 

emission unit unless different collection or control measures apply for the different emission points from an 

emissions unit). Specify the Emission Unit ID and Collection system ID (if applicable), and APCD_ID(s) by 

following the directions in the “Instruction” row of the PI Equip detail tab. Some common configurations of 

emission units are addressed below.

Multiple emission units ducted to a single release point. List each emission unit separately in the PI Equip 

detail tab even if the exhaust from the emission unit is ducted to a common conveyance. For multiple 

emission units ducted through a common conveyance to the same release point, list each Emission Unit ID

separately and provide the same Collection system ID for the different Emission Unit IDs.

For example, an LVHC collection system (Emission Unit ID LVHC01) may collect emissions from 

multiple emission points associated with digesters 1, 2, and 3 and an evaporator (Emission Unit 

IDs D1, D2, D3 and EVAP1). You should list digesters 1, 2, and 3 and the evaporator on four

separate rows in the PI Equip detail tab (with 4 separate Emission Unit IDs, as shown above) and 

provide the data requested for each emission unit, indicating for each entry that the emissions are 

collected by the LVHC collection system (Emission Unit ID LVHC01). You should also list the 

LVHC collection system in the Emission Unit ID column (using the Collection system ID as the 

Emission Unit ID) so you can provide control information and equipment details for the LVHC 

collection system.

Single emission unit with multiple release points. Repeat the Emission Unit ID on separate rows and 

distinguish the release points using the “Emission unit description” column in as many rows as needed to 

reflect all of the release points associated with the emission unit in the PI Equip detail tab. For example, 

Emission Unit ID 001 (EU001) is vented to two stacks with different controls. Split EU001 to EU001a and 

EU001b on separate rows of the PI Equip detail tab, and then indicate in the “Emission Unit Description”

column that EU001a and EU001b vent through separate stacks. Enter details associated with emission 

release (APCD information and NSPS/NESHAP compliance options) in each row. Enter equipment details 
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(year installed, hours per year [hr/yr], combustion controls, fuel data, equipment design and other operating 

parameters) in only 1 row, leaving all other rows associated with the Emission Unit ID blank.

Emission units vented into the building. Include emissions units that vent into a building in the PI Equip 

detail tab, and enter “BLDG” in the “Configuration if not emitted through a conveyance” column.

Emission units that are not vented. Include emissions units that are not vented in the PI Equip detail tab, 

and enter “NV” in the “Configuration if not emitted through a conveyance” column.

Emission units with fugitive emissions. Include emissions units with fugitive emissions in the PI Equip 

detail tab, and enter “FUGITIVE” in the “Configuration if not emitted through a conveyance” column.

If an emission unit produces both fugitive emissions and emissions that are emitted though a conveyance,

then you need to specify the fugitive emissions on a separate row in the PI Equip detail tab (e.g., as a 

“Single emission unit with multiple release points” as described in the instructions immediately above for 

the PI Equip detail tab).

Bypass stacks used only during certain times. Do not include data for bypass stacks or control system 

bypasses in the PI Equip detail tab, except as specified for backup controls below.

Air pollution control devices (APCDs). In the APCD columns, enter primary APCDs (i.e., the pollution 

control used most frequently) in the sequence in which they are used to control emissions from each 

emission unit (or collection system) identified in the Emission Unit ID column. Enter a description of the 

APCD in the APCD “type” column and an ID code in the APCD_ID column. The ID you enter into the 

APCD_ID field will correspond with the APCD_ID you enter in the Controls tab. For example,

If you use an electrostatic precipitator (ESP) (ESP1) followed by a scrubber (WSa), you would 

enter APCD1 type = ESP and APCD2 type = scrubber, and APCD1_ID = ESP1 and 

APCD2_ID = WSa. 

If a white liquor scrubber (identified as WLIQSBR) is used to scrub SOG prior to burning of the 

SOG in a lime kiln (Emission Unit ID = LK2), then APCD1_ID = WLIQSBR and APCD2_ID 

= LK2.

Emission units routed to a boiler, lime kiln, or recovery furnace for emissions control. Enter the Emission 

Unit IDs for each emission unit (e.g., digester) in the Emission Unit ID column. Use the boiler, lime kiln, 

or recovery furnace’s Emission Unit ID as the APCD_ID in the APCD columns. The same Emission Unit 

ID (e.g., for the lime kiln or recovery furnace) should be used in Part III when equipment-specific details 

are provided for these equipment.

Backup controls. Backup controls include alternative controls used when flow from an emission source 

(e.g., high-volume, low-concentration (HVLC) or LVHC collection system) is diverted from the primary 

control device to a less frequently used control device. For example, the primary LVHC control may be 

lime kiln 1 and the backup control may be a boiler when lime kiln 1 is not operating. Enter backup controls 

in the “Back-up method of control” column of the PI Equip detail tab. Do not include backup controls in 

the columns for APCD1 through APCD4.

Complete the applicable equipment-specific details requested in columns AP through DT for each type of emission 

unit in the PI Equip detail tab by following the directions in the “Instruction” row of the tab. Additional specific 

instructions are provided below for equipment requiring instructions beyond what could be explained in the 

“Instruction” row. Leave columns that do not apply for a given emission unit blank.

All emission units listed in Attachment 1. Complete columns A through AO. These columns ask generic questions 

for all emission units related to how the emission units are vented and controlled, and related to Federal rule 

applicability. Additional questions in columns AP through DT may also apply for selected emission unit types.
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Pulp processing equipment. Information pertaining to pulp processing equipment such as digesters, pulp washers, 

knotters, screens, deckers, evaporators, and oxygen delignification is requested so EPA can determine the population 

and characteristics of these emission units following subpart S MACT compliance. Capacities are requested so EPA 

can estimate emissions and perform impacts analyses.

Strippers. Information related to strippers is requested to provide an understanding of the number and characteristics 

of strippers in use at pulp and paper mills following subpart S compliance.

Pulp storage and liquor storage, and liquor ponds. HAP emissions may be associated with pulp and cooking liquor 

storage tanks, and liquor storage ponds. Questions pertaining to pulp and liquor storage are asked to provide an 

inventory of storage equipment and to characterize any storage processes that may require further analysis for 

subpart S residual risk purposes.

Causticizing equipment. Limited questions are asked for equipment in the causticizing loop of mills that perform 

kraft or soda pulping. Information on causticizing operations provides inventory detail and process rates for 

purposes of emission calculations, and can inform EPA of practices that could be used to reduce emissions from the 

lime kiln or from other causticizing equipment. 

Boilers, thermal oxidizers, and direct-fired dryers. The EPA is requesting limited information on boilers (and other 

fuel-fired equipment such as thermal oxidizers and dryers) in the PI Equip detail tab. Many pulp and paper mills 

use boilers for primary or backup control of organics from pulping process, and some mills use thermal oxidizers for 

this purpose. Boilers (and other fuel-fired equipment) currently contribute to the facility-wide risk levels at pulp and 

paper mills.

Wastewater handling/treatment units. Complete the generic questions in Columns A through AO of the PI Equip 

detail tab for any wastewater handling/treatment units that are closed and/or vent through a conveyance.

Other equipment. Complete the generic questions in Columns A through AO of the PI Equip detail tab for any pulp 

and paper production equipment not elsewhere specified in the tab.

Primary and supplemental fuels. Fuel types are requested for fuel-fired equipment because fuel type can have an 

effect on emissions. The EPA may consider fuel types and perform calculations based on fuel firing rates for 

various nationwide impact analyses. Because the types and amounts of fuels fired can vary seasonally, EPA is 

requesting the approximate percent of annual heat input capacity in million British thermal units per year 

(MMBtu/yr) supplied by each fuel.

Primary and supplemental fuel information is requested for fuel-fired equipment such as boilers, thermal oxidizers, 

and direct-fired dryers (e.g., pulp dryers or paper machine dryers). NCG and SOG are not considered to be either 

primary or supplemental fuels for purposes of this survey. Information for secondary and additional fuels used 

routinely for multifuel-fired equipment may be indicated in the supplemental and other fuel columns.

What averaging period should be used in responding to process detail questions?

Several questions in the PI Equip detail and other survey tabs ask for process parameters such as 

exhaust flow rate (acfm), temperature, etc. Unless otherwise specified, typical values are requested, 

and are subject to the respondent’s discretion. For example, if you measure a particular parameter 

with an online meter and you have data available for most operating hours of the year, then you may 

choose to supply an annual average for the parameter. However, if the parameter is only measured 

periodically, then you may want to provide the most recent measurement. 
Part I Form Approved __/__/__

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Emission unit startup and shutdown. Complete the startup and shutdown questions for all emission units currently 

subject to Federal or State emission limits or monitoring requirements. Questions pertaining to emission unit startup 

and shutdown are asked in order to provide EPA with an understanding of the duration, emissions potential, work 

practices, and control mechanisms of startup and shutdown events for the wide variety of equipment used at pulp 

and paper mills. The EPA is considering standards that could apply during startup and shutdown events (or whether 

the current standards developed for normal operation should apply) in light of the December 2008 vacatur of the 

NESHAP startup, shutdown, and malfunction exemption in 40 CFR Part 63, subpart A. The startup and shutdown 

questions would also identify pulp and paper emission unit types for which startup and shutdown are not already 

addressed with the current emission standards. You are asked to supply information for routine startup and 

shutdown events associated with planned process or mill downtime. (Do not provide information for unplanned 

startup/shutdown events associated with equipment malfunctions.) The startup and shutdown data in the PI Equip 

detail tab are being sought for regulatory development purposes and will not be used for enforcement purposes. 

c. PI Permit limits tab

Permit limits for each emission unit/point listed in Attachment 1 of this document are requested. You are only asked 

to include permit limits for the emission units listed in Part I Attachment 1 at this time. However, you may also 

include permit limits for the chemical recovery combustion source emission units listed in Part III Attachment 1 

(and, therefore, would not need to include these limits in Part III).

If available in the permit, provide limits in terms consistent with the suggested units shown in Table 2 below. These 

suggested units were taken from existing Federal limits codified in 40 CFR Part 60, subpart BB or 40 CFR Part 63,

subparts S or MM. Specify permit limits as written in the permit if the suggested units are not included in the 

permit. You do not need to convert limits to the suggested units. You may specify limits for a given pollutant in 

multiple units/formats (e.g., ppmdv and/or % reduction) if the permit is written to include multiple compliance 

options. However, you do not need to provide every unit/format for pollutants with multiple limits in different units 

of measure or formats (e.g., only provide ppmdv and gr/dscf at specified % oxygen (O2) for a combustion unit sulfur 

dioxide (SO2) limit specified in the permit in terms of ppmdv, lb/hr, lb/day, and tpy, gr/dscf at specified % O2, etc.). 

The survey spreadsheet allows for up to five different permit limit formats for the same pollutant. Permit limits of 

most interest to EPA are concentration limits (ppmdv, gr/dscf, etc.), percent reduction, mass per unit production 

(lb/ton of material throughput, etc.) because these limits can be compared from facility to facility independent of 

emission unit or mill capacity. Mass emission rate limits (lb/hr or tpy) are not being requested unless this is the 

only way in which limits are specified in the permit. Please note:

Permits restating NESHAP and NSPS limits. Your permit may simply restate the emission limits contained 

in Federal rules such as NESHAP subparts S and MM and NSPS subparts BB or Db. Some permits may 

list all of the compliance options contained in the Federal rules as permit limits. If this is the case, you do 

not need to enter permit limits that are exactly the same as Federal NESHAP or NSPS. Instead, specify the 

applicable Federal rule (not the specific numeric Federal limits) in Column F and skip the remaining permit 

questions/columns in the table. If your permit contains additional State limits in terms other than the 

Federal limit, please indicate these limits in the appropriate column (e.g., Column G for permit limit 1, 

Column J for permit limit 2, etc.) Please do not enter State lb/hr or tpy emission limits in addition to the 

Federal limits.

Opacity. The opacity limits of most interest to EPA are those for fuel-fired equipment such as recovery 

furnaces, semichemical combustion units, lime kilns, boilers, and thermal oxidizers. You do not need to 

include State opacity limits for every emission unit (only the fuel-fired units).

EPA will use the permit limit information you supply in comparing permit limits across similar emission units 

nationwide. Please be as specific as possible when entering permit limit units. Include any oxygen correction 

factors (% O2). Be sure to note if ppm values are on a dry (d) or volume (v) or weight (w) basis if specified this way 

in your permit (ppmdv, ppmdw, ppmv, ppmw). 
Part I Form Approved __/__/__

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Approval Expires __/__/__

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While we would prefer to receive data in the PI Permit limits tab, we will accept a copy of your operating permit

(e.g., title V operating permit) instead of the completed PI Permit limits tab. Other complete and up-to-date 

summaries of permit limits, such as a mill-specific summary of permit limits or compliance matrix, would be 

acceptable as well.

Table 2. Suggested Units of Measure for Permit Limits

Pollutant Suggested units

PM1 Recovery furnaces/chemical recovery combustion units: gr/dscf @ 8% O2

SDT: lb/ton BLS

LK: gr/dscf @10% O2

PM10

1 Other processes: lb/ton of throughput, lb/MMBtu, gr/dscf, g/dscm, or specify

PM2.5

1

Opacity % (provide averaging time)

TRS RF/combustion units: ppmdv @ 8% O2

SDT: lb/ton BLS (as H2S)

LK: ppmdv @ 10% O2

Other processes: lb/ADT pulp and/or ppmdv

SO2 lb/MMBtu and/or ppmdv or limits on fuel S content

NOX lb/MMBtu (as NO2) or ppmdv

CO lb/MMBtu or ppmdv

Pb or other HAP metals Specify units

VOC lb/{production}, specify if as propane, etc. or ppmdv

THC Report as carbon. 

RF/combustion units: lb/ton BLS

HCl ppmdv and/or % reduction

Methanol and gaseous organic 

HAP

chemical recovery combustion sources: lb/ton BLS

process sources: ppmv @ 10% O2, lb/ton ODP, and/or percent reduction

Chlorine and chlorinated HAP ppmv, lb/ton ODP, and/or percent reduction 

Other speciated HAP (specify...) Specify units

1

Specify filterable and/or condensable if your permit limits distinguish between the filterable and condensable PM 

fractions.

d. PI Controls tab

Complete the Controls tab by following the instructions in the “Instruction” row for add-on APCDs used to control 

pulp and paper emission units. The data requested in the Controls tab include pertinent control device design 

parameters that will be used by EPA to distinguish among control devices (e.g., pressure drop and L/G ratio can be 

used to identify high- vs. low-efficiency wet scrubbers) and to understand the non-air environmental impacts 

associated with the control devices (e.g., amount of wastewater or solid waste generated and methods for handling).

Baghouses, cyclones, and other material handling equipment. The EPA is most interested in details for control 

systems used to reduce HAP emissions (for equipment in the NESHAP source categories) and criteria air pollutant 

emissions from equipment in the NSPS subpart BB source category. You do not need to include the specific details

requested in the Controls tab for control devices used solely for wood/material handling operations (e.g., baghouses 

or cyclones on pneumatic wood handling systems, etc.).

Boilers. You do not need to include APCD details for boilers in the Controls tab since NCGs combusted by boilers 

are presumed to be destroyed in the boiler and are subsequently unaffected by the boiler’s APCD. 

Control efficiency. Actual control efficiencies are requested for PM, TRS, HCl, SO2, and other HAP. This 

information will be used in determining the capability of different control devices for reducing emissions. If you 

have data from inlet/outlet emissions testing used to determine a percentage reduction in the requested pollutant 
Part I Form Approved __/__/__

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across the control device, then you would enter this test result as the “actual” control efficiency. Leave the control 

efficiency columns blank if actual control efficiency is not known (or not applicable for a given pollutant). 

Strippers. Specific information for strippers used to reduce air emissions from process liquid or wastewater streams 

is requested in the PI Equip detail tab rather than in the Controls tab.

Thermal oxidizers. Questions pertaining to thermal oxidizers are included in both the Controls and PI Equip detail

tabs. The PI Equip detail tab contains questions about heat input capacity, equipment incinerating NCG or SOG,

and primary or supplemental fuels.

Control device startup and shutdown. The EPA is considering standards that could apply during startup and 

shutdown events (or whether the current standards developed for normal operation should apply) in light of the 

December 2008 vacatur of the NESHAP startup, shutdown, and malfunction exemption in 40 CFR Part 63 subpart 

A. Questions pertaining to control device startup and shutdown are asked in order to provide EPA with an 

understanding of the duration and definition of startup and shutdown events for the types of control devices used at 

pulp and paper mills. The EPA is seeking information on the integral nature of startup and shutdown events for the 

different combinations of emission units and control devices used in the pulp and paper industry. In addition, 

because Federal NSPS and NESHAP require continuous monitoring of emissions or control device operating 

parameters, information is requested to inform EPA of particular pulp and paper NSPS or NESHAP control device 

parameter limits that cannot feasibly be met during startup and shutdown events. Certain parameters may be 

"instant on" while others are more transient in nature (i.e., changing as startup or shutdown progresses). Examples 

could include control device temperature that must heat up to a set point, or pressure drop that cannot be achieved 

due to low exhaust gas flow from the emission unit. The EPA will use this information to evaluate which existing 

control device parameter limits may remain in effect during startup and shutdown events, and which parameter 

limits may need to be replaced with another requirement during startup and shutdown. In all of the control device 

startup and shutdown questions, you are asked to supply information for routine startup and shutdown events

associated with planned equipment or mill downtime. (Do not provide information for unplanned startup/shutdown 

events associated with equipment malfunctions.) The startup and shutdown data in the Controls tab are being 

sought for regulatory development purposes, and will not be used for enforcement purposes. 

e. Pulp prod tab

The Pulp prod tab is to be completed by all mills that produce pulp onsite using chemical, semichemical, 

mechanical, non-wood, and secondary fiber pulping processes. This tab is arranged in a way to accommodate 

multiple pulping processes or pulping lines (if applicable) and each pulping process/line should occupy only one 

row (e.g. a mill that co-produces kraft and mechanical pulps should use two rows). Some data fields apply for 

specific types of pulp (e.g., mechanical pulp, non-wood pulp). If a data field does not apply to a particular type of 

pulping line, simply leave the field blank. Provide data for the 2009 operating year. 

The pulp capacity data will be used by EPA to understand the general mill flow and in estimation of impacts and 

economic analyses. In the Pulp prod tab, the 2009 pulp capacity (ADTP/d) and capacity utilization refer to 

unbleached pulps (i.e., pulp exiting the pulping line prior to any brightening or bleaching). [Note: Capacity of 

bleached pulp (e.g., pulp exiting the bleaching/brightening line) is requested in the Bleaching tab.] An example of 

how to calculate the pulp capacity utilization percentage requested in the Pulp prod tab is as follows:

A B C D E F

Pulping 

process

Pulp 

capacity 

ADTP/d 

in 2009

Maximum 

d/yr

Actual 2009 

operating d/yr 

when pulp was 

produced

2009 capacity, 

ADTP/yr

(= A x B)

2009 actual 

production, 

ADTP/yr*

(= A x C)

Pulp capacity 

utilization decimal

percentage in 2009

(= E / D)

kraft 950 365 340 346,750 323,000 0.93

mechanical 300 365 250 109,500 75,000 0.68

ADTP/d = air dried tons of pulp per day. *The 2009 actual pulp production could be determined by multiplying 

columns A x C or by other means. The EPA is not asking that you report the 2009 actual production.
Part I Form Approved __/__/__

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In the Pulp prod tab, EPA asks questions regarding how various pulps are used by the mill in order to understand the 

mill flow for purposes of economic modeling. With these questions, EPA seeks the amount of unbleached pulp 

from the pulping line that typically:

 goes to an onsite bleaching/brightening line (if applicable)

 is sold (or transferred to another mill within the same company) as unbleached market pulp

 is used onsite to manufacture unbleached paper/paperboard

Complete the Pulp prod tab by following the instructions in the “Instruction” row.

f. Byproducts tab

Mills that recover turpentine or tall oil from pulping processes should complete the Byproducts tab. Basic turpentine 

and tall oil production information are requested (hr/yr, gal/day and equipment supplying byproduct production). 

Turpentine recovery systems are covered under subpart S. Tall oil production may be considered in the review of 

pulp and paper regulations. The information requested may be used to estimate emissions and in economic 

calculations.

Complete the Byproducts tab by following the instructions in the “Instruction” row.

g. Kraft condensates tab

Complete the Kraft condensates tab by following the instructions in the “Instruction” row. Enter the Emission Unit 

IDs or Collection system IDs for each kraft condensate stream. Common condensate sources are listed in the Kraft 

condensates tab (e.g., digester systems, turpentine recovery systems, evaporator systems, HVLC and LVHC 

collection systems). Complete the questions in table headings I through VII as applicable (depending on the 

condensate treatment method your mill uses to comply with subpart S). The kraft condensate control options are 

summarized as follows. This table corresponds with the pull down menu options for condensates treated by steam 

strippers, biological treatment, or other means. 

Control option Applicability Rule reference

92% total HAP reduction (by weight) §63.446(e)(3)

Remove 6.6 pounds/ton ODP Mills that do not bleach §63.446(e)(4)

210 ppmw at the outlet of the control 

device Mills that do not bleach §63.446(e)(4)

Remove 10.2 pounds/ton ODP Mills that bleach §63.446(e)(5)

330 ppmw at the outlet of the control 

device Mills that bleach §63.446(e)(5)

Remove prorated mass of ___ pounds/ton 

ODP. {Respondent should specify limit in 

blank}

Mills producing a 

mixture of bleached and 

unbleached pulp §63.446(i)

If your mill uses multiple treatment methods for a given kraft condensate stream, please answer the questions for 

each treatment method (under table headings III, IV, V, and/or VI) and the question in table heading VII. For 

example, if your mill normally treats condensates with a steam stripper but relies on biological treatment when the 

stripper is down, then you would respond to the questions under table headings IV (stripping), V (biological 

treatment), and VII (multiple treatment methods). 
Part I Form Approved __/__/__

OMB Control No. ____-____

Approval Expires __/__/__

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h. CCA tab

The CCA tab is divided into two portions: (1) Emission Balance to the left of the orange vertical line (column I), and 

(2) CCA Equipment List on the right of the orange vertical line. You will enter one row of data for the Emissions 

Balance and multiple rows of data for the CCA Equipment List. This information is being requested to inform EPA 

of the mill-specific emission units involved in CCA compliance calculations.

The CCA tab must be completed once for each set of CCA compliance calculations used by your mill. Add another 

CCA tab if you need to provide more than one set of CCA calculations. As an alternative to completing the CCA 

tab, you may attach separate documentation of your CCA calculations used for purposes of showing compliance. 

Sources eligible for inclusion in the CCA as credit generators include: pulping systems, bleaching systems, 

causticizing systems, and papermaking systems. Debit generating sources can include equipment from the kraft 

mill HVLC system, including: pulp washing systems, knotter systems, screen systems, decker systems, O2

delignification systems, and weak liquor storage tanks. Refer to the system definitions in subpart S at §§63.441 and 

63.447(a). If equipment other than that listed above is included in your CCA calculations, please include that 

equipment in the CCA tab. EPA is interested in identifying which mills are using the CCA option and the millspecific equipment used in CCA calculations. EPA is not requesting detailed calculations used to show compliance 

with the CCA at this time. However, EPA reserves the right to request additional detail if needed as a follow-up to 

this survey. 

Complete the CCA tab by following the instructions in the “Instruction” row.

i. Bleaching tab

All mills that perform bleaching or brightening of chemical, mechanical, secondary fiber, or non-wood pulps should 

complete the portion of the Bleaching tab to the left of the orange vertical line (column M) to describe the bleaching

(or brightening) systems used at your mill. Note that, for brevity, the terms “bleaching” and “brightening” are used 

interchangeably in the Bleaching tab (e.g., the word “bleaching” can be read to me “brightening” if that is the 

process your mill uses). 

Your response in the Bleaching tab will consist of one row for each bleaching/brightening line located at your mill.

Most mills will have only one or two bleaching line rows. For example, a mill that produces bleached chemical 

pulp, bleached secondary fiber pulp, and brightened mechanical pulp could include three rows (one for each type of 

pulp that is bleached/brightened using separate bleaching/brightening processes).

If your bleaching system includes any stages that use chlorine or chlorinated compounds, then you must complete

the portion of this tab to the right of the orange vertical line. Extraction or other bleaching stages that do not use 

chlorine or chlorinated compounds are not covered by subpart S and should be reported in the Bleaching tab with 

“NR (no chlorine or chlorinated compounds used in this stage)” indicated. 

When specifying controls used for the various bleaching stages, enter not applicable “NA” for stages without 

control. Enter the APCD_ID used in the PI Equip detail and PI Controls tabs when referring to any control device. 

Each bleaching stage includes several vents: the tower vent, washer hood, seal tank vent, chemical and steam 

mixers, and vacuum pumps. If all vents from a particular bleaching stage are not routed to the control device 

indicated for that stage, then you should describe the control system configuration in the control methods column.

Responses to these bleaching questions will be used to characterize mills according to bleaching processes used, 

estimate nationwide emissions, and identify subpart S compliance options commonly used (e.g., to determine if any

remaining residual risk is associated only with bleaching at mills meeting certain compliance options). Information 

on how the mill uses the pulp exiting the bleach plant may be used for economic modeling and in characterization of 

potential emissions from paper machines (e.g., use of bleached/unbleached pulp produced onsite, use of purchased 

pulp, effects of bleaching process on paper machine emissions, etc.).
Part I Form Approved __/__/__

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Approval Expires __/__/__

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Complete the Bleaching tab by following the instructions in the “Instruction” row.

j. Paper prod tab

All mills that produce paper should complete the Paper prod tab. Report information for all operable paper 

machines (including idle machines that are capable of operating in the future). Do not include pulp dryers in the 

Paper prod tab. Complete the Paper prod tab by following the instructions in the “Instruction” row.

If multiple paper grades are produced on the same paper machine (e.g., coated free sheet produced some of the time, 

and uncoated freesheet produced at other times), then you will need to include paper machine information on 

separate rows. Given the numerous specific grades of paper and paper characteristics, EPA requests that you 

distinguish among a relatively short list of generalized paper grades, including: 

coated free sheet kraft packaging

uncoated free sheet linerboard

coated groundwood corrugating medium

uncoated groundwood solid bleached board

tissue & sanitary recycled board

specialty packaging & industrial construction paper and board

other *

*Respondents are asked to specify a general paper grade in the event that one of the 

 general grades listed above is not representative.

Information on pulp type is requested because it is possible that pulp type may have an effect on emissions 

(particularly for bleached versus unbleached pulps). Should EPA consider paper machines for residual risk 

rulemaking, information such as pulp type, whether the pulp is bleached or unbleached, paper grade, stock 

consistency, and liquid HAP concentration may be useful for purposes of subcategorizing of paper machines. 

You are asked to specify the approximate makeup of each paper machine furnish - specifically the approximate 

percentage of each pulp type. We recognize that the percentage can vary throughout the operating year and within 

paper grades (due to specific product variations), and therefore, a specific percentage is not being requested. It will 

be sufficient to round to the nearest 5 or 10 percent.

k. HAP additives tab

Complete the HAP additives tab for any stock preparation and paper machine additives that contain “measurable”

concentrations of one or more of the following HAP: formaldehyde, acetaldehyde, napthalene, methylene chloride, 

acrylamide, or benzene. Only include in this tab additives with measurable quantities of HAP as reported on the 

material safety data sheet (MSDS) for the additive. For purposes of this survey, “measurable” is defined consistent 

with OSHA requirements that chemical suppliers provide specific constituent amounts in Material Safety Data 

Sheets for any carcinogens that are present in amounts greater than 0.1 percent and any non-carcinogens that are 

present in amounts greater than 1 percent. Although it is unclear whether paper machine additives contribute 

significantly to paper machine emissions (e.g., because additives may partition to the paper product or white water, 

and not necessarily to the air), EPA is requesting information for paper machine additives that contain HAP of 

significance for purposes of residual risk. EPA is not requesting information for other paper machine additives 

(many of which contain no HAP), except in determining any non-HAP substitutes for the additives. The HAP 

additives information would be used (e.g., along with emissions data for paper machines) to identify HAPcontaining additives that may contribute significantly to paper machine HAP emissions or residual risk, and to 

evaluate work practices related to additives. 

Complete the HAP additives tab by following the instructions in the “Instruction” row.
Part I Form Approved __/__/__

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l. WW tab

All mills with onsite wastewater treatment plants (WWTP) should complete the WW tab columns to the left of the 

orange vertical line (column X). The purpose of the WW tab is to provide EPA with information regarding the status 

of permitting requirements and emissions measurement for pulp and paper mill wastewater treatment plants. This 

information will be used by EPA for purposes of reviewing the pulp and paper regulations (e.g., NSPS and/or 

NESHAP subpart S). Use the WW tab to specify any Federal/State/local requirements, permit limits, fence-line 

monitoring, measurement methods (such as ambient measurements), or modeling methods that apply for 

measurement or estimation of HAP and TRS (including H2S) air emissions associated with the wastewater treatment 

system.

In addition to questions about measurement and permitting status, mills are requested to submit a flow diagram of 

the WWTP (see section D1 of these instructions) and to complete some basic questions regarding WWTP capacity, 

the sequence of wastewater treatment units, and upstream controls/practices that reduce air emissions from the 

WWTP. Mills are also asked to identify any wastewater treatment units that are closed to limit emissions to the 

atmosphere, or equipped with a closed-vent collection system and APCD. If any wastewater treatment units are 

equipped with a closed-vent collection system and APCD, then you should also include the wastewater treatment 

unit in the Emission Unit ID column of the PI Equip detail and Control tabs and indicate the APCD information in 

those tabs. 

The series of questions seeking an approximate volume percentage of WWTP capacity from various mill areas will 

inform EPA of the overall nature of the wastewaters generated by pulp and paper mills for treatment. For this series 

of questions, if the WWTP is a joint treatment facility and treats process wastewater from several mills owned by 

the same company, then the questions should be answered for each individual pulp and paper mill in their survey 

response considering the total volume of wastewater sent to the WWTP by that mill. 

Mills with wastewater treatment plants that serve as the biological treatment system for the subpart S kraft 

condensate standards must complete the questions to the right of the orange vertical line in the WW tab. These 

questions request the subpart S quarterly biological treatment system compliance testing results for the four quarters 

of calendar year 2009. This information will inform EPA of the performance of biological treatment systems in 

destroying HAP.

Complete the WW tab by following the instructions in the “Instruction” row.

D3. Test data

Attachment 3 of this Part I survey contains a table of emission units and pollutants for which existing 

emissions data are requested. Emissions data are being requested in the form of emissions test reports or continuous 

emissions monitoring data, whichever may be available. You are not required to conduct any new emissions 

testing or continuous emissions monitoring to respond to this survey. Follow the instructions below for the 

“Emissions test data tab” for emissions test reports. Follow the instructions for completing the “CEMS data 

spreadsheet (P&P CEMS_PI.xls)” if you have continuous emissions monitoring system (CEMS) data instead of 

emission test reports for a given emission unit and pollutant combination. The emissions test data collected will 

provide valuable information on current emissions levels and will allow EPA to consider variability in emissions 

from mill to mill (and over time for a given emission unit and pollutant) in reviewing and setting emission standards. 

When submitting test data, EPA is requesting full test reports with field and lab data sheets and example 

calculations, not just summary reports.

a. PI Emissions test data tab

Attachment 3 of this survey contains a table of emission units and pollutants for which existing emission test data

are requested. You are not required to conduct any new emissions testing to respond to this survey. The EPA is 

only requesting existing emission test reports at this time as they may already be available. 
Part I Form Approved __/__/__

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Emissions test data are not requested for power boilers unless the power boiler is used to control NCGs or SOGs (in 

which case the test data requested are for the pulping systems controlled by the power boiler, assuming these 

emissions points have been tested).

Review the test data request table in Attachment 3 of this survey. Locate any existing emissions test reports in your 

files that match the test method and other criteria for each emission unit and pollutant combination requested. 

Emissions test data representative of your current operations are requested. You are not required to supply 

emissions data that are no longer representative of the current emission unit and control system configuration. For 

example, if you have installed controls or made significant process changes expected to change emissions, then you 

need not supply emissions data for the prior configuration. However, you may voluntarily supply emissions data for 

prior configurations, as such information would be useful to EPA in characterizing emissions in general (for nonsite-specific uses), but we request that you identify that such data are no longer representative in the PI Emissions 

test data tab.

Cutoff dates are provided in Attachment 3 for certain emission unit and pollutant combinations. More recent cutoff 

dates (e.g., 2001 or date of MACT compliance) are specified for emission unit and pollutant combinations expected 

to be widely available. Longer cutoff dates (e.g., dating back to 1990) are included for emission unit and pollutant 

combinations for which data are likely to be sparse. Test data prior to the cutoff dates are requested only if 

necessary to obtain results of at least one representative test for a given process unit and pollutant.

Provide available test data for multiple years dating back to the cutoff date. Multiple years of test data will allow 

EPA to examine and account for variability in emissions in setting emissions standards. 

Supply both APCD inlet and outlet data if available. 

As noted above, submit full and complete copies of the emission test reports, to include field and lab data sheets and 

example calculations, meeting the criteria in Attachment 3 with your survey response. Electronic (pdf) or hard 

copies are acceptable. Include the summary portion of the report and any appendices showing run-by-run test 

parameters, method detection limits, laboratory data, production data, example calculations, etc. EPA will extract 

the test data from the emission test reports for use in nationwide regulatory analyses.

Complete the PI Emissions test data tab to identify the specific emission units and control systems for which 

emission test reports are being submitted, the pollutant tested, and the test method. The PI Emissions test data tab 

will be used by EPA as the starting point for development of the emissions test data base that EPA intends to

construct based on the emissions test data received through this survey.

b. CEMS data spreadsheet (P&P CEMS_PI.xls)

The EPA is requesting existing CEMS data and/or continuous opacity monitoring system (COMS) data for calendar 

year 2009 (CY2009) operations from facilities that have installed continuous monitoring systems. You are not 

required to install or operate any new CEMS or COMS to respond to this survey.

CEMS data that are representative of your current operations are requested. You are not required to supply CEMS 

data that are no longer representative of the current emission unit and control system configuration. 

You do not need to supply CEMS data for power boilers unless the boiler has a CEMS installed to show compliance 

with a NESHAP subpart S (or subpart MM) or NSPS subpart BB emission limit. 

A separate Microsoft Excel spreadsheet file (P&P CEMS_PI.xls) is provided for submittal of the requested CEMS 

data. The spreadsheet file contains individual worksheets (tabs) designed specifically for TRS (12-hour block 

average), TRS (hourly), Opacity, NOx, SO2, CO, Methanol, Chlorine, and PM. Each worksheet is designed to 

accommodate data from one CEMS (including oxygen data). If you have multiple CEMS of the same type (e.g., 
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two TRS CEMS on different emission units), then you must copy the relevant worksheet in order to enter data for 

the additional CEMS.

A brief introduction to each of the CEMS worksheets follows. Additional, field-specific instructions are included on 

each worksheet. An “EXAMPLE” completed worksheet is also provided as a separate tab within the P&P 

CEMS_PI.xls spreadsheet file.

TRS (12-Hour Average). This worksheet is designed for recovery furnaces, smelt dissolving tanks, lime 

kilns, digester systems, brown stock washer systems, multiple effect evaporator systems, and condensate 

stripper systems subject to the TRS monitoring requirements in NSPS subpart BB, but can be used for any 

emission units with TRS CEMS (e.g., for compliance with State emissions standards which may be based on 

the TRS emissions guidelines). Respondents are requested to specify the Emission Unit ID (or Collection 

system ID), the APCD_ID, and report the 12-hour averages of CEMS concentration data for TRS for 

CY2009 operations. In addition, respondents are asked to provide the highest single 12-hour average TRS 

concentration recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or 

shutdown, and (c) under malfunction conditions. [Note: The reported concentrations of TRS should be 

corrected to 8% O2 for recovery furnaces and 10% O2 for lime kilns and other equipment.]

TRS (1-Hour Average). Same as above, except that this worksheet is designed to accept the 1-hour average 

TRS data for the sametime period as provided for the 12-hour averages.

Opacity. This worksheet is designed for recovery furnaces or lime kilns equipped with COMS but may be 

used for thermal oxidizers and other equipment. Respondents are requested to specify the Emission Unit ID

(or Collection system ID) and the APCD_ID, and report the 6-minute average opacity for CY2009

operations. An optional column is also included for hourly average opacity for mills that calculate an hourly 

average. In addition, respondents are asked to provide the highest single 6-minute average opacity recorded

in CY2009: (a) under normal operating conditions, (b) under conditions of startup or shutdown, and (c) under 

malfunction conditions. 

NOx, SO2, and CO. These worksheets are designed for recovery furnaces or lime kilns equipped with CEMS 

for NOx, SO2, or CO, but can be used for other emission units equipped with these CEMS. Respondents are 

requested to specify the Emission Unit ID (or Collection system ID) and the APCD_ID (or type of 

combustion controls used), and report the 1-hour averages of the CEMS data for these compounds for 

CY2009 operations. In addition, respondents are asked to provide the highest single 1-hour average 

concentration recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or 

shutdown, and (c) under malfunction conditions. 

Total HAP or Methanol. This worksheet is designed for total HAP or methanol CEMS installed to 

demonstrate compliance with the NESHAP subpart S limits for LVHC systems, HVLC systems, or steam 

strippers (but can be used for other emission units equipped with these CEMS). Respondents are requested 

to identify by Emission Unit ID (or Collection system ID) the source of the NCGs/SOGs being controlled,

specify the APCD_ID, and report the 1-hour averages of the CEMS data for CY2009 operations. In addition, 

respondents are asked to provide the highest single 1-hour average recorded in CY2009: (a) under normal 

operating conditions, (b) under conditions of startup or shutdown, and (c) under malfunction conditions.

Total Chlorinated HAP or Chlorine. This worksheet is designed for total chlorinated HAP or chlorine CEMS 

installed to show compliance with the NESHAP subpart S limits for bleaching systems (but can be used for 

other emission units equipped with these CEMS or HCl CEMS). Respondents are requested to indicate the 

Emission Unit ID (or Collection system ID) being controlled and APCD_ID, and report the 1-hour averages 

of the CEMS data for CY2009 operations. In addition, respondents are asked to provide the highest single 1-

hour average recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or 

shutdown, and (c) under malfunction conditions.
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PM. This worksheet is designed for any emissions unit equipped with a PM CEMS. Respondents are 

requested to specify the Emission Unit ID (or Collection system ID) and the APCD_ID, and report the 1-hour 

averages of the CEMS data for CY2009 operations. In addition, respondents are asked to provide the highest 

single 1-hour average concentration recorded in CY2009: (a) under normal operating conditions, (b) under 

conditions of startup or shutdown, and (c) under malfunction conditions. 

OPTIONAL-CEMS cost. Completion of this worksheet is OPTIONAL. This worksheet requests equipment 

cost data for CEMS or COMS installed within the past 10 years. EPA can use these data to estimate costs of 

CEMS or COMS when evaluating monitoring options.

D4. Optional cost data

The EPA requests information related to the capital and operating costs of selected air pollution controls or 

process/equipment changes. Providing this cost information to EPA is optional at this time. The Agency wishes to 

receive enough cost information on a voluntary basis to perform regulatory analyses. However, should additional 

cost information be needed, EPA reserves the right to follow up with mills that have installed equipment or 

implemented process changes of interest to request cost information under CAA section 114 authority. 

The spreadsheet entitled “P&P costs OPTIONAL_PI.xls” can be completed to provide cost information. This 

spreadsheet contains two tabs (APCD costs and Equip change costs). The EPA recognizes that cost information can 

be sensitive. The “P&P costs OPTIONAL_PI.xls” spreadsheet contains a red block at the top of each tab where you 

can indicate if the tab contains CBI, or if the entire tab should be treated as CBI. Responses containing CBI should 

be submitted according to the instructions in section C2 of this document.

Any cost information that you provide would be very useful to EPA for purposes of evaluating the costs of control 

measures that may be considered as regulatory options. These cost data will be used by EPA to estimate the 

nationwide costs of any regulatory options based on the control measure indicated. Cost information from within

the last 10-12 years is requested (e.g., costs dating back to 1998). The cost information could come from vendor 

quotes for APCD or equipment changes that either have been implemented or were explored but not implemented.

For Part I, the EPA is particularly interested in costs of the following APCDs. Please supply this information using 

the APCD costs tab:

 - Paper machine HAP control devices

 - Controls that reduce HAP emissions from wastewater handling and treatment systems 

What if my data are not in a form that can be inserted into P&P CEMS_PI.xls? 

It is very helpful for EPA’s data analysis purposes if data are entered into the P&P CEMS_PI.xls 

template provided. However, we understand that some CEMS software may not be configured to 

provide output that can be easily converted to our preferred spreadsheet format. We also 

understand that, in some cases, the hourly production data requested in the CEMS spreadsheet 

may not be coupled with the CEMS data or may not be available in a manner to be easily linked to 

the CEMS data. If you face these or related issues, please note that EPA is not asking you to hand

enter hard copy CEMS data into the spreadsheet. You may provide CEMS data in an alternative 

format if you are unable to convert it to our spreadsheet format within the timeframe for this 

survey. We request that you provide CEMS data in a form suitable for analysis if possible (e.g., 

spreadsheet or data base format is preferred over read-only pdf format). We’d accept more recent 

CEMS data (e.g., from the most recent 6 months) if 2009 CEMS data are no longer in electronic 

form due to company records retention policies. Further, you may omit the production data if they 

cannot reasonably be included in your CEMS spreadsheet. Estimates of production data are 

acceptable (e.g., if you have a daily production rates, you may divide by 24 operating hours in a 

day to estimate hourly production). 
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 - Bleach plant CO control devices

The EPA is particularly interested in costs of the following process changes or equipment changes/upgrades. Please 

supply this information using the Equip change costs tab.

 - Process changes that reduce HAP emissions from wastewater handling and treatment systems 

 - Process changes to improve lime mud washing or to control makeup water quality in the causticizing area

 - Process changes that reduce paper machine HAP emissions

Complete the APCD costs and Equip change costs tabs by following the instructions in the “Instruction” rows of 

those tabs. You may also submit information in an alternative format (e.g., as an attachment to your response) if 

needed. Because the cost data will be used by EPA to estimate the nationwide costs, please note if you believe that 

any portion of the cost information that you supply would be completely unrepresentative of costs that other mills 

may face for similar control projects (e.g., if your project capital cost included installation of extra buildings, land 

purchases, etc. that may not be required for other mills). 
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PART I - ATTACHMENT 1

Emission Units to Include in the Part I Pulp and Paper Survey Response

Include the following types of equipment (emission units) in your Part I survey response. You may not operate all 

of the emission units listed below. Only include equipment operated at your mill. [Note: Chemical recovery 

combustion units are included in Part III.] 

Causticizing Equipment

Green liquor clarifier

Green liquor storage tank

Green liquor surge tank

Slaker

Causticizers

White liquor clarifier

White liquor storage tank

White liquor pressure filter tank

White liquor/weak wash pressure filter

Weak wash storage tank

Dregs washer

Dregs filter exhaust

Salt cake mix tank

Lime mud washer

Lime mud filter system

Digester Area Equipment

Digester

Chip bin

Chip steaming vessel

Flash tank

Blow tank

Condenser

Turpentine decanter

Pulp Washing, Thickening, and Storage Equipment

Brown stock washers

Hoods

Filtrate tanks

Vacuum pumps

Screens

Knotters

Decker

Stock chests (including open stock chests)

Pulp storage tanks

Thickeners

Pulp dryers

Evaporators

Black liquor storage tanks

Evaporator hot wells

Condensers

Boilout tanks

Soap storage tanks

Soap skimmer tanks

Other emission points associated with evaporators. 

Oxygen Delignification Equipment

Oxygen delignification reactor

Oxygen delignification blow tank

Oxygen delignification washer

Post-oxygen washer filtrate tank

Pulp storage tanks 

Other oxygen delignification system emission points.

Non-condensable Gas (NCG) Collection

LVHC system

HVLC system

Stripper System Equipment

Stripper feed tanks

Condensers

Heat exchangers

Methanol Rectification Equipment

Rectifiers

Condensers

Decanters

Storage tanks 

Storage Tanks

Weak liquor storage tanks

Strong liquor storage tanks

Liquor storage ponds

Acid condensate storage tanks (at sulfite mills)

Tall Oil Production Equipment

Tall oil acidulation reactor

Storage tank

Dehydrator

Brine storage tank

Screen

Centrifuge tank

Other tall oil production vents 

Bleaching Equipment

Tower vents

Washer hoods

Seal tank vents

Chemical and steam mixers

Vacuum pumps
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Mechanical Pulping Equipment

Stone grinder

Refiner

Chip pre-steaming vessel

Chip cooker 

Screen 

Decker

Brightening/bleaching tower 

Non-wood Pulping Equipment

Secondary Fiber Pulping Equipment

Paper Making Equipment

Paper machines

Pulp dryers

Machine chest

Repulpers

Stock blending and storage tanks

Broke tanks

Savealls

White water storage tanks

Wastewater Treatment System Units

Clarifiers

Settling ponds

Aerated stabilization basins

UNOX systems

Wastewater tanks

Other wastewater handling and treatment units 

Power Boilers – PI Equip detail tab only

Thermal Oxidizers/Incinerators

Woodyard Operations
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PART I - ATTACHMENT 2

Small Business Size Standards

Small Business Size Standards for NAICS Subsector 322 – Paper Manufacturing

NAICS

Codes

NAICS U.S. industry title Size

standards in

number of

employees

322110 Pulp Mills 750

322121 Paper (except Newsprint) Mills 750

322122 Newsprint Mills 750

322130 Paperboard Mills 750

322211 Corrugated and Solid Fiber Box Manufacturing 500

322212 Folding Paperboard Box Manufacturing 750

322213 Setup Paperboard Box Manufacturing 500

322214 Fiber Can, Tube, Drum, and Similar Products Manufacturing 500

322215 Non-Folding Sanitary Food Container Manufacturing 750

322221 Coated and Laminated Packaging Paper Manufacturing 500

322222 Coated and Laminated Paper Manufacturing 500

322223 Coated Paper Bag and Pouch Manufacturing 500

322224 Uncoated Paper and Multiwall Bag Manufacturing 500

322225 Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses 500

322226 Surface-Coated Paperboard Manufacturing 500

322231 Die-Cut Paper and Paperboard Office Supplies Manufacturing 500

322232 Envelope Manufacturing 500

322233 Stationery, Tablet, and Related Product Manufacturing 500

322291 Sanitary Paper Product Manufacturing 500

322299 All Other Converted Paper Product Manufacturing 500

Source: U. S. Small Business Administration Table of Small Business Size Standards Matched to North American 

Industry Classification System Codes, Effective August 22, 2008. Accessed June 16, 2009 at: 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf
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PART I - ATTACHMENT 3

Part I Emissions Test Data Request

(Note: Test Reports submitted should be full and complete copies of the emission test reports, to include field and 

lab data sheets and example calculations.)
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Part I - Attachment 3. Pulp and Paper Emission Units and Pollutants for Which Existing Representative Emission Test Data Are Requested

Note: Emissions test data representative of your current operations are requested as described in the survey instructions.

Emission Unit Particulate 

matter (PM)1

Speciated HAP 

metals2

PM2.5 

(fil.)

PM2.5 

(cond.)

Chlorinated 

HAP (Cl)1

Acetaldehyde, 

Formaldehyde, 

and Methanol1

Total 

hydrocarbon 

(THC) as 

carbon

Total reduced 

sulfur (TRS)1,3

Nitrogen 

oxides 

(NOx)1

Sulfur 

dioxide 

(SO2)

1

Carbon 

monoxide 

(CO)1

Test methods4 M5, M29, 

M17

PM CEMS, 

COMS

M29 EPA 

OTM 27

EPA 

OTM 28

Chlorine (Cl2) via 

M26A with 

modifications 

described in 

subpart S

Cl2 CEMS

Methanol: Method 

308 (part 63) or 

Methanol CEMS

Other methods 

(e.g., for 

acetaldehyde & 

formaldehyde)

M25 or M25A M16 or

TRS CEMS

Provide total 

TRS data. Also 

provide 

speciated TRS 

data, if 

available.

M7

CEMS

M6

CEMS

M10

CEMS

Thermal oxidizers Supply most 

recent data Not requested

Supply 

most recent 

data

Digesters, Pulp 

washers, 

Evaporators, 

Turpentine recovery, 

Strippers, O2

delignification, 

Knotters and 

screens, Deckers 

(high density 

storage), and Weak 

and strong liquor 

storage tanks (or 

their associated 

LVHC and/or HVLC 

collection systems)

Not requested

Supply most recent 

data following 

MACT compliance

Supply most 

recent data 

following 

MACT 

compliance

Not 

requested

Sulfite pulping 

sources

Not requested

Supply most recent 

data following 

MACT compliance

Supply most 

recent data Not requested

Wastewater 

treatment systems Not requested

Supply most recent 

modeling or 

measurement data 

(as requested in 

WW tab)

Supply most 

recent modeling 

or measurement 

data (as 

requested in 

WW tab)

Not 

requested
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Emission Unit Particulate 

matter (PM)1

Speciated HAP 

metals2

PM2.5 

(fil.)

PM2.5 

(cond.)

Chlorinated 

HAP (Cl)1

Acetaldehyde, 

Formaldehyde, 

and Methanol1

Total 

hydrocarbon 

(THC) as 

carbon

Total reduced 

sulfur (TRS)1,3

Nitrogen 

oxides 

(NOx)1

Sulfur 

dioxide 

(SO2)

1

Carbon 

monoxide 

(CO)1

Bleaching systems 

subject to subpart S Not requested

Supply most 

recent data 

following MACT 

compliance

Supply most 

recent data 

following 

MACT 

compliance

Paper machine

emission points Not requested Supply most recent 

data

Causticizing area 

sources

Not requested Supply most 

recent data

Stand alone 

semichemical, 

mechanical, 

nonwood, and 

secondary fiber

pulping

Not requested Supply most 

recent data

1

If your emission unit is equipped with a continuous emissions monitoring system (CEMS) or continuous opacity monitoring system (COMS), supply the CEMS and COMS data using the CEMS data 

spreadsheet (P&P CEMS_PI.xls)

2 The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chromium VI (Cr+6) and speciated mercury (Hg) test data if 

available.

3

Speciated TRS would include: hydrogen sulfide (H2S), methyl mercaptan, dimethyl sulfide, and dimethyl disulfide.

4 M = method (e.g., M5 is EPA Method 5). EPA Methods 5, 6, 7, 10, 16, 17, 23, 25/25A, 26/26A appear in 40 CFR Part 60, Appendix A. EPA Method 308 appears in Part 63, Appendix A. The “OTM” test 

methods can be found at http://www.epa.gov/ttn/emc/prelim.html