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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 p ulp 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 d ata (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. By products 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
- AT TA CHMENT 1 Emission Units to Include in the Part I Pulp and Paper Survey Response
.................. 23 PART I
- AT TA CHMENT 2 Sm all Business Size Standards
................................ ................................ .................... 25 PART I
- AT TA CHMENT 3 Part I Emissions Test Data Request
................................ ................................ ............. 26

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## A. Part I Introduction The pulp and paper sector informatio n 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 mechan ical, 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 s ource ” 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 pollut ant 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 follow ing 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 exempt ion 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, perfo rm 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 t o 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 yo u operate). T able 1 below denotes whic h 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 liste d in the Section 114 letter you received in the mail. If you received mo re 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 surve y spreadsheets, they can be dow nloaded 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 emis sion 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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### 3 Use the following attachments to the Survey Overview document for reference: Attachment 2: Regulatory definitions from the k raft 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 Compl ete 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, bl eaching emission units, or papermaking emission unit s . Pulp prod Mills that produce any type of pulp (including chemical, mechanical/groundwood, secondary fiber, including non

- wood pulp) By products Mills that produce turpentine or tall oil byproducts fro m p ulping 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 paperbo ard 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 data 1 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 po llution controls (see sect ion D4 ) Equip change costs Mills implementing selected process or e quipment changes (see section D4 ) 1 Separate tabs are included for different pollutants and for CEMS cost.

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### 4 

## B. Confidential Business I nformation (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 indicat ing 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. How ever, please do not label your entire response as CBI if only a portion includes trade secrets
. The EPA is likely to follow up w ith a request for validation of CBI claims for mills claiming large amounts of information as trade secret s , especially information that is readily reported by other mills without such claims
. 

## C. How to S ubmit Your Part I S urvey R esponse If your respon se 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 t wo different mailing addresses
. 

### C 1 . Submitting Your N on - CBI Response Follow these instructions for the non

- CBI portions of your survey response (or for responses that are entirely non

CBI.) After you have completed and reviewed your survey response , sign and date the certificati on form in Attachment 4 of the S urvey O verview document. R emove the CBI com ponents from your survey as instructed in section C2 . Save the Excel spreadsheet (s) containing the non

- CBI portion s 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 yo ur 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 Ai r 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 Expr ess, or other method for which someone must provide a signature upon receipt. 

### C 2 . 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 spre adsheet response with only the CBI portion of yo ur 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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### 5 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 secur e form s of communication and should never be used to transmit CBI. 

## D. How to Complete the Part I S urvey Your survey response will consist of flow diagrams , test reports, and completed Microsoft Excel spreadsheets. Separate Excel spreadsheet file s 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 ty pe of mill you operate) as shown in Table 1 above. The P&P CEMS_PI.xls s preadsheet file is to be completed if yo u 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. 

### D 1. 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 r ecovery combustion sources in the diagrams submitted in response to Part I. Readily available block flow diagrams (e.g., such as those use d for permit applications) will suffice. Electronic or hard copies are acceptable. You need not prepare any new f low 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 wo uld be helpful for EPA are as follows: Chemical recovery area
. A diagram showing eac h 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 wo uld be helpful
. Pulping process
. A diagram showing the equipment in all pulping lines , including the digester area, pulp wa shing lines, evaporator lines, and o xygen delignification systems , wo uld be useful
. The diagram could show any brown stock washers, hoods, filtrate tanks, vacuum pumps, screens, knotters, deckers, s tock chests (including open stock chests, pulp storage tanks), thickeners, and weak black liquor storage tanks. D eckers, screens, knotters, stock chests, and pulp storage tanks following the last stage of pulp washing and/or those located prior to the pap er machines are also o f interest
. Black liquor gasification . I f 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 , wo uld be helpful
. Wastewa ter treatment plant (WWTP)
. A flow diagram of each WWTP showing each wastewater handling/treatment unit would be useful
.

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### 6 D 2 . 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 select ed 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 m enus for common entries. Use these pull

- down menus whenever possible, or w rite 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  B leaching 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 exi sts for yo ur mill) , the n 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 ex ist 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 p arts 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 n eed process data ? Facility and equipment details are being request ed to inform the technolog y revie w of the pulp and paper NE SHAP 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 technolog yl review of the NESHAP and NSPS considers emission unit and control e quipment details specific to the processes employed and matches these details to emissions levels that are achieved (e.g., emission concentrations). A pplicability of the NESHAP and NSPS compliance options depend s on the specific process equipment. How d etailed 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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### 7 Follow the instructions below

and in the “Instru ction” row s 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 Com plete 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 inform ation to answer a survey question ? There may be survey questions that you do not know the answer to, or for w

hich 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 im perative that you use the same I Ds 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 functiona l 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 yo ur 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 APC D_ID yo u create/specify in Part I should also be used w hen 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 th e 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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### 8 Size of entity
. Attachment 2 to this document contains a listing o f North American Industry Classification Sy stem (NAICS ) codes and small business size standards f or NAICS subsector 322
. For private businesses, small entity is defined for each NAICS code of the owning entity based on number of em ploy ees and/or company r evenue. 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., t em

porary) 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 tem porarily idle due t o 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 th e 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 c ould 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 s t/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 TO TAL 1,100 396,000 348,500 0.88 st = short tons (1 st = 2000 pounds) *T he 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 utilizatio n 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

- spec ific 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 Atta chment 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 com

bustion sources which are covered in Part III )
. Ho we ver, 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 A O of the PI Equip detail tab ask generic questions for all emission units listed in Attachment 1
. The c olumns to the right of column A O request design and operating details for specific types of emissio n units

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### 9 (e.g., diges ters, 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 inform ation requested

A
- A O Equipment, controls, and Federal rule applicability for each emission unit and collection system. AP
- A R Digesters A S
- AW Pulp washers AX
- AY Knotters, screens, and deckers AZ
- B B Evaporators B C
- B E Oxygen delignification B F
- B O Strippers B P
- B S Pulp storage and liquor stora ge BT
- BW Liquor storage ponds BX
- C A 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 shutdow n . Data are requested for each emission unit (and need not be broken out by individual emission points for a given emission unit unless different col lection 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
. L ist 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 s ystem ID for the different Emission Unit ID s. 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 ID s 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 s

ystem 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 “E mi ssion Unit D escription” 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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### 10 (year installed, hours per year [ hr/yr ] , com bustion controls, fuel data, equipment design and other operating parameters) in only 1 row , leaving all other row s 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 produce s 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 i nstructions immediately above for the PI Equip detail tab ). By pass 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 pol lution control devices (APCD s )
. 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 Emissi on 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, I f you use an electro static 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. I f 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. Emiss ion units routed to a boiler, lime kiln , or recovery furnace for emissions control . Enter the Emission Unit ID s 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 I II whe n equipment

- specific d etails 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 dev ice 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 b ackup controls in the “ Back

- up method of control ” column of the PI Equ ip detail tab. Do not include backup controls in the columns for APCD1 through APCD4. Com plete the applicable equipment

- specific details requested in columns AP through D T for each type of emission unit in the PI Equip detail tab by following the directi ons in the “ Instruction ” row

of the tab. Additional specific instructions are provided below for e quipment requiring instructions beyond what could be explained in the “ Instruction ” row . Leave columns that do not apply for a given emission unit blank. A ll emission units listed in Attachment 1 . Complete columns A through A O . 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 questi ons in columns AP through D T may also apply for selected emission unit types.

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### 11 Pulp processing equipment . Information pertaining to pulp processing equipment such as d igesters , p ulp washers , knotters, screens, deckers , e vaporators , and o xygen delignificati on 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
.

Stripp ers . 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 l iquor 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 requ esting limited information on boilers (and other fuel

- fired equipment such as thermal oxidizers and dryers) in the PI Equip detail tab . M any pulp and paper mills use boilers for primary or backup control of organics from pulping process , and some mills us e thermal oxidizers for this purpose . B oilers (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 A O of the PI Equip detail tab for any wastewater handling/treatment units that are closed and/or vent through a conveyance. Other equipment . Com

plete the generic questions in Columns A through A O of the PI Equip detail tab for any pulp and paper production equip me nt not elsewhere specified in the tab
. Primary and s upplemental fuels
. Fuel types are requested fo r fuel

- fired equipment because fuel type can have an effect on emissions . The EPA may consider fuel types and perform calculations based on fuel firi ng r ates for various nationwide impact analy ses. 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 fu el. Primary and supplemental fuel information is requested for fuel

- fi red equipment su ch 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 o r supplement al fuel s for purposes of this survey. Information for s econdary 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 proce ss parameters such as exhaust flow rate (acfm), temperature, etc. Unless otherwise speci fied, ty pical 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.

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### 12 Emission unit s tartup and shutdow n . Com plete 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 c ould apply during startup and shutdow n events (or whether th e 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 shutdow n are not already addressed with the current emission standards. You are asked to s upply information for routine startup and shutdown events associated with planned process or mi ll downtime. (Do not provide information for unplanned startup/shutdown events associated with equipment malfunctions
. ) The st artup 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 P art I Attachment 1 at this time. However, you m ay 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 w ith the suggested units shown in Table 2 below . These suggested units were taken from existing Federal limits codified in 40 CFR P art 60 , subpart BB or 40 C FR Part 6 3 , subparts S or MM. Specify permit limits as written in the permit if the suggested unit s 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 opt ions. How ever, 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 ( O 2 ) for a combustion unit sulfur dioxide ( SO 2 ) limit spec ified in the permit in terms of ppmdv, lb/hr, lb/day, and tpy, gr/dscf at specified % O 2 , etc.). The survey spreadsheet allows for up to five different permit limit formats for the same pollutant. Permit limits of mo st interest to EPA are concentration l imits (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 B B 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 Fede ral 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 i nterest to EPA are those for fuel

- fired equipment such as recovery furnaces, semi chemical 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). E PA 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 (% O 2 ). Be sure to note if ppm values are on a dry (d) or volume (v) or w eight (w) basis if specified this way in your perm it (ppmdv, ppmdw, ppmv, ppmw).

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### 13 While we would prefer to receive data in the PI Permit limits tab, w e 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 , wo uld be acceptable as well. Table 2. Suggested Units o f Measure for Permit Limits

Pollutant Suggested units PM 1 Recovery furnaces/chemical recovery combustion units: gr/dscf @ 8% O 2 SDT: lb/ton BLS LK: gr/dscf @10% O 2 PM 10 1 Other processes: lb/ton of throughput, lb/MMBtu, gr/dscf, g/dscm, or specify PM 2. 5 1 Opacity % (provide averaging time) TRS RF/combustion units: ppmdv @ 8% O 2 SDT: lb/ton BLS (as H 2 S) LK: ppmdv @ 10% O 2 Other processes: lb/ADT pulp and/or ppmdv SO 2 lb/MMBtu and/or ppmdv or limits on fuel S content NO X lb/MMBtu (as NO 2 ) 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% O 2 , 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 conden sable if your permit limits distinguish between the filterable and condensable PM fractions. d. PI Controls tab Com plete the Controls tab by following the instructions in the “ Instruction ” row for add

- on APCD s 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 b e 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 w aste generated and methods for handling). Baghouses, cyclones, and other material handling equipment. The EPA is most interes ted 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 detail s 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 sinc e 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, SO 2 , and other HAP. This information will be us ed in d etermining 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

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### 14 across the control device, th en 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 w aste water 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 Control s and PI Equip detail tabs. The PI Eq uip detail tab contains questions about heat input capacity, e quipm ent incinerating NCG or SOG , and primary

or supplemental fuels
. Control device s tartup and shutdow n . 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, i nformation 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, y ou are asked to s upply 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 equip ment ma lfunctions
. ) 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 T he 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 onl y o ne row (e.g. a mill that co - produces kraft and mechanical pulps should use two rows). Som e 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 util ization refer to unbleached pulps (i.e., pulp exiting the pulping line prior to any brig htening or bleaching). [Note: Capacity of bleached pulp (e.g., pulp exiting the bleaching/brightening l ine ) is requested in the Bleaching tab.] An exa mp le 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/y

r when pulp was produced 2009 capacity,

ADTP/yr (= A x B) 2009 actual

production, ADTP/yr* (= A x C) Pulp capacity

utilization d ecimal 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
. *T he 2009 ac tual 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.

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### 15 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 th ese 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 Com plete 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 com plete 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. Com plete the Byproducts tab by following the instructions in the “ Instruction ” row . g . Kraft condensates tab Com plete the Kraft co ndensates 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 th e Kraft condensates tab (e.g., digester systems, turpentine recovery systems, evaporator systems, HVLC and LVHC collection systems). Com plete the questions in table headings I through VII as applicable (depending on the condensate treatment method your mi ll 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 strip pers, biological treatment , or other means
. Control option Ap plicability Rule refere n ce 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 treatm ent 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 meth ods).

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### 16 h . CCA tab The CCA tab is divided into two portions: (1) Emission B alance to the left of the orange vertical lin e (column I) , and (2) CCA Equipment List on the right of the orange vertical line. You will enter one row of data for the Emissio ns 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 complia nce 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 com pliance. 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, inc luding: pulp washing systems, knotter systems, screen systems, decker systems, O 2 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 i s 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 mill

specific 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. Com plete 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) syste ms used at your mill. Note that, for brevity, the terms “bleaching” and “bri ghtening” 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 wi ll consist of one row for each ble aching/brightening line located at your mill. Most mills will have only one or two ble aching line rows
. For example, a mill that produces bleached chemical pulp, bleached secondary fiber pulp, and bright ened m echanical 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 c hlorine or chlorinated compounds , then you must co mp lete the portion of this tab to the right of the orange vertical line. E xtraction or other bleaching stages that do not use c hlorine or chlorinated compounds are not covered by subpart S and shou ld be reported in the Bleaching tab wi th “N R (no chlorine o r chlorinated compounds used in this stage) ” indicated. When specifying controls used for the various bleaching stages, enter not applicable “N A ” for stages without control. Enter the APCD_ID used in the PI Equip detail and PI Controls tabs when referr ing 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 indicat ed 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
. )
.

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### 17 Com plete 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 s om e 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 reque sts that you distinguish among a re latively 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 pac kaging & 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 po ssible 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 gr ade, stock consistency, and liquid HAP concentration may be useful for purposes of subcategorizing of paper machines. You are asked to s pecify the approximate makeup of each paper machine furnish

- specifically the approximate percentage of each pulp typ e . 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 pe rcent. k. HAP additives tab Com plete 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, a crylamide, 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 consi stent 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. A lthough it is unc lear whether paper machine additives contribute significantly to paper machine emissions (e.g., because additives may partition to the paper product or w hite 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
. Th e HAP additives information wo uld be used (e.g., along with emissions data for paper machines) to identify HAP

containing additives that may contribute significantly to paper machine HAP emissions or residual risk , and to evaluate work practices related to additives
. Com plete the HAP additives tab by following the instructions in the “ Instruction ” row .

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### 18 l . WW tab All m ills 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 revie wing 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 mo nitoring, measurement methods (such as ambient measurements) , or modeling methods that apply for measurement or esti mation of HAP and TRS (including H 2 S) 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 instru ctions) 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 e quipped with a closed

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

- vent collection system an d APCD , then you should also include the wastewater treatment unit in the Emission Unit ID column of th e 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 w astewater from several mills owned by the same company, then the questions sh ould 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 ye ar 2009. This information will inform EPA of the performance of biological treatment systems in destroying HAP. Com plete the WW tab by following the instructions in the “ Instruction ” row . 

### D 3 . Test data Attachment 3 of this Part I survey contains a t able of emission units and pollutants for which existing emission s 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 c onduct any new emissions testing or continuous emissions monitoring to respond to this survey
. Follow the instructions below for the “E missions 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 fiel d 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 requ ired 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
.

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### 19 Emissions test data are not requested for power boilers unless the pow er boil er is used to control NCGs or SOGs (in which case the test data requested are for the pulping systems controlled by the pow er boiler, assuming these emissions points have been tested). Revie w the test data request table in Attachment 3 of this survey. Lo cate 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 requ ired 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 yo u need no t supply emissions data for the prior configuration. How ever, you may voluntarily supply emission s data for prior configurations, as such information would be useful to EPA in characterizing emissions in general (for non

site

- specific uses) , but we request that you identify that such data are no longer representative in the PI Emissions test data tab. C utoff dates are provided in Attachment 3 for certain emission unit and pollutant com binations. More recent cutoff dates (e.g., 2001 or date of MACT complia nce) 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 d ata p rior 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 d ata 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, s ubmit 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 , m ethod 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. Com plete the PI Emission s test data tab to identify the speci fic emission units and control systems for which emission te st reports are being submitted, the pollutant tested, and the test method. The PI Emission s 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 emission s test data received through this survey. b. CEMS data spreadsheet ( P&P CEMS_PI.xls ) The EPA is requesting existin g CEMS data an d/or continuous opacity monitoring system (COMS) data for calendar year 2 009 (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 reques ted. 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 pow er boilers unless the boiler has a CEMS installed to show com plian ce 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 ) i s provided for submittal of the re quested CEMS data. The spreadsheet file contains individual worksheets (tabs) designed specifically for TRS (12

- hour block average), TRS (hourly), Opacity, NOx, SO 2 , CO, Methanol, Chlorine, and PM. Each wo rksheet 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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### 20 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 e ach 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 C ollection system ID) , the APCD_ID, and report the 12

- hour averages of CEM S 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 report ed concentrations of TRS should be corrected to 8% O 2 for recovery furnaces and 10% O 2 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 same tim e 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 re quested to specify the Emission Unit ID (or C ollection system ID) and the APCD_ID, and report the 6

- mi nute average opacity for CY 2009 operations
. An optional column is also included for hourly average opacity for mills that calculate an hourly average. In addition, respondents are asked to pr ovide the highe st single 6

- minute average opacity recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or shutdow n, and (c) under m alfunction conditions
. NOx, SO 2 , and CO . These worksheets are designed for recovery furnaces or lime kilns equipped with CEMS for NOx, SO 2 , or CO , but can be used for other emission units equipped with these CEMS . Respondents are requested to specify the Emission Unit ID (or C ollection 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 conditi ons, (b) under conditions of startup or shutdown, and (c) under malfunction conditions
. Total HAP or M ethanol . This worksheet is designed for total HAP or methanol CEMS installed to demonstrate compliance with the NESHAP subpart S limits for LVHC syste ms, 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 C ollection 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 shutdow n , and (c) under malfunction conditions
. Total C hlorinated HAP or C hlorine . 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 oth er emission units equipped with these CEMS or HCl CEMS ) . Respondents are requested to indicate the Emission Unit ID (or C ollection 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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### 21 PM . This worksheet is de signed for any emi ssions unit equipped with a PM CEMS. Respondents are requested to specify the Emission Un it ID (or C ollection system ID) and the APCD_ID , and report the 1

- hour averages of the CEMS data for CY 2009 operatio ns . 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 start

up 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 dat a The EP A 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 im plemented process changes of interest to request cost information unde r 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 sens itive. 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 in structions in section C 2 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 est imate the nationwide costs of any regulatory options based on the control measure indicated. Cost information from within the last 10

- 12 y ears is requested (e .g., costs dating back to 1998). The c ost information could come from vendor quotes for APCD or equipment changes that either have been implemented or w ere explored but not implemented. For Part I, the EPA is particularly interested in costs of the following APCD s . Please supply this informati on 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 formthat 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 tem plate provided. How ever, 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, th e 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 fo r 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 retent ion 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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### 22 - 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 Com plete 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 forma t (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 o f 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 n ot be required for other mills)
.

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### 23 PART I - ATTACHMENT 1 Emission Units to Inclu d e 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.] C austicizing E quipment Green liquor clarifier Green liquor storage tank Green liquor surge tank Slaker Causticizers White liquor clarifier White liquor storage tank White liquor pressure fil ter 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 Condense r Turpentine decanter Pulp Washing, Thickening, and Storage Equipment Brown stock washers Hoods Filtrate tanks Vacuum pumps Screens Kno tters Decker S tock chests (including open stock chests ) Pulp storage tanks T hickeners Pulp dryers Evaporators Black li quor storage tanks Evaporator h ot w ells Condensers Boilout tanks Soap storage tanks Soap skimmer tanks Other emission points associated with evaporators. Oxygen Delignification Equipment Oxyg en delignification reactor Ox ygen delignification blow tank Ox ygen de lignification washer Po st - oxygen washer filtrate tank Pulp storage tanks Other oxygen delignification system emission points. Non
- c ondensable G as (NCG ) Collection LVHC system HVLC system S tripper S ystem Equipment Stripper feed tanks Condensers H eat exchangers M ethanol Rectification Equipment Rectifiers Condensers Decanters Storage tanks Storage T anks Weak liquor storage tank s Strong liquor storage tank s Liquor storage ponds Acid condensate storage tank s (at sulfite mills) T all Oil Production Equipment Tall oil acidulation reactor Storage tank Dehydrator Brine storage tank Screen Centrifuge tank Other tall oil production vents Bleaching Equipment T ow er vent s W asher hood s S eal tank vent s C hemical and steam mixers Vacuum p um

ps

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### 24 M echanical 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 b lending and storage tanks Broke tanks Savealls White water storage tanks Wastewater T reatment S ystem Units Clarifiers Settling ponds Aerated stabilization basins UNOX systems Wastewater tanks Other waste water handling and treatment units Po we r B oilers

– PI Equip detail tab only Thermal O xidizers/ I ncinerators Woody ard O perations

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### 25 PART I - ATTACHMENT 2 Sm all Business Size Standards

Sm all Business Size Standards for NAICS Subsector 322

– Paper Manufacturing NAICS Codes NAICS U.S. industry title Size standards in number of em ployees 322110 Pulp Mills 750 322121 Paper (except New sprint) 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 3 22226 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 M anufacturing 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. A ccessed June 16, 2009 at: http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf

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### 26 PART I - ATTACHMENT 3 Part I E missions Test Data Request (Note: Test Reports submitted should be full and complete copies of the emission test r eports, to include field and lab data sheets and example calculations
. )

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### 27 Part I - Attachment 3 . Pulp and P aper E mission U nits and P ollutants for Which E xisting R epresentative E mission T est D ata A re R equested

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

metals 2 PM 2.5

(fil.) PM 2.5

(cond.) Chlorinated

HAP (Cl) 1 Acetaldehyde,

Formaldehyde, and Methanol 1 Total

hydrocarbon (THC) as carbon Total reduced

sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 1 Carbon

monoxide (CO) 1 Test methods 4 M5, M29, M17 PM CEMS, COMS M29 EPA OTM 27 EPA

OTM 28 Chlorine (Cl 2 ) via

M26A with modifications described in subpart S Cl 2 CEMS Me thanol: 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, O 2 delignification, Knotters and screens, Deckers (high density storage), and Weak and strong liquor storage tanks (or the ir 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 fol lowing MACT compliance Supply most recent data Not requested

Wastewater t reatment s ystems 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 t ab) Not

requested

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### 28 Emission Unit Particulate

matter (PM) 1 Speciated HAP

metals 2 PM 2.5

(fil.) PM 2.5

(cond.) Chlorinated

HAP (Cl) 1 Acetaldehyde,

Formaldehyde, and Methanol 1 Total

hydrocarbon (THC) as carbon Total reduced

sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 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, m echanical , 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, mang anese, mercury, nickel, and selenium. Include chromium VI (Cr+6 ) and speciated mercury (Hg) test data if available. 3 Speciated TRS would include: hydrogen sulfide (H 2 S), 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 a ppears in Part 63, Appendix A. The “ OTM ” test methods can be found at http://www.epa.gov/ttn/emc/prelim.html