## EPA-453/R-93-050b



## Pulp, Paper, and Paperboard Industry - Background Information for Promulgated Air Emission Standards Manufacturing Processes at Kraft, Sulfite, Soda, Semi-Chemical, Mechanical, and Secondary and Non-wood Fiber Mills

Emission Standards Division

U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Air and Radiation Ofiice of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 October 1997This report has been reviewed by the Emission Standards Division of the Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, and approved for publication. Mention of trade names or commercial products is not intended to constitute endorsement or recommendation for use. Copies of this report are available through the Library Services Offices (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, N.C. 27711 , (919)541-2777, from National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161, (703)487-4650, or from the internet (http://www.epa.gov/ttn/).

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X1.0 SUMMARY

1.1 INTRODUCTION On December 17 , 1993 (58 FR 66078), the U.S. Environmental Protection Agency (EPA) jointly published proposed National Emission Standard for Hazardous Air Pollutants (NESHAP) and Effluent Guidelines (December 17 , 1993 proposed rule) for the pulp and paper industry. The rule proposed standards for MACT I

sources , which include kraft, soda, sulfite, and semi-chemical pulping mills. On March 17, 1994 (59 FR 12567) EPA published a correction notice to the proposed NESHAP and Effluent Guidelines

(March 17, 1994 correction notice). On February 22, 1995 (60 FR 9813) EPA published a Notice of Data Availability (NODA) that would be considered for developing the promulgated NESHAP. On March 8, 1996 (61 FR 9383), EPA published a supplemental notice (March 8 , 1996 supplemental notice) that presented EPA's assessment of the additional data and information obtained after proposal and announced potential changes to the proposed rule. As part of the March 8 , 1996 supplemental notice, EPA also proposed standards for MACT III sources (papermaking systems, mechanical pulping mills , secondary fiber pulping [deinked and non-deinked] mills, and non-wood mills , and asked for additional information on these mills). MACT II sources (combustion sources) are covered under a separate rulemaking.

l-lIn the March 8 , 1996 supplemental notice, EPA solicited additional data and comments on proposed changes to the December 17 , 1993 proposed rule. Data added to Air Docket A-92-40 since the March 8 , 1996 supplemental notice are located in section IV of the docket. These items include additional information on sulfite mills (IV-Dl-98, IV-Dl-100) comments on definitions (IV-Dl-97, IV-Dl-99, IV-Dl-104), comments on the emission factor document (IV-Dl-102), clarification of the 1992 MACT survey responses (IV-Dl-lOl), and other information. The public comment period for the December 17, 1993 proposed rule was from December 17, 1993 to March 17, 1994. Approximately 155 comment letters were received on the December 17, 1993 proposed rule. The public comment period for the supplemental notice was from March 8, 1996 to April 8, 1996. Approximately 33 comment letters were received on the March 8, 1996 supplemental notice , including letters received on the MACT III

sources. Comments were provided by industry representatives, governmental entities, environmental groups, and private citizens. 1.2 ORGANIZATION OF THIS DOCUMENT This introduction includes the list of commenters on the December 17, 1993 proposed rule and notices. In order to present the comments in a logical manner, the comments and EPA's responses have been divided into 18 categories. The categories and respective chapter numbers in this background information document are as follows: 2.0 INDUSTRY CHARACTERIZATION 3.0 SUBCATEGORIZATION 4.0 BASIS OF STANDARDS 5.0 PULPING AREA 6.0 BLEACHING AREA

l-27.0 PROCESS WASTEWATER AREA 8.0 MONITORING 9.0 TEST METHODS AND PROCEDURES 10. 0 RECORDKEEPING AND REPORTING 11. 0 COST/ECONOMIC IMPACTS 12. 0 BENEFITS 13. 0 EMISSIONS AVERAGING 14. 0 DEFINITIONS 15. 0 CLUSTER RULE INTERACTION 16. 0 INTERACTION WITH OTHER RULES 17. 0 SCHEDULE ISSUES 18. 0 MACT III 19. 0 MISCELLANEOUS COMMENTS 20. 0 ENVIRONMENTAL IMPACT STATEMENT The environmental impact statement is chapter 20 of this document. The following section, section 1.3, includes tables listing the commenters , their affiliation , and assigned comment number. Numerous acronyms appear throughout this document. The following is provided for reference. Acronyms Used in this Document

Act Clean Air Act

ADP Air-dried pulp

ADTP Air-dried ton of pulp

AF&PA American Forest and Paper Association (formerly the American Paper Institute)

AP-42 Compilation of Air Pollutant Emission Factors, 5th edition, Volume 1: Stationary Point and Area Sources

API

AQRV American Paper Institute
Air quality related value

l-3BAT

BACT

BID

BIF

BLO

BMP

BOD

BOD 5

BPT

Btu

CEMS

CCA

CFR

ClO 2

CO

CO 2

CTG

CWA

EA Best available technology (under the Effluent Limitation Guidelines and Standards of the Clean Water Act)
Best available control technology
Background information document

Boilers and industrial furnaces
Black liquor oxidation
Best management practices
Biochemical oxygen demand

Biochemical oxygen demand 5-day test
Best practicable control technology

Britis h therma l unit
Continuous Emissions Monitoring Systems

Clean condensate alternative
Code of Federal Regulations

Chlorine dioxide

Carbon monoxide

Carbon dioxide
Control Technology Guidance

Clean Water Act
Economic Analysis for the National Emission Standards for Hazardous Air Pollutants for Source Category: Pulp and Paper Production; Effluent Limitations and Guidelines, Pretreatment Standards and New Source Performance Standards; Pulp, Paper, and Paperboard Category

- Phase I

l-4EPA

FOIA

FLM

FR

GC/FID

GRM

HAP

HCl

HON

HVLC

IRIS

lb/ODTP

kg

LAER

LVHC

MACT

Mg

NAA

NAAQS

NCG

NCASI U.S. Environmental Protection Agency

Freedom of Information Act
Federal land manager
Federal Register
Gas chromatography/flame ionization detection
Gallons per minute
Hazardous air pollutant
Hydrogen chloride
Hazardous organic NESHAP
High volume, low concentration collection system
Integrated Risk Information System
Pound per oven-dried ton of pulp
Kilograms

Lowest achievable emission rate

Low volume , high concentration collection system.
Maximum achievable control technology.

Megagram

Non-attainment Area
National Ambient Air Quality Standards
Noncondensible gas
National Council of the Paper Industry for Air and Stream Improvement

l-5NESHAP

NIOSH

NOCEPM

NODA

NO x
NPDES

NSPS

NSR

OAQPS

OCCM

ODP

ODTP

OMB

ORD

OSHA

OTR

OW

PCP

PM

PM 10

ppmv National Emission Standard for Hazardous Air Pollutants
National Institute Occupational Safety and Health
NCASI Organic Compound Elimination Pathway Model
Notice of Data Availability
Nitrogen oxides
National Pollutant Discharge Elimination System

New Source Performance Standards

New Source Review
Office of Air Quality , Planning and Standards
OAQPS Control Cost Manual
Oven-dried pulp
Oven-dried ton of pulp
Office of Management and Budget
Office of Research and Development
Occupational Safety and Health Administration
Ozone Transport Region

Office of Water
Pollution control project

Particulate matter

Particulate matter less than 10 microns mean aerodynamic diameter
parts per million by volume

l-6ppmw

PSD parts per million by weight
Prevention of Significant Deterioration

PSES Pretreatment Standards for Existing Sources

PSNS Pretreatment Standards for New Sources

RACT

RCRA

RIA Reasonable Attainable Control Technology
Resource Conservation and Recovery Act
Regulatory Impacts Analysis

SCR Selective catalytic reduction

SIC Standard Industrial Classification

SIP State Implementation Plan

SNCR Selective non-catalytic reduction

SO 2 Sulfur dioxide

SOCMI

TCF Synthetic Organic Chemical Manufacturing Industry
Totally chlorine free

SCF Secondarily chlorine free

TRE Total resource effectiveness

TRS Total reduced sulfur

VOC Volatile organic compounds
1.3 SUMMAR Y OF PUBLIC COMMENTS Approximately 188 written comments were received on the proposed standards and subsequent notices. A list of the commenters on the December 17, 1993 proposed rule, their affiliations , and the EPA docket number assigned to their correspondence is given in table l-l. Table l-2 lists all

l-7persons submitting general written comments on the March 8, 1996

supplemental notice, their affiliations, and the docket item number assigned to each correspondence. Table l-3 lists separately all persons submitting written comments on the MACT III sources (papermaking systems, mechanical pulping mills, secondary fiber pulping mills, and non-wood mills), their affiliation, and the docket item number assigned to each correspondence.
1.4 SUMMARY OF CHANGES SINCE PROPOSAL In response to comments received on the proposed standards, several changes were made to the final rule. While some of these changes are clarifications designed to make the Agency's intent clearer, a number of them are significant changes to the proposed standard requirements. A summary of the substantive comments and changes made since the proposal are described in this section. Detailed Agency responses to public comments are presented in chapters 2.0 through 19.0 of this document. The revised analyses for the final rule are in the public docket.
1.4.1 Definition of Source The December 17, 1993 proposed rule presented a broad source definition which included pulping processes, bleaching processes, and pulping and bleaching process condensates. The Agency specifically requested comment on the source definition (i.e., broad versus narrow) in the proposal. After considering comments, EPA adopted the broad definition in the final rule. The EPA determined that the affected source is all emission points in the pulping and the bleaching systems (including oxygen delignification and the pulping condensate system). The final rule explicitly defines the new source MACT applicability by

l-8TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17, 1993 PROPOSED RULE

Office of Water docket control number Commenter and affiliation 20,000

20,001 Tom Burgess Chemetics International, Inc. Vancouver, British Columbia, Canada Wayne E. Glenn United Paperworkers International Union Nashville, Tennessee Gordon D

. Strickland Chemical Manufacturers Association Washington, DC Richard M. Harvey Florida Department of Environmental Protection Tallahassee, Florida David W

. Schmutzler Niagara of Wisconsin Paper Corporation Niagara, Wisconsin David A.C. Carroll Maryland Department of the Environment Baltimore, Maryland Citizen Nat Hendricks Putney, Virginia Carl W. Ehmann RJ Reynolds Tobacco Company Winston Salem, North Carolina 20,002 Attachment 20,002Al 20,003

20,004

20,005

20,006

20,007

20,008

20,009 Robert C. Steidel Environmental Manager City o f Hopewell Hopewell, Virginia Dianne M. Reid State of North Carolina Department of Environment, Health, and Natural Resources Raleigh , North Carolina

l-9TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,010 John W. Walton State of Tennessee Department of Environment and Conservation Nashville, Tennessee 20,011

20,012 Attachment 20,012Al 20,013 Gregory J. Hollod Riverwood International Atlanta, Georgia David J. Lutrick Simpson Paper Company Anderson, California Paul A. Walker Hollingswort h & Vose Company East Walpole , Massachusetts 20,014 Attachment 20,014Al 20,015

20,016 Attachments 20,016Al

- 20,016A6 A.D

. Whitford Longview Fibre Company Longview , Washington Thomas R. Hewitt CRS Sirrene Environmental Raleigh , North Carolina Kathy E. Gill Northwest Pulp & Paper Bellevue, Washington

20,017

20,018 Attachments 20,018Al

- 20,018A2 Seattle Audubon Society Seattle , Washington Kimberly A. Hughes Weyerhaeuser Tacoma , Washington

20,019 J.R. Nein Chesapeake Paper Products Company West Point, Virginia

l-10TABL E l-1. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,020 Robert G. Smerko Attachment The Chlorine Institute 20,020Al Washington, DC 20,021

20,022 Kenneth L. Wendell Westvaco Luke , Maryland Marianne Dugan Western Environmental Law Center, Inc. Eugene, Oregon 20,023

20,024

20,025 Attachments 20,025Al

- 20,025Al0 20,026 Attachments 20,026Al

- 20,026A51 20,027 Attachments 20,027Al

- 20,027A32 20,028

20,029 Herbert C. Scribner Van Leer Packaging Keyes Fibre Company Waterville, Maine Josephine S. Cooper American Forest and Paper Association Washington, DC Josephine S. Cooper American Forest and Paper Association Washington, DC

American Forest and Paper Association Washington, DC

American Forest and Paper Association Washington, DC

Guy R

. Griffin Potlatch Corporation San Francisco, California Michael J. Wax Institute of Clean Air Companies Washington, DC

l-11TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,030 William Robert Neff The Upper Potomac River Commission Westernport, Maryland 20,031

20,032 C.L. Missimer P.H. Glatfelter Company Spring Grove, Pennsylvania Douglas C. Pryke Alliance for Environmental Technology Ontario, Canada 20,033

20,034 Attachments 20,034Al

- 20,034A6 20,035 George A. Schmitt 3M Industrial & Consumer Sector St. Paul , Minnesota Robert B. Burns Jr. Albert H

. Toma III Fort Howard Corporation Green Bay, Wisconsin C.F. Bledsoe Alabama Pulp and Paper Council Montgomery, Alabama 20,036 Attachment 20,036Al 20,037 Nicholas J. Lardieri Scott Paper Company Philadelphia, Pennsylvania Leslie Ritts Counsel for American Forest and Paper Association Chadbourn e & Parke Washington, DC 20,038

20,039 Wilson Blackburn Lake Superior Paper Industries Duluth, Minnesota J. Carter Fox President and CEO Chesapeake Richmond, Virginia

l-12TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,040

20,041 Douglas A. Hall Minnesota Pollution Control Agency St. Paul, Minnesota Raymond J. Connor Technical Director Manufacturers of Emission Controls Association Washington, DC 20,042

20,043 L.J

. Achee, Jr. Jackson City Port Authority Pascagoula, Mississippi Robert J. Sistko, PhD, Sr. Environmental Specialist Rayonier Shelton , Washington 20,044 Attachment 20,044Al 20,045 Kurt N.W

. Soderberg Western Lake Superior Sanitary District Duluth, Minnesota M.T. Fisher Procto r & Gamble Cincinnati, Ohio 20,046 Attachments 20,046Al

- 20,046A2 R.E. Cannon Buckeye Florida Perry, Florida

20,047 R.E. Cannon Attachment Buckeye Cellulose Corporation 20,047Al Memphis, Tennessee 20,048 Kenneth T. Hood Attachment Simpson Paper Company 20,048Al Anderson, California

1-13TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,049 Attachments 20,049Al

- 20,049A2 Jessica C

. Landman Natural Resources Defense Council Washington DC

20,050

20,051

20,052 Luigi Terziotti Attachment Alabama River Pulp Company 20,052Al Perdue Hill, Alabama 20,053 Attachment 20,053Al 20,054 Attachments 20,054Al

- 20,054A5 20,055

20,056 Attachments 20,056Al

- 20,056A3 20,057 Attachments 20,057Al

- 20,057A22 20,058 Lindsay M. Lancaster International Paper Company Mobile , Alabama Luigi Terziotti Alabama River Pulp Company Perdue Hill, Alabama

James Miller Louisiana-Pacific Corporation Samoa, California Richard Diforio Champion International Stamford, Connecticut

Erick Tokar Rayonier Shelton , Washington Duane Marshall Union Camp Savannah, Georgia

Thomas Jorling International Paper Company Purchase, New York

Catherine Marshall American Forest and Paper Association Washington, DC

l-14TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,059

20,060

20,061

20,062

20,063

20,064 Attachments 20,064Al

- 20,064A3 20,065

20,066 Attachments 20,066Al

- 20,066A4 20,067

20,068 Attachments 20,068Al

- 20,068A7 Deborah A. Sheiman Natural Resources Defense Council Washington, DC Jerry Pardilla Penobscot Indian Nation Old Town, Maine David Lutrick Simpson Paper Company Seattle , Washington Robert Collez Augusta Newsprint Augusta, Georgia Peter Washburn Natural Resources Council of Maine Augusta, Maine Greenpeace Washington, DC

Joe Thornton Greenpeace Washington, DC Charles Ackel Stone Container Corporation Tucker, Georgia

Roger Stone Stone Container Corporation Chicago, Illinois
Dan a Dolloff Rayonier Stamford, Connecticut

l-15TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,069 Attachments 20,069Al

- 20,069Al0 20,070 Attachments 20,070Al

- 20,070A15 20,071 Attachments 20,071Al

- 20,071A13 20,072 Attachments 20,072Al

- 20,072All 20,073

20,074

20,075 amends 20,057 20,076 amends 20,045 20,077 Attachments 20,077Al

- 20,077A7 Douglas Walsh Lincoln Pulp & Paper Company Lincoln, Maine

Kathleen Bennett James River Corporation Richmond, Virginia

Dale Phenicie Georgia-Pacific Atlanta, Georgia

Jerome Tatar Mead Chillicorne, Ohio

Russell Frye Chadbourn e & Parke Washington, DC
Steve Mason Mead Dayton, Ohio Alan Lindsay International Paper Memphis, Tennessee Henry Clifford Procto r & Gamble Cincinnati, Ohio Corrine Goldstein Covingto n & Burling Washington, DC

l-16TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,078

20,079 Attachments 20,079Al

- 20,079A4 20,080

20,081 Attachments 20,081Al

- 20,081A2 20,082

20,083

20,084

20,085

20,086

20,087 Greg Sorlie Washington Department of Ecology Olympia , Washington Charles Bridges Van Leer Packaging Waterville, Maine

Mary O'Brien Environmental Research Foundation Annapolis, Maryland Rick Montanari Ecotech St. Petersburg, Florida

Martin Visnosky Erie County Environmental Coalition Erie, Pennsylvania Steve Kilpatrick Dow Midland , Michigan Gordon Strickland Chemical Manufacturers Association Washington, DC Norman Anderson American Lung Association of Maine Augusta, Maine Darrell Jeffries Wausau Papers Brokaw , Wisconsin Brian Benson Roy F

. Weston, Inc. Auburn , Alabama

l-17TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,088 Attachment 20,088Al 20,089

20,090

20,091 Attachments 20,091Al

- 20,091A5 20,092

20,093

20,094

20,095 Attachments 20,095Al

- 20,095A9

20,096 Attachments 20,096Al 20,097 Kenneth Gilbreath Chesapeake Paper Products West Point, Virginia David Buente Sidle y & Austin Washington, DC Ted Strong Columbia River Inter-Tribal Fish Commission Portland, Oregon Donna Hayes Dickinson Citizens for Clean Air Norway, Michigan

Davi d Driesen Natural Resources Defense Council Washington, DC Bharat Shah Wisconsin Tissue Menasha , Wisconsin Art Vosburg Pop e & Talbot Halsey, Oregon Reid A. Miner National Council of Paper Industry for Air and Stream Improvement New York, New York

Dick Brown Gulf Coast Waste Disposal Authority Houston, Texas
Jo e Mayhew Chemical Manufacturers Association

l-18TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,098 Also A-92-40 IV-Dl-18

20,099 Attachments 20,099Al

- 20,099A2 20,100

20,101

20,102

20,103

20,104

20,105

20,106

20,107 John Pinkerton National Council of Paper Industry for Air and Stream Improvement New York, New York G.W. Zielinski City of St. Helens, Oregon attachments not sent to OAQPS

Stewart Thomas Newsprint South Inc. Grenada , Mississippi Stacy Palamatary Oxychem Dallas, Texas Robert Colby STAPPA/ALAPCO Washington, DC Susan Sylvester Wisconsin Department of Natural Resources Madison , Wisconsin William Nicholson No company affiliation disclosed Ross, California Nicholas J. Lardieri Scott Paper Company Philadelphia, Pennsylvania Corinne Goldstein Covingto n & Burling on behalf of Finch Pruyn & Company Glensfalls, New York Reid A. Miner National Council of Paper Industry for Air and Stream Improvement New York, New York

l-19TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,108

20,109

20,110

20,111 Attachment 20,lllAl 20,112 Attachments 20,112Al

- 20,112All 20,113 Attachment 20,113Al 20,114 Attachment 20,114Al 20,115 Attachments 20,115Al

- 20,115A5 20,116 Attachments 20,116Al

- 20,116A2 20,117 Attachment 20,117Al Guy Griffin Potlatch Corporation San Francisco, California Paul Wiegard National Council of Paper Industry for Air and Stream Improvement New York, New York Peter Baljet American Lung Association Washington, DC Dennis Keschl Maine Department of Environmental Protection Augusta, Maine John Festa American Forest and Paper Association Washington, DC

Terry Cole St. Joe Forest Products Comapny City of Port St. Joe, Florida Kenneth A. Strassner Kimberly-Clark Washington, DC
James Beason Appleton Papers Inc. Appleton, Wisconsin

John Festa American Forest and Paper Association Washington, DC

John Millican Florida Pulp & Paper Association Tallahassee, Florida

l-20TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RUL E (Continued)

Office of Water docket control number Commenter and affiliation 20,118

20,119

20,120 Attachments 20,120Al - 20,120A88 20,121

20,122 Attachments 20,122Al

- 20,122A7 20,123 Attachments 20,123Al

- 20,123A7 20,124

20,125

20,126

20,127 Attachment 20,127Al Anthony Gammie Bowater, Inc. Greenville, South Carolina Robert C. Kaufmann American Forest and Paper Association Washington, DC Josephine S. Cooper American Forest and Paper Association Washington, DC

Washington Toxics Coalition and 4 1 other Environmental Organizations in the Pacific Northwest Prepared by Carol Dansereau, J.D. Director of Washington Toxics Coalition Seattle , Washington

Dale Phenicie Georgia-Pacific Corporation Atlanta, Georgia

Frank Pate City of Port St. Joe, Florida Catherine Marshall American Forest and Paper Association Washington, DC Jessica C. Landman, Senior Attorney; Diane M. Cameron , Environmental Engineer; Brian L. Doster, Legal Associate Natural Resources Defense Council New York Joy Cummings HOPE in Taylor Company Perry, Florida

l-21TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RULE (Continued)

Office of Water docket control number Commenter and affiliation 20,128

20,129

20,130 Attachments 20,130Al

- 20,130A5 20,131

20,132

20,133

20,134

20,135 Attachment 20,135Al 20,136 Attachments 20,136Al

- 20,136A14 20,137 Frank Molen Commonwealth of Virginia Senate New Hope, Virginia Edward Sullivan New York State Department of Environment and Conservation Albany , New York David Lutrick Simpson Paper Company Anderson, California

Duane Marshall Union Camp Savannah, Georgia
Mr. and Mrs. James J. Sloan Salinas, California Phillir Chaudoir Green Bay, Wisconsin Alber t Toma Fort Howard Green Bay, Wisconsin Kathleen M. Bennett James River Co. Richmond, Virginia Mark Haley City of Hopewell, Virginia

Alan D

. Whitford Longview Fibre Company Longview , Washington

l-22TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RUL E (Continued)

Office of Water docket control number Commenter and affiliation 20,138 Chester Williams FUSE, Inc. Texarkana, Arkansas-Texas 20,139

20,140

20,141

20,142

20,143

20,144

20,145

20,146

20,147

20,148 James W. Riley Cumberland, Maryland Jim Anders Anders Real Estate & Timber Co., Inc. Blountstown, Florida Karey Shaw Columbia River United Hood River, Oregon Stuart I. Gansell Pennsylvania Department of Environmental Resources Joy Huber Rivers Council of Washington Seattle , Washington Robert H. Collom, Jr. Georgia Department of Natural Resources Atlanta, Georgia Randy Thurman Arkansas Environmental Federation Little Rock, Arkansas J.D. Weinbauer Consolidated Papers, Inc. Wisconsin Rapids, Wisconsin

Bruce W

. Beckstrom A.H. Lundberg Associates, Inc. Bellevue, Washington Richard A. Samp Washington Legal Foundation Washington, DC

l-23TABLE l-l. LIST OF COMMENTERS ON THE DECEMBER 17 , 1993 PROPOSED RUL E (Continued)

Office of Water docket control number Commenter and affiliation 20,149 Pau l Gerbec Minnesota Pollution Control Agency St. Paul , Minnesota 20,150

20,151

20,152

20,153

20,154

20,155 Bo b Jackman and Frank Ossiander Citizens for a Clean Columbia Kettle Falls, Washington Randal S. Telesz Michigan Department of Natural Resources Lansing , Michigan Stephen B. Letendre Tennessee Department of Environment and Conservation Nashville, Tennessee Samuel N. Penney Ne z Perce Tribal Executive Committee Lapwai, Idaho Paul C. Martyn Los Angeles County Sanitation Districts Whittier, California Yogesh M. Mehta Brow n & Root U.S.A., Inc. Houston, Texas 20,156 Edward Mudd, Jr. Birmingham, Alabama 25,538 Josephine S. Cooper American Forest & Paper Association Washington, DC

l-24TABLE l-2. LIST OF COMMENTERS ON MARCH 8, 1997 SUPPLEMENTAL NOTICE

Item number in Docket A-92-40 Commenter and affiliation
IV-D2-2 Keith M. Bentley Georgia Pacific Savannah, Georgia IV-D2-3

IV-D2-4

IV-D2-5

IV-D2-6

IV-D2-7

IV-D2-8

IV-D2-9

IV-D2-10 Dan Pearson Texas Natural Resource Defense Council Austin, Texas
IV-D2-11

IV-D2-12 Duane W

. Marshall Union Camp Atlanta, Georgia Donald F. Theiler STAPPA/ALAPCO Washington, DC William 0. Dameworth Pop e & Talbot Halsey, Oregon Robert J. Sistko Rayonier Shelton , Washington Gregory J. Hollod Riverwood International Atlanta, Georgia Kathleen M. Bennett James River Corporation Richmond, Virginia K.E. Lewis Procto r & Gamble Cincinnati, Ohio

Thomas C. Jorling International Paper Purchase, New York Phillip J. Arthur Finch Pruy n & Co., Inc. Glen Falls, New York

l-25TABLE l-2. LIST OF COMMENTERS ON MARCH 8, 1997 SUPPLEMENTAL NOTICE (Continued)

Item number in Docket A-92-40 Commenter and affiliation
IV-D2-13 Josephine Cooper American Forest and Paper Association Washington, DC
IV-D2-14

IV-D2-15

IV-D2-16

IV-D2-17

IV-D2-18

IV-D2-19 Sara S

. Kendall Weyerhaeuser Tacoma , Washington
Robert C. Kaufmann American Forest and Paper Association Washington, DC Richard C. Abrams Kimberly-Clark Everett , Washington

Dana B

. Dolloff Rayonier Stamford, Connecticut
R.E. Cannon Buckeye Florida Perry, Florida

Larr y Tenth Chemitics Vancouver, British Columbia, Canada
IV-D2-20 Duane W

. Marshall Union Camp Savannah, Georgia

l-26TABLE l-3. LIST OF COMMENTERS ON MACT III SOURCES a

Item number in Docket A-95-31 Commenter and affiliation IV-D-l

IV-D-2 K.E. Lewis The Proctor & Gamble Company Cincinnati, Ohio J. Grumet and W. Cass Northeast States for Coordinated Air Use Management Boston , Massachusetts R.H. Colby and D.F. Theiler State and Territorial Air Pollution

Programs Administrators/Association of Local Air Pollution Control Officials Washington, DC IV-D-3

IV-D-4

IV-D-5

IV-D-6

IV-D-7

IV-D-8

IV-D-9

IV-D-10 K.M

. Bennet James River Corporation Richmond, Virginia G.J. Hollod Riverwood International Atlanta, Georgia J. Brooks State of Maine Augusta, Maine J.S. Cooper American Forest & Paper Association Washington, DC R.C. Kaufmann American Forest & Paper Association Washington, DC
R.E. Cannon Buckeye Cellulose Corporation Memphis, Tennessee T. Mattson Environmental Technology

- Air Fort Howard Green Bay, Wisconsin

l-27TABLE l-3. LIST OF COMMENTERS ON MACT III SOURCES a (Continued)

Item number in Docket A-95-31 Commenter and affiliation IV-D-11

IV-D-12

IV-D-13 C. Ackel Stone Container Corp. Tucker , Georgia S.S. Kendall Weyerhauser Corp. Taucoma, Washington R.A. Ellis, J.H. Lewis, R.J. Hampson, L.J. Barry (et al.), P.J. Luciano, W.J. Schulz, L. Gill, and R.J. Ellithorpe. Letters to Elaine Manning (OAQPS/EPA)

a MACT III sources include papermaking systems, mechanical pulping

mills, secondary fiber pulping mills, and non-wood mills.

l-28specifying the control requirements for (1) greenfield sites,

(2) the addition of new equipment at existing sources, and (3) changes to existing equipment that could trigger reconstruction. By designating the exact equipment to be controlled at new and existing sources, the rule reduces confusion and misinterpretation over what actions trigger new source requirements. This approach preserves the advantages of a broad source definition for compliance by existing sources while ensuring that new and reconstructed equipment are regulated as new sources consistent with Section 112(a) and 112(d) of the Clean Air Act (Act).

The final rule also provides for an alternative definition of source for use with the clean condensate alternative (CCA). For mills using the CCA (see section 1.4.4.2) to comply with the standards, the broad definition includes all the pulping, bleaching, causticizing, and paper making systems. These additions were made to the definition of affected source to encourage pollution prevention since the paper making and causticizing systems typically receive recycled or reused condensates. 1.4.2 Subcategories In the proposed rule, no distinction was made between the different types of pulping processes. The standards for control of hazardous air pollutant (HAP) emissions from vents and wastewater sources (i.e., pulping process condensates) were the same for kraft, semi-chemical, soda, and sulfite pulping

processes. After evaluating public comments and data received following proposal, EPA established separate subcategories for

l-29kraft, semi-chemical, soda , and sulfite pulping processes due to differences in process emissions and applicable control techniques. As in the proposed rule, the final standards for kraft, semi-chemical , and soda pulping processes in the final rule are based on combustion. For sulfite pulping processes, the final rule is based on absorption technologies. 1.4.3 Contro l Applicabilitv Determination The proposed rule prescribed applicability cutoff values (i.e., volumetric flow rate and mass flow rate) as a way to specify the vent and condensate streams that would be required to meet the rule. Since proposal , the pulp and paper industry submitted additional data that allowed EPA to better characterize the vent and condensate streams that should be controlled. In the final rule , the applicability cutoff values contained in the December 17 , 1993 proposed rule have been replaced in favor of specifically naming the vent and condensate streams that would be required to meet the rule for each subcategory, with the exception of decker, knotter , and screen systems at kraft pulping mills. For these systems , the rule specifies applicability cutoffs in the form of emission limits (knotter and screen systems) and HAP concentration in process condensates (decker systems) to identify the systems that should be controlled at new and existing mills. The different approach used in the final rule does not significantly change the stringency or scope of the December 17 , 1993 proposed rule. The emission points and condensate streams that are being controlled in the final rule are fundamentally the same emission sources that EPA intended to be controlled in the December 17, 1993 proposed rule. The

l-30revised approach is easier and less costly to implement, for both the affected industry and the enforcement officials, since extensive emission source testing is not required to identify the vent and condensate streams to be controlled. 1.4.4 Kraft Standards 1.4.4. 1 Applicabilitv for Existinq Pulping Kraft Sources. In the December 17 , 1993 proposal all pulping vent emission points were , with some exceptions , required to be enclosed and vented to a closed-vent system and routed to a control device that achieves 98 percent destruction. The exceptions were for deckers and screens at existing mills and small vents below specified volumetric and mass flow rates. Pulping wastewater streams with HAP concentrations below 500 parts per million by weight (ppmw) and flow rates below 1.0 liter per minute did not require control. In the final rule , specific vent and condensate streams are required to be controlled. For existing sources, the vent emission sources include: the low volume, high concentration collection (LVHC) system, pulp washing system, decker system, oxygen delignification system, knotter system, and screening system. The EPA based its decisions to require these systems to be controlled on information presented in responses to industry surveys used to characterize controls that are installed at existing mills and in comments to the proposed rule. Based on analysis of additional information provided by industry, the final rule does not require the control of existing weak black liquor storage tanks or control of decker systems that use clean water or process water from papermaking systems ("white

l-31water"). These types of process water are defined as streams with HAP concentrations less than or equal to 400 ppmw. Also, in the final rule , existing sources are required to control knotters with mass emission rates greater than 0.1 pounds of HAP per oven dried ton of production (lb/ODTP)(0.05 kilograms per megagram) , screens with mass emission rates greater than 0. 2 lb/ODTP (0.10 kilograms per megagram), or combined knotter and screen systems with emissions greater than 0.3 lb/ODTP

(0.15 kilograms per megagram). New sources are required to control all decker, knotter , and screen systems and weak black liquor storage tanks. Condensate Segregation. The proposed standards for process wastewater required that all pulping wastewaters that met the applicability criteria had to be treated by one of several specified control options. Comments and data submitted to EPA indicated that kraft mills typically steam strip the condensates from the digester , turpentine recovery , LVHC, and high volume, low concentration collection (HVLC) system, and certain evaporator system condensates. The data also indicated that mills that use steam strippers also practice varying degrees of condensate segregation in order to reduce treatment costs by minimizing the flow rate and maximizing the methanol mass of

streams sent to treatment. To allow this cost saving option, the final rule requires that the entire volume of condensate generated from the named pulping process equipment must be treated unless the condensates from the digester system , turpentine recovery system, and the weak liquor feed stages in the evaporator system are segregated. If these condensates are adequately segregated, only the high-HAP

l-32fraction stream from these systems, along with the condensates

from the LVHC and HVLC collection systems, must be sent to

treatment. The final rule contains two options for demonstrating compliance with the segregation requirements. The first option is to isolate 65 percent of the total HAP mass that was present in the specified system condensate streams prior to segregation. The second option specifies that a minimum HAP mass from the digester, turpentine recovery, evaporator, LVHC collection, and HVLC collection systems be sent to treatment. 1.4.4.2 Clean Condensate Alternative. The December 17, 1993 proposed rule did not contain any provisions for emissions averaging. Industry comments on the proposal indicated support for incorporating an emission averaging approach in the final
rule. After the public comment period, industry submitted a report comparing the emission reductions that could be achieved using the option developed by industry and emission reductions that could be achieved using the proposed MACT standards. Specifically, the industry option is based on comparing the HAP emission reductions achieved by implementing the alternative technology with the baseline HAP emission reductions that would have been achieved by implementing the MACT standards. The industry option formed the basis for what is referred to as the CCA in the final rule.

The CCA is an option for compliance with kraft pulping standards for the HVLC system. As an alternative to combustion of HVLC vent emissions, a mill may reduce the HAP concentration in process water that is used in the HVLC process equipment and in other areas throughout the mill, such as the paper making and

l-33causticizing systems. By reducing the HAP loading in the process water, less HAP will be available to be emitted to the atmosphere. The final rule specifies that the determination of the baseline HAP emission reductions and the reductions achieved by the alternative strategy must be determined by emissions testing data. 1.4.4.3 Biological Treatment. At proposal, one of the compliance options for process wastewaters was to destroy at least 90 percent HAP by weight by hard piping the process wastewater streams to biological treatment. For the performance test, owners or operators were required to measure inlet and outlet methanol concentrations using Method 305, and determine the mass flow rate of total HAP or methanol entering the biological treatment system. The biological treatment system's destruction efficiency was determined by dividing the difference of the outlet and inlet mass flow rates by the inlet mass flow rate and multiplying by the fraction of methanol removed in the biological treatment system. The site-specific fraction of methanol removed in the biological treatment system was determined using EPA's WATER7 model. The continuous monitoring requirements specified that total HAP or methanol concentration be measured at the inlet and outlet of the biological treatment system every 30 days. Additionally, the standard required monitoring of appropriate operating parameters as specified in the operating permit and demonstrated to the Administrator's satisfaction. In the final rule , biological treatment systems may still be used to comply with the pulping process condensate standards, however, the monitoring procedures have been revised. In the

l-34final rule , mills using a biological treatment system to treat pulping process condensates must monitor, on a daily basis, samples of outlet soluble biochemical oxygen demand 5-day test (BOD5) concentration (maximum daily and monthly averages), inlet liquid flow , mixed liquor volatile suspended solids, liquid temperature , and the horsepower of aerator units. Additionally, inlet and outlet grab samples from each biological treatment system unit must be collected and stored for 5 days. These samples must be collected and retained since some of the monitoring parameters (e.g. , solubl e BOD 5 ) can not be determined within a short period of time. These samples are to be used in conjunction with the WATER8 emissions model to demonstrate compliance if any of the monitoring parameters (except the liquid temperature and inlet flow) fall outside the range established during the initial performance test. Additionally, quarterly percent reduction tests must be performed using the WATER8 model and site-specific inputs. The first quarter test must be performed for total HAP while the remaining quarterly tests may be performed for methanol only. 1.4.5 Sulfite Standards At proposal , all pulping vent streams from sulfite processes were required to be enclosed and routed to a control device achieving 98 percent reduction in emissions. In the March 8, 1996 supplemental notice , the Agency discussed in detail its determination that the sulfite standards should be based on absorption technology and apply to the total emissions from specific vents and any wastewater emissions associated with HAP emission control devices. The specific vents are associated with the digester, evaporator , and pulp washing systems.

l-35Several commenters objected that the proposed emission limits were not appropriate because they were based on limited data that did not reflect the variability of emission from sulfite pulping processes. The commenters provided the Agency with emissions test data that illustrated fluctuations in the methanol mass emissions over an extended time period due to variations in products and process conditions. The Agency evaluated the information provided by the commenters and subsequently agreed with the commenters regarding process variability at sulfite mills. For sodium- and calciumbased sulfite pulping processes, the final emission limit is 0.89 lb/ODTP. For ammonium- and magnesium-based sulfite pulping

processes , the final emission limit is 2.2 lb/ODTP. Because the emission limits were statistically derived to reflect process variability, these emission limits and corresponding monitoring parameters are never-to-be-exceeded values. 1.4.6 Soda and Semi-Chemical Mill Standards The proposed standards required the owners or operators of new or existing semi-chemical and soda mills to comply with the same pulping standards as kraft mills. As a consequence of subcategorizing the pulp and paper industry by pulping type, different MACT control requirements were developed for soda and semi-chemical mills. The final rule requires existing soda and semi-chemical mills to control the digester and evaporator systems (LVHC system). New soda and semi-chemical mills are required to control the LVHC and the pulp washing systems.
1.4.7 Bleaching System Standards In the December 17, 1993 proposed rule, all HAP emissions from bleach plants were required to be reduced by 99 percent

l-36using a caustic scrubber. The Agency proposed to control chlorinated HAP emissions only , using chlorine as a surrogate for chlorinated HAP. As an alternative to the percent reduction standard, the Agency proposed a 10 parts per million by volume (ppmv) HAP caustic scrubber outlet concentration (measured as chlorine). The Agency also proposed that chloroform emissions be controlled by using 100 percent chlorine dioxide (ClO 2 ) substitution and eliminating hypochlorite use or by complying with the requirements of the Effluent Limitation Guidelines and Standards of the Clean Water Act (CWA). In addition, the Agency proposed different control requirements for paper-grade and dissolving-grade bleaching systems. The Agency also solicited comments on providing a mass emission limit alternative to the percent reduction and the outlet concentration standards. The final rule continues to require chlorinated HAP emissions (not including chloroform) to be reduced by 99 percent

(based on caustic scrubbing). As an alternative, bleach plants can achieve an outlet concentration limit of 10 ppmv total chlorinated HAP or a mass emission limit of 0.001 kg of total chlorinated HAP (not including chloroform) per Mg ODP produced

(0.002 lb/ODTP) (not including chloroform) for the following bleaching systems: systems that use chlorine; systems at kraft, sulfite, or soda pulping processes that use any chlorinated compounds ; and systems that use ClO 2 to bleach pulp from mechanical wood pulping processes or from any process using secondary or non-wood fibers. A bleaching system that does not use any chlorine or chlorinated compounds is exempt from controls. The mill may use chlorine as a surrogate for chlorinated HAP other than chloroform.

l-37All bleaching systems are also required to control chloroform emissions by using 100 percent ClO 2 substitution and eliminating hypochlorite use or by complying with the effluent limitation guidelines and standards. For dissolving-grade bleaching systems , the effective date of compliance with all the bleaching standards has been stayed until the effluent limitation guidelines and standards for dissolving-grade mills are promulgated. 1.4.8 Compliance Schedule In the December 17, 1993 proposed rule, the compliance schedule for all pulping and bleaching processes was 3 years. The final rule allows a total of 8 years to comply with the HVLC vent standards at kraft pulp mills. Since the industry will be implementing both water and air rules essentially at the same time, the extended compliance schedule was adopted to allow the necessary time to fully consider all pollution control options including pollution prevention. Given the engineering requirements , permitting requirements , and resources necessary to implement the standards , the Agency decided that additional compliance time for kraft HVLC sources is appropriate. The 3-year compliance schedule is retained for semi-chemical, sulfite, and soda pulping processes the LVHC kraft pulping vent standards, and bleaching systems at paper-grade mills. Standards for the pulping process condensates apply to streams that are typically not recycled or reused in the pulping process without prior treatment. Therefore, the Agency did not consider it necessary to extend the additional compliance time to pulping

wastewater streams. Dissolving-grade mills are required to comply with the bleaching system standards no later than 3 years

1-38after promulgation of the effluent limitation guidelines and standards for dissolving-grade mills under 40 CFR 430, subpart D. In addition , the final rule sets out a two-phased standard for paper-grade bleach plants at a limited number of mills which elect to control wastewater discharges to levels surpassing the Advanced Technology Incentives Program in the effluent limitation guidelines and standards portion of the final rule. The first phase for existing source MACT requires no increase in the existing HAP emission levels from the paper-grade bleaching system (i.e. , no backsliding) during the interim period when the mill is working toward meeting their advanced technology (Best available technology (under the Effluent Limitation Guidelines and Standards of the Clean Water Act) (BAT) requirements. The effective date of the first phase requirements is 60 days from the date of publication in the Federal Register of the final rule. The second phase requires compliance with revised MACT based on baseline BAT requirements for all parameters, or 100 percent ClO 2 substitution and elimination of hypochlorite, for bleached paper-grade kraft and soda mills. The compliance date of the second phase of existing source MACT would be 6 years after publication of the standards in the Federal Register. The final rule also includes requirements for kraft mills to submit a non-binding control strategy report along with the initial notification. The purpose of the control strategy report is to provide the Agency and the permitting authority with a means for measuring a mill's progress towards compliance. The control strategy report contains information such as a description of the emission controls or process modifications selected for compliance with the control requirements and

1-39compliance schedule. The information in the control strategy report must be revised or updated every two years until the mill is in compliance with the standards of § 63.443. 1.4.9 Test Methods At proposal , the Agency required that Methods 308 and 26A be used to test for compliance with the provisions of the rule. Method 308 is used to measure methanol in vent streams. Method 26A is used to measure chlorine in vent streams. Method 305 is used to measure methanol in wastewater streams. Since proposal , Method 308 has been validated using Method 301 validation criteria. Method 308 has also been revised to incorporate the technical comments received after proposal. The Agency evaluated the commenter's claims regarding the appropriateness of Method 26A and agrees that ClO 2 is a potential interferant to the method. In the final rule the Agency decided to incorporate modifications to Method 26A, based on the industry chlorine test method. In March of 1997 , industry communicated to EPA that Method 305 was not used by National Council of the Paper Industry for Air and Stream Improvement (NCASI) to obtain the data used to evaluate steam stripper system performance. Consequently, industry asserted that Method 305 should not be specified in the final rule for determining compliance with the pulping process condensate standards. However, the method originally used by NCASI has not been validated using the Method 301 procedures. The Agency has considered the industry argument and has decided to proceed with specifying Method 305 in the final rule. However, EPA may amend the rule with a supplemental Federal Register notice to allow this method to be used as either an

l-40alternative or a replacement for Method 305 pending satisfactory completion of the Method 301 validation procedures. 1.4.10 Control Device Downtime At proposal , emission limits were required to be met at all times, except during startup, shutdown, or malfunction. No allowance for control devices or collection system downtime was specified in the rule. The EPA re-evaluated the need to incorporate downtime or excess emissions allowances for LVHC , HVLC, and steam stripper systems. Based on the information collected in the 1992 voluntary MACT survey (A-92-40 , IV-B-8) EPA has concluded that 100 percent compliance is not achievable at a well-designed and operated system in this industry. The data indicate that some allowance for excess emissions is part of the MACT floor level of control. In the final rule , EPA established excess emissions allowances to approximate the level of downtime and number of backup control devices that exist at the best-performing mills. The excess emissions allowances are designed to account for periods when the control device is inoperable and when the operating parameter values established during the initial performance test cannot be maintained due to problems with the

process. The excess emissions allowance for LVHC system control devices is 1 percent of the operating hours on a quarterly basis. For the HVLC system control devices or for control devices that reduce both LVHC and HVLC system vent gases, the excess emissions allowance is 4 percent. For LVHC and HVLC systems, the excess emissions allowances do not include scheduled maintenance activities malfunctions, startups, and shutdowns. Malfunctions,

l-41startups, and shutdowns must comply with the part 63 general provisions. The excess emissions allowance for steam stripper systems is 10 percent. This downtime allowance includes all periods when the stripper systems are inoperable including scheduled maintenance. 1.4.11 Equipment Enclosures, Closed-Vent Svstems, and Control Equipment 1.4.11.1 Requirements for Closed-Vent Systems. At proposal, the Agency required specific standards and monitoring requirements for closed-vent systems. The standards required:

(1) maintaining a negative pressure at each opening, (2) ensuring enclosure openings that were closed during the performance test be closed during normal operation, (3) designing and operating closed-vent systems to have no detectable leaks, (4) installing flow indicators for bypass lines , and (5) securing bypass line valves. Monitoring requirements included visually inspecting seal/closure mechanisms and closed-vent systems and demonstrating no detectable leaks in the closed-vent system. The Agency evaluated comments on these provisions and made several changes to the closed-vent system requirements. The Agency agreed with the commenters that most closed-vent systems will be under negative pressure. Any leaks, therefore, would pull air into the collection system rather than release HAP's to the atmosphere. Therefore, the Agency revised the requirement for demonstration of negative pressure and no detectable emissions to apply only to enclosures/hoods and portions of the closed-vent system operated under positive pressure. The Agency also agreed that requiring a lock and key type seal on bypass

1-42lines would be burdensome and could potentially pose a safety hazard. The intention of the requirements was to prevent circumvention of the control device by venting directly to the atmosphere. The Agency believes that this assurance can be achieved using car-seals or seals that could easily be broken, to indicate when a valve has been turned. The Agency revised the bypass line requirements to allow the use of car-seals but require log entries recording valve position, flow rate, and other parameters. The Agency has modified the enclosure requirements to allow for short-term openings for pulp sampling and maintenance. The final rule retains the visual monitoring requirements. These requirements can be conducted at a reasonable cost and are necessary to ensure proper operation of collection systems.
1.4.11.2 Concentration Limit for Combustion Devices and Design Incinerator Operating Parameters. At proposal, the rule required vent streams to be controlled in a combustion device that achieves 98 percent reduction of HAP's or a thermal oxidizer that achieves an outlet HAP emission concentration of 20 ppmv corrected to 3 percent oxygen. Alternatively , mills could comply with the control requirements by routing vent streams to a design incinerator operating at 1,600 O F with a residence time of 0.75 seconds or to a boiler, lime kiln, or recovery furnace. In the final rule , EPA maintained the design incinerator operating requirements. The EPA re-evaluated the 3 percent correction factor in order to ensure that it is appropriate for the pulp and paper industry. Based on industry data and thermodynamic models, EPA decided to revise the oxygen correction factor to 10 percent in

l-43the final rule. Therefore, the final rule allows thermal oxidizers to be in compliance if they reduce HAP concentrations to 20 ppmv corrected to 10 percent oxygen. 1.4.12 Interaction With The Resource Conservation and Recovery

Ac t (RCRA) Following proposal , industry presented an approach for recovering the energy contained in steam stripper condensates. The condensates exhibit characteristics that would lead to its classification as a hazardous waste under the Resource Conservation and Recovery Act (RCRA). After review of the characteristics of the condensate, the Agency concluded that no additional control under RCRA is warranted since combustion of these condensates will not increase environmental risk , would reduce secondary impacts, and would provide a cost savings. Therefore, the final rule contains a direct final notice that amends RCRA to allow the on-site combustion of condensates derived from steam stripping systems used to comply with the pulping process condensate standards. 1.5 SUMMARY OF IMPACT OF FINAL STANDARDS This section summarizes the emissions, energy, cost, and economic impacts for the final NESHAP. 1.5.1 Emissio n Impacts This NESHAP will reduce nationwide emissions of HAP from pulp and paper mills by 139,000 Mg/yr (154,000 tpy), which represents a 67 percent reduction by 2005 compared to the emissions that would result in the absence of standards. Emissions of volatile organic compounds (VOC) will be reduced by 409,00 0 Mg/yr (450,000 tpy), which represents a 49 percent reduction by 2005 compared to emissions that would result in the

l-44absence of standards

. Emissions of total reduced sulfur (TRS) compounds will be reduced by 78,500 Mg/yr (86,500 tpy), which represents a 54 percent reduction by 2005 compared to the emissions that would result in the absence of the standards. 1.5.2 Energy Impacts The national energy usage required to comply with the NESHAP is expected to increase by 33 x 10 12 British thermal units (Btu's) per year. The additional energy includes electricity required to power fans and blowers to transport vent streams to an emission control device , additional steam required for steam stripping of pulping condensates , and auxiliary fuel required for incineration of pulping area vent streams.
1.5.3 Secondary Environmental Impacts Secondary environmental impacts of the NESHAP include increased emissions of carbon monoxide (CO), nitrogen oxide

(NO x ), sulfur dioxide (SO 2 ), and particulate matter (PM). Secondary impacts are generated from combustion of fuel used to power pollution control equipment and as a by-product of the destruction of HAP's in combustion devices. Sulfur dioxide emissions are expected to increase by approximately 94,500 Mg annually. Sulfur dioxide emissions are generated primarily from the combustion of sulfur-containing compounds (such as TRS) in the vent streams at kraft mills. The CO emissions are expected to increase by approximately 8,660 Mg annually. The NO x emissions are expected to increase by approximately 5,230 Mg annually. The PM emissions are expected to increase by approximately 83 Mg annually.

l-451.5.4 Cost Impacts The implementation of this NESHAP is expected to result in an annualized national cost of $130 million/year. This estimate includes a cost of $123 million/year for air pollution control devices and operational changes, and a monitoring, recordkeeping, and reporting cost of $7 million/year. Table l-4 presents the national control cost impacts for the NESHAP at mills that pulp wood using the kraft, semi-chemical , soda and sulfite processes. No significant costs from mills that mechanically pulp wood, pulp secondary fibers or non-wood are anticipated.
1.5.5 Economi c Impacts and Benefits Utilizing the estimated annualized cost of this NESHAP, an evaluation of the economic impacts and distributional effects to the pulp and paper industry is performed. The final rule when evaluated independently of other regulatory requirements for air and water pollution , is not expected to have a substantial impact on the industry. Estimated price increases are less than 0.5 percent for bleached paper-grade kraft and sulfite, dissolving-grade kraft and sulfite , and semi-chemical pulp and paper products , while unbleached kraft pulp is estimated to have a price increase of almost 5 percent. The costs imposed on affected facilities do not result in any mill or firm closures, thus, the rule assessed individually is not expected to alter employment, shipments , or exports for the industry by appreciable

amounts. Implementation of the final rule is expected to reduce emissions of HAP's, VOC, and TRS , but increase emissions of PM,

SO 2 , CO, and NO x . The benefits (damages) that accrue as a result of the standard result from changes in human health effects

l-46TABLE l-4. NATIONAL COST IMPACTS FOR NESHAP a

Cost category Total capital Total annualized investment cost b (million $) (million $/yr) Control Equipment Costs Kraft 452 117 Sulfite 23 5 Semi-chemical 11 1 Soda 2 0.2 Recordkeeping and Reporting Costs
Total 8 7

496 130

a Impacts are for controlling air emissions after the CWA

effluent guidelines are implemented.

b Amortized capital costs plus operation and maintenance costs.

l-47associated with inhalation of the above pollutants, as well as, changes in welfare effects, such as: visibility and crop yields, materials soiling and corrosion. The EPA is not able to place a monetary value on all of the benefits achieved by the rule. Values are obtained for changes in VOC, PM, and SO 2 emissions only. Total benefits for these pollutants range in value from

($1,040) million to $1,054 million for the NESHAP, and ($727) million to $1,493 million for the entire cluster rule.

l-482.0 INDUSTRY CHARACTERIZATION

2.1 ADEQUACY OF DATA FOR STANDARDS DEVELOPMENT

Comment: One commenter (20,059) contended that the data base was unrepresentative of actual control levels because it did not take into account best available control technology (BACT) or lowest achievable emission rate (LAER) determinations. The commenter (20,059) asserted that the Act requires EPA to include all BACT determinations and all but the most recent LAER determinations in determining the floor levels of control for MACT standards. The commenter (20,059) asserted that Congress intended for EPA to gather actual emissions data from a sample likely to represent the top performers in order to determine the floor level of control , and that a data gathering program must be sufficient to ensure that EPA does not miss any sources that have superior levels of emissions control. The commenter (20,059) contended that EPA claimed to have reviewed BACT and LAER in the BID (A-92-40 , II-A-35) but had not provided any data or analyses in the BID. Therefore, the commenter (20,059) concluded that EPA had not collected or evaluated the data needed to identify the average emission limitation achieved by the best-performing 12 percent of sources as required by the statute. Response: BACT is the level of control required in attainment areas undergoing Prevention of Significant

2-1Deterioration (PSD) review. LAER is the control level required in nonattainment areas undergoing New Source Review. Both are determined on a case-by-case basis. In establishing the MACT
level of control , EPA evaluated existing controls at all mills, including the BACT/LAER controls in place as a result of PSD/NSR review (although in some circumstances, EPA may not consider LAER
level of control to be MACT ; see Act section 112(d)(3)(A)). The BACT and LAER determinations are accounted for in the control devices that were reported in the MACT survey responses. These controls were used to calculate the baseline emissions and baseline level of control. 2.2 EMISSION FACTORS 2.2.1 Data and Approach Used
Comment: Several commenters on the proposed rule (20,011, 20,043, 20,054, 20,056, 20,071, 20,102, 20,103, 20,115) expressed concerns over the use of general models and liquid-based emission factors for a mill-wide characterization because: (1) it was unreasonable and insupportable to base decisions in the rulemaking on emission factors for vent streams developed from models and from liquid stream concentrations, and (2) actual measured data should have been used to develop the emission factors. Two commenters (20,011 , 20,027) asserted that EPA models did not have the capability to accurately predict emissions. One of the commenters (20,027) asserted that: (1) the emission factors used in the model process units were based on several assumptions for which they could find no scientific or technical basis (the

commenter provided several examples of erroneous assumptions),

(2) the models for estimating air emissions from HAP

2-2concentrations tested in process wastewater incorrectly assumed that equilibrium was reached between the water and air components, and (3) they were not aware of data pertaining to liquid-phase HAP concentrations entering or exiting bleach plant equipment that would be sufficient for developing reliable air emission rates for standards development. Two commenters (20,102, 20,129) recommended that EPA develop more specific emission factors for various emissions from the pulping area. One of the commenters (20,129) indicated that EPA should summarize the air emission data from NCASI Technical Bulletin No

. 650 into emission factors dealing with the MACT regulation and for Compilation of Air Pollutant Emission Factors, 5th edition, Volume 1: Stationary Point and Area Sources (AP-42) emission inventory purposes. After reviewing the industry data,

one commenter (20,054A2) pointed out that there appear to be differences in various process emissions, which if properly understood , may provide options for less expensive controls. One commenter (20,071) concluded that the approach that EPA used to characterize the HAP emissions of over 160 diverse chemical pulping mills (including bleached kraft, unbleached kraft, sulfite, and semi-chemical processes) was inadequate for a regulation with such significant financial impact on the industry. The commenter (20,071) stated that EPA should not have relied on limited data and the extrapolation of these data through mathematical models to develop emission factors. Response: At proposal , EPA developed emission factors for each type of individual emission point typically found at pulp and paper mills. The emission factors were developed from measured air emissions at process vents and from air emissions

2-3estimates extricated from liquid stream data, assuming equilibrium conditions. This information was the best data available to EPA. Based on test data received after proposal, EPA changed the approach from individual emission point factors to emission factors based on mill systems. Availability of these data was announced in the Federal Register on February 22, 1995 and proposed changes to emissio n factors were announced in the March 8, 1996 Federal Register supplemental notice. The EPA concluded that the system approach is the best approach because it provides a more objective comparison of mills and lessens the problems associated with the nomenclature assigned to individual process components. The EPA believes that the revised system emission factors provide the best data to characterize emissions from the pulp and paper industry. The EPA concluded that the liquid-based model used at proposal provided an adequate estimate of emissions when compared to the actual test data. However, the system emission factors used in the final rule were not based on the liquid-based equilibrium models , but on actual data received from industry after proposal. Since most of the standards in the final rule remain at the MACT floor level , the significance of emission factors is somewhat reduced.

Comment: One commenter (20,122) expressed concern about the chloroform releases that occur even with ClO 2 substitution. To support their concern , the commenter (20,122) reported an estimated chloroform emission factor of 0.22 tons per 1,000 tons of pulp for market bleached kraft mills using ClO 2 substitution.

2-4Response: Emission information submitted to EPA from several facilities provides an emission factor of 0.39 lb chloroform per oven-dried ton of pulp (ODTP) for bleaching systems operating with 100 percent ClO 2 substitution and a hypochlorite bleaching stage. This emission factor reduces to 0.012 lb of chloroform per ODTP for bleaching systems operating with 100 percent ClO 2 substitution and no hypochlorite bleaching stage. The emission factor submitted by the commenter (20,122) for chloroform of 0.22 tons of chloroform per 1,000 tons of pulp converts to 0.44 lb of chloroform per ton of pulp, which is comparable to the emission factor of 0.39 lb chloroform per ODTP for bleaching systems operating with 100 percent ClO 2 substitution and a hypochlorite bleaching stage. The MACT floor level of control at bleaching systems is caustic scrubbing and process modifications (100 percent substitution and no hypochlorite use). The effluent limitation guidelines and standards requirements for paper-grade bleaching are also 100 percent substitution of ClO 2 and no hypochlorite

(EPA is evaluating requirements for dissolving-grade bleach mills). The EPA considers the effluent limitation guidelines and standards requirements to be at least as stringent as the floorlevel process modifications. Therefore, the final rule requires compliance with the effluent limitation guidelines and standards requirements to control chloroform in the bleaching system or certification that no hypochlorite or chlorine is used for bleaching. This requirement will significantly reduce chloroform emissions from bleaching systems because chloroform emissions are related to using hypochlorite as a bleaching agent.

2-52.2.2 Emission Factor Document

Comment: After evaluating the draft Chemical Pulping Emission Factor Development Document (A-92-40, IV-A-6), one commenter (IV-Dl-102) provided suggestions and comment on the development of emission factors. In particular, the commenter disagreed with the HAP ratio procedure used. The commenter

(IV-Dl-102) perceived two flaws with the approach: (1) EPA ignored results where a compound was tested but the results were below the detection limit, and (2) EPA assumed, in the absence of data, that the ratios between specific HAP compounds and methanol were constant for a given type of source (e.g., brownstock washers or weak black liquor tanks). Response: Generally, the scope of the emissions tests were limited to a select group of compounds. In the draft emission
factor document , the method used to estimate emission factors was based on the assumption that the ratio of a compound's concentration in a vent to the concentration of methanol in the same vent is similar to the ratio in vents of similar systems. Based on industry comments , the data were re-evaluated and a system-unit approach to estimating emission factors was adopted in place of the previous HAP-ratio approach. The system-unit approach consists of sorting the data for each HAP species into the same mill-system groupings used to develop the methanol emission factor, as described in the revised Chemical Pulping Emission Factor Development Document (A-92-40, IV-A-8). Where sufficient data to characterize a HAP compound by mill system were not available , the unit approach was used for that compound. In the unit approach , equipment-specific emission factors were developed. Then , mill system equivalent emission

2-6factors were generated for these compounds by assuming that mill systems are typically made up of certain equipment configurations (e.g., the typical pulp washing system consists of three washer hood vents and one filtrate tank vent). The system-unit approach accounted for results below the detection limit. For compounds for which a detection limit was reported, one half of the detection limit was used. If no detection limit was recorded in the test report, that test was
not used. The EPA believes that the system-unit approach to analyzing the industry test data provides an accurate characterization of emissions by incorporating results below the detection limit and avoiding assumptions of constant ratios across different sources.

Comment: One commenter (IV-Dl-102) disagreed with EPA's contention in the draft emission factor document (A-92-40, IV-A-6) that the summary of results presented in the NCASI Technical Bulletin No

. 701 (IV-J-31) fall within the ranges developed in the draft emission factor document and will not significantly alter the results. The commenter (IV-Dl-102) agreed that the methanol results would not be significantly different but argued that the summary of HAP emissions would need to be revised upon incorporating the Technical Bulletin

No. 701 data. Response: The data presented in NCASI Technical Bulletin No

. 701 are a summary of the same data that EPA used to revise the emission factors ; they are not new or separate test data. The EPA agrees that the methanol emissions would not be significantly different by including of the NCASI Technical Bulletin No. 701 data. The EPA also agrees that the approach to

2-7determining total HAP used in NCASI Technical Bulletin No. 701 would result in significantly lower total HAP emissions for the mill systems. The approach used to develop speciated HAP emission factors for the final rule has been revised and is more consistent with the results in the Technical Bulletin No. 701

summary. (See previous discussion regarding the mill system-unit approach.)
Comment: One commenter (IV-Dl-102) noted two problems with the appropriateness of the model plant approach: the lack of neutralization units in some models, and the lack of a diffused aeration model plant. The commenter (IV-Dl-102) also questioned the number of mills assigned to the model plants. Response: Because neutralization occurs in units besides stric t "neutralization basins, " EPA does not believe that the absence of explicit neutralization units in some models is inconsistent with the models having neutralization units. Also, the available data do not support creating a diffused aeration model or making changes to the mill assignments. Since no new data were provided , EPA maintains that the model plants and mill assignments used are an accurate representation of the industry.
Comment: One commenter (IV-Dl-102) disagreed with three aspects of the WATER8 modules: the model plant B settling pond, the assumption that in the model plant C that neutralization occurs in stabilization basins following the clarifier, and the model plant D non-aerated basin. The commenter (IV-Dl-102) expressed concern over the length of settling basin residence time in model plant B. The commenter (IV-Dl-102) also objected to having neutralization follow the model plant C clarifier and to having the model plant D polishing basin as non-aerated.

2-8Response: The residence time for the model plant B settling basin is based on a settling pond at one kraft paper mill. The WATER8 outputs for that mill (based on the assumed residence time) agree with the test data. In model plant C , no neutralization was assumed to occur in the basins following the clarifier. Neutralization was assumed to occur between the bar screen and the clarifier. The non-aerated basin in model plant D was determined to be improperly labeled as aerated. The current basin is a composite of the ten model plant D mills with non-aerated systems and the 11 mills with aerated systems. The EPA does not believe that revising the WATER8 inputs would yield a significant change, but the labels and documentation of the approach have been updated.
Comment: Eight specific WATER8 input parameters (e.g., concentrations, temperatures) were rated by one commenter

(IV-Dl-102) as inconsistent, inaccurate, or unreasonable. Response: The EPA evaluated the commenter's concerns and data characterizing the industry. The results of the evaluation show that the parameters used in the WATER8 model accurately reflect the industry based on comparison with industry data. Based on EPA's analysis of the commenter's concerns and suggestions , EPA maintains that only minor changes would result from altering the input parameters as suggested by the commenter (A-92-40, IV-B-101).
Comment: One commenter (IV-Dl-102) asserted that the WATER8 primary clarifier module overestimates emissions. Response: Validation of the WATER8 primary clarifier module is documented in a memorandum included in the revised emission

2-9factor document (A-92-40, IV-A-8). The EPA maintains that the WATER8 primary clarifier module adequately estimates emissions.

Comment: One commenter (IV-Dl-102) supplied WATER8 outputs using modified input parameters , and suggested updating the emission factor document to reflect emission estimates based on the modified input parameters. Response: The EPA reviewed the industry-derived emission
factors for methanol and chloroform. Although the revised
methanol results were lower , the revised chloroform results were higher than those obtained by the Agency's model. The EPA believes that the current model adequately characterizes emissions from wastewater treatment and did not incorporate the industry-derived emission factors since the factors had little effect on overall HAP emission estimates.
Comment: One commenter (IV-Dl-102) noted the following specific concerns about using kraft mill system emissions as defaults for non-kraft mill systems where data were not available:

. Oxygen delignification systems at sulfite mills are configured differently from kraft oxygen delignification systems and should have a different emission factor based on typical equipment.

. Stand-alone semi-chemical mills should have refiners rather than knotters and screens, and the causticizing area at a stand-alone semi-chemical mill would not have a lime kiln, lime mud washer, or slaker.

. Kraft digester and evaporator numbers should not be used for other types of pulping because of the different liquor characteristics and cooking conditions.

. Semi-chemical pulping wastewater has considerably lower methanol concentrations than kraft pulp mill

2-10wastewater , so it does not seem appropriate to use average kraft mill values.

Response: In response to these specific concerns, EPA made the following revisions to the emission factor document:

. No data were supplied in relation to oxygen delignification systems at sulfite mills; therefore no revisions were made.

. The knotter and screening systems at stand-alone semichemical mills were correctly identified by the "refiner " terminology; however, no data were available to suggest that the emissions from the pre-washing screening area are different at semi-chemical mills.

. The equipment that is not present at a stand-alone semi-chemical mill causticizing area were removed.

. Kraft digester and evaporator numbers were not used for semichemical and sulfite mills. The HAP emissions at soda mills are expected to be similar to the non-TRS HAP emissions from kraft mills. Therefore, the soda numbers were based on kraft emissions.

. Semi-chemical pulping wastewater emission characteristics were developed separately from the kraft characteristics. The revised emission factor document (A-92-40, IV-A-8) contains more detail regarding emission factor development, assumptions , and applications.

Comment: On e commenter (IV-Dl-102) asserted that the boiler methanol emission factor in the draft emission factor document (A-92-40 , IV-A-6) is too high and that the Agency has not adequately documented why 0.5 lb methanol/ODTP from a boiler, especially one without a wet scrubber, is typical of the industry.

2-11Response: Emissions from boilers are not addressed under this rule and the boiler methanol emission factor does not impact the final rulemaking. Since it was not relevant to this standard, EPA did not revise the emission factor for the NESHAP. The boiler emission factor is discussed and evaluated in further detail in the revised emission factor document (A-92-40, IV-A-8).

Comment: One commenter (IV-Dl-102) stated that the reason for the difference in chloroform generation in the bleach plants is largely a function of chlorine use. The commenter (IV-Dl-102) stated that the difference should not be attributed to the presence or absence of oxygen delignification. Response: The EPA agrees with the commenter that other parameters besides the presence of oxygen delignification have greater impact on chloroform emissions from the bleach plants. The presence of a hypochlorite stage in the bleach sequence and the degree of ClO 2 substitution have both been determined to significantly affect bleach plant chloroform emissions. Greater detail and data analysis pertaining to this issue are presented in the revised emission factor document (A-92-40, IV-A-8). 2.3 MODEL PROCESS UNITS
Comment: Two commenters (20,027 , 20,086) stated that EPA should not have used model process units to evaluate the range of possible control options and the ability to achieve the proposed MACT standards ; they should have evaluated these things on a "real world" mill-by-mill basis. Another commenter (20,011) argued that invalid process models led to mischaracterized pulp mill and wastewater emissions. One commenter (20,027) cautioned that the models used for semi-chemical mills and sulfite mills were incorrect. The

2-12commenter (20,027) contended that for semi-chemical mills, EPA incorrectly assumed that there were digester relief gases and digester blow evaporators. The commenter (20,027) recommended that mill Q from the industry test program be used as the basis for the semi-chemical model mill rather than EPA's models P9

an d PlO. The commenter (20,027) also claimed that the sulfite pulping model mill developed by EPA did not accurately reflect the process emissions points because several of the emission points in the sulfite model (P7) were inappropriately taken from the kraft model (P2). The commenter (20,027) did not provide alternative points. Another commenter (20,072) indicated that their model developed for a soda mill was more effective at estimating the effects of process changes at soda mills than a model which uses kraft TRS control technology. The commenter (20,072) provided a report on this mathematical model. Response: Based on comments and data received after proposal, EPA has re-evaluated the methodology used to estimate national impacts for the pulp and paper industry. The impacts estimated in the final rule were determined for each mill using mill-specific data provided by industry after proposal. Therefore, the MACT floor analyses and impacts analyses were based on actual processes and controls at each of the mills and were not based on models. Where information was missing , average characteristics of mills with similar pulping types were used to complete the data base. Through this revised analysis , EPA has more accurately estimated emissions from non-kraft mills. (Kraft models are not assigned to semi-chemical, sulfite, or soda mills because actual

2-13mill-specific data was used in place of model mills.) The

revisions to the national impacts analyses are discussed in detail in chapter 20 of this document.

2-143.0 SUBCATEGORIZATION

Comment: Several commenters to the December 17, 1993 proposed rule (20,001, 20,011, 20,018, 20,027, 20,054A2, 20,072A8, 20,086) requested that EPA subcategorize mills by pulp type because different pulp types have different emission characteristics, baseline controls, and retrofit costs. One commenter (IV-D2-15) on the March 8 , 1996 supplemental notice supported the decision to subcategorize by pulping type. Two commenters (20,027 , 20,072A8) supported their argument to subcategorize by noting that section 112(c)(l) of the Act requires MACT standards to be consistent with the list of source categories established in section 111. The commenters (20,027, 20,072A8) contended that section 111 New Source Performance Standards (NSPS) source categories only include kraft pulping mills, and do not include semi-chemical, soda, or sulfite pulping mills. Therefore, the commenters concluded that EPA should have treated kraft mills separately from other mill types. The commenters also suggested that sources other than kraft mills not be included in the regulation. Two commenters (20,059 , 20,103) recommended no subcategorization, agreeing with the consolidation of subcategories proposed by EPA and suggesting no further division or combination of subcategories. One commenter (20,059) on the

3-lDecember 17, 1993 proposed rule indicated that the industry has not provided data to support subcategorization. Another

commenter (20,011) contended that the lack of air and wastewater emissions data for sulfite, soda, and semi-chemical mills prevented a balanced assessment of the need for subcategories. Response: Section 112 of the Act requires NESHAP for categories of major sources of HAP. On July 16, 1992, EPA published a list of source categories for the 189 listed HAP's

(57 FR 31576). Pulp and paper production was listed as a major source of HAP emissions. Soda, semi-chemical, and sulfite mills are major HAP sources and, therefore , are being regulated as a part of this source category. The final standards are based on evaluation of all available data for potentia l controls and the best opportunity for integration with effluen t guidelines.
In the March 8 , 1996 supplemental notice , EPA presented the rationale for establishing separate subcategories based on pulping type (kraft, soda, sulfite, or semi-chemical). The establishment of the subcategories was based on comments received and review of additional emissions information submitted after proposal of the standards. The information obtained after proposal indicated that as a result of the differences in digestion methods, mills utilizing different types of pulping systems produce different emissions, and as a result , achieve different degrees of control with different applicable control technologies. At proposal, EPA understood that the four types of mills differ in the way they digest wood to make pulp , but did not have the data to determine the extent to which these differences influence potential emission control strategies. The information received after

3-2proposal indicated the significant extent of these differences. The commenters are referred to the March 8, 1996 supplemental notice for a detailed discussion of the differences between the pulping types and rational e for the decision to establish each of the subcategories. Where two or more subcategories are located at the same mill site and share a piece of equipment, that piece of equipment would be considered a part of the subcategory with the more stringent MACT requirements for that piece of equipment. For example, the pulping process condensates from an evaporation set processing both kraft weak black liquor and spent liquor from a semi-chemical process would have to comply with the kraft subcategory requirements for pulping process condensates. This more stringent requirement is appropriate because there is no viable way to isolate the emission s for each pulping source to determine compliance separately.
Comment: One commenter (20,043) indicated that separate subcategories should be established for dissolving-grade and nondissolving (paper-grade) sulfite mills based on significant differences that exist between dissolving- and paper-grade sulfite mills. The commenter (20,043) urged EPA to accurately characterize the emissions, control technology, and the costs of controlling emissions at dissolving-grade sulfite mills. Response: The EPA believes the commenter's point is valid for the bleaching systems at all mills, not just sulfite mills. In characterizing the bleaching system, there are greater differences between the paper-grade bleaching process and dissolving-grade bleaching process than between the type of pulp mill that proceeds the bleaching systems. The EPA evaluated the

3-3differences between paper-grade and dissolving-grade bleaching systems and determined the appropriate MACT requirements for each. The average emission limitation of the best-controlled paper-grade and dissolving-grade mills is control of chlorinated HAP's using a caustic scrubber and control of chloroform using process modifications. For paper-grade mills, the effluent limitation guidelines and standards were determined to be at least as stringent as the process modifications evaluated

(100 percen t ClO 2 substitution and no hypochlorite use). Therefore, the MACT requirements for paper-grade bleaching systems is caustic scrubbing for control of chlorinated HAP, other than chloroform , and compliance with the effluent limitation guidelines and standards or certification that no hypochlorite or chlorine is used for bleaching for control of chloroform. The EPA at present lacks sufficient information to establish effluent limitation guidelines and standards at dissolving-grade mills, and also lacks information to reliably ascertain what a MACT floor standard for chloroform air emissions would be for this unit operation. The EPA is continuing to evaluate potential limitations for dissolving-grade mills and is deferring establishing MACT standards for chloroform until effluent limitation guidelines and standards are established. Therefore, dissolving-grade mills are required to comply with the bleaching system chloroform standards no later than 3 years after publication of the wastewater effluent limitation guidelines and standards under 40 CFR 430, subparts A and D.

3-4In a related action, EPA is also delaying MACT requirements

for chlorinated HAP's other than chloroform from dissolving-grade bleaching operations until 3 years after publication of the wastewater effluent limitation guidelines and standards under 40 CFR 430, subparts A and D. The Agency is doing so in order to avoid imposition of Act requirements that would be inconsistent with, or superseded by, forthcoming CWA regulations. A more detailed discussion of bleaching system compliance times is presented in section 17.2.

3-54.0 BASIS OF STANDARDS

4.1 STATUTORY INTERPRETATION 4.1.1 88t h percentile vs. 94th percentile Interpretation

Comment: Several commenters (20,027, 20,037, 20,046, 20,046A2, 20,056, 20,07OAl, 20,083, 20,089, 20,092, 20,102, 20,103, IV-D2-15 , IV-D2-7) objected to EPA's interpretation that the 94th percentile represents "the average emission limitation of the best-performing 12 percent of existing

sources." These commenters contended that: (1) the MACT floor level of control should be set at the 88th percentile rather than the 94th percentile , and (2) the 94th percentile interpretation was impractical; irrational; not allowed by the Act; significantly more costly than the 88th percentile interpretation

[Case law cited: Chevron, U.S.A. v. NRDC, 467 U.S. 837 (1984)]; and likely more stringent than that achieved by any existing

source. Several commenters (20,027, 20,054A2, 20,057A2, 20,070Al) advised that using the 88th percentile interpretation would have significant consequences regarding which pieces of equipment must be controlled , asserting that brownstock washers, oxygen delignification units , and weak black liquor storage tanks are not enclosed or controlled at the 88th percentile.

On e commenter (20,054A2) indicated that the method for determining the floor level of control was applied inconsistently

4-lbetween components that were controlled at greater than 12 percent and those controlled at less than 1 2 percent. The

commente r (20,054A2) stated that if the component was not controlled by at least 12 percent of mills, EPA determined what the top 6 percent of mills were doing. One commenter (20,122) supported EPA's interpretation that the MACT floor level of control effectively equaled the 94th percentile control technology , and one commenter (20,059) indicated that the interpretation was immoral because it was set below the minimum legal stringency for protecting human health. Several industry commenters (20,057A2, 20,059, 20,092, 20,102, 20,149) agreed with the interpretation of averaging the top 12 percent , but they did not agree with using the median to represent the average performance of these sources. Some

commenter s (20,057A2, 20,059) indicated that an arithmetic mean should be used regardless of corresponding control technologies, while others (20,092 , 20,102) indicated that the floor should be set at the next most stringent corresponding technology. One commenter (20,103) expressed support for EPA's use of the median of the top 12 percent , stating that the arithmetic mean may place too much emphasis on either the best or worst performing of the top 12 percent. Response: In the June 6, 1994 Federal Register (59 FR 29196) EPA presented its final decision regarding the interpretation of sectio n 112(d) (3) (A) of the Act for purposes of the Hazardous Organic NESHAP (HON). As presented in 59 FR 29196, EPA concluded that section 112(d)(3)(A) is best interpreted to require EPA to first determine the emission limitation achieved by sources within the best-performing 12 percent, and then

4-2average these limitations. This interpretation of the statute
has been referred to as th e "Higher Floor Interpretation." The Agency adheres to that interpretation in this rule. The Agency
notes, however, that while the interpretation presented in 59 FR 29196 sets a precedent, it is not binding since EPA believes the Agency retains discretion in establishing floors for MACT standards depending on the circumstances of each source category. The EPA has the discretion to use its best engineering judgment in collecting and analyzing the data, and in assessing the data's comprehensiveness, accuracy , and variability in order to determine which sources achieve the best emission reductions. The EPA fully considered all comments regarding the proper interpretation of section 112(d)(3)(A) of the Act in the context of the pulp and paper rulemaking. For this rulemaking, EPA held to the "Higher Floor Interpretation" (average of the best-performing 12 percent). Commenters on the December 17, 1993 proposal provided additional emissions and control information to be evaluated in determining the floor levels of control and characterizing the industry. After review of the data , EPA revised several aspects of the proposal. These changes are discussed in the March 8, 1996 supplemental notice. Specific changes to the rule and associated rationale are presented in the notice. In general, EPA determined that it was appropriate to subcategorize the pulp and paper industry based on pulping type (e.g., kraft, soda, semi-chemical, sulfite). Revisions were made to recalculate the floor level of control for regulated emission points within each subcategory. Additionally , emission points

4-3were grouped together to form mill systems in order to better characterize emissions from this industry. In determining the best-performing source s from which to compute the floor level of control, EPA calculated the emission controls for emission points within each system. In most cases , EPA relied on the arithmetic average of the best-performing sources. Whenever the resulting value did not correspond to an emission limitation that was achievable by any particular technology, the median of the bestperforming sources was used in order to develop a standard in fact reflecting achievable performance (see section 112(d)(2)). The EPA believes that the changes to the rule presented in the March 8 , 1996 supplemental notice result in floor determinations that are appropriate and reasonable for all mills within each subcategory. 4.1.2 MACT Floor on a "Per Unit" vs. "Whole Mill" Basis

Comment: Several commenters (20,027, 20,045, 20,051, 20,057A2, 20,066A3, 20,114, 20,118, 20,145, IV-D2-7) disagreed with EPA's use of the "best-performing individual emission units" to determine the MACT floor level of control, rather than considering the integrated mill performance. The commenters

(20,027, 20,045, 20,051, 20,057A2, 20,066A3, 20,114, 20,118, IV-D2-7) suggested that EPA overstated the MACT floor level of control , because it did not consider the interrelationship of the different processes used to produce bleached and unbleached kraft pulp, and the commenters indicated that this interpretation led to a floor level of control that exists at less than the top six percent of mills. The commenters (20,027, 20,045, 20,057A2, 20,066A3, 20,118, 20,145, IV-D2-7) asserted that this approach

4-4proved that EPA did not use a correct interpretation of section 112 of the Act. Response: The Act does not define "source." A source may be a facility , a kind of emission point, or a collection of emission points. The definition chosen for each MACT standard is dependent on the characteristics of the source category being regulated, and the information available to characterize emissions. The EPA has chosen to define a source in the pulp and paper rule as a collection of emission points (i.e., pulping system, bleaching system, pulping process condensates). The floor level of control was then determined for each emission point. This method is referred to as the "per unit" approach. The approach the Agency used to determine the floor level of control based on emission points was the most appropriate because this approach represents the best use of the data available. The data available at proposal consisted of responses from a 1992 voluntary MACT survey , a field test program of air and liquid samples from four kraft mills and one sulfite mill (the "EPA 5-mill study") and some limited industry data used to supplement the EPA 5-mill study. Based on comments and data received after proposal (A-92-40, IV-Dl-29, IV-Dl-29a, IV-Dl-31, IV-Dl-33, IV-Dl-34, IV-Dl-35, IV-Dl-38, IV-Dl-39, and IV-Dl-41), EPA reevaluated the approach and established the MACT floor by subcategories (i.e., kraft, soda, semi-chemical, sulfite). The EPA, however, retained the "per unit" approach to setting the MACT floor by adopting MACT standards for specifically defined equipment systems (pulping , bleaching) and associated wastewater streams within each subcategory.

4-5The EPA elected to determine MACT floors on a per unit basis

because sufficient information was not available to determine the MACT floor on a mill basis. Due to the differences in control technologies used in processes and systems in a mill, the MACT floor for a whole mill could not be based on a type of control technology, but would need to be based on emissions or percent reductions from the mills. Computing emission levels or percent reductions of the whole mill would require accurate site-specific knowledge of the emission levels of each process at each mill being regulated (i.e., emission source tests). At proposal EPA did not have sufficient data to establish a mass emission limit or a mass emission reduction percentage across each mill. Since proposal, EPA obtained site-specific information that was used to develop emission factors for various systems at a mill. However, these emission factors represent average or typical systems and are not specific to each mill. While EPA believes such information may be used to estimate national impacts, it is not adequate to determine the MACT floor level of control (i.e., the factors are not representative of the actual emissions at each mill but may be used to represent typical emissions from all mills). Actual mass emission levels or mass emission reductions would still be required. Information on the controls for various systems at each mill was available to EPA. Therefore, EPA decided to develop MACT floors on a unit (i.e., system) basis. Additionally, the day-to-day variability of the pulp and paper processes would preclude establishing mill-wide emission or percent reduction limits. These process variabilities include swings in production depending on the wood species available and

4-6products being produced , as well as other variables associated with using a natural feedstock such as wood.
4.1.3 Legal Requirement to Base MACT Floor on Actual Data

Comment: Several commenters (20,027, 20,061, 20,146) maintained that EPA is legally required to base the MACT floor on what is actually achieved by sources or sources technically similar. The levels achieved must be determined based on reliable data and analyses rather than on predictions or projections. On e commenter (20,027) asserted that EPA must redetermine the MACT floor based on actual data. Response: Section 112(d)(3)(A) of the Act requires that the maximum degree of reduction in emissions be calculated from "the average emission limitation achieved by the best-performing
12 percent of the existing sources (for which the Administrator has emissions information) . . ." (emphasis added). The EPA agrees with the commenters that the MACT standards should be based on the best data available to the Administrator and EPA contends that the data available at proposal was used properly. The EPA made all reasonable efforts to gather available data using literature , State regulations, previous studies, sampling tests, and a voluntary industry survey. Additionally, EPA worked with the pulp and paper industry to gather data and used data the industry submitted. Where information was lacking, average values from the data base were used to fill in gaps. Also, in the proposal of December 17, 1993, EPA acknowledged that industry had air emissions sampling and data collection underway. However, the data results were not expected to be available until after proposal. Therefore, the proposal stated that EPA would analyze and any data that became available before

4-7promulgation of the NESHAP. After proposal, commenters and industry representatives submitted additional data including results of sampling tests to EPA (A-92-40, IV-Dl-29, IV-Dl-29a, IV-Dl-31, IV-Dl-33, IV-Dl-34, IV-Dl-35, IV-Dl-38, IV-Dl-39, and IV-Dl-41). This information was evaluated and, where appropriate , changes were made to the proposed rule accordingly. A detailed discussion of EPA's evaluation and these proposed changes as well as EPA's plans to address some other concerns raised by the commenters are presented in the March 8, 1996 supplemental notice.
Comment: One commenter (20,011) indicated that the use of a model pulp mill improperly extended the MACT floor beyond the statutory definitions. Response: Model pulp mills were not used by EPA to determine the MACT floor. Rather, the MACT floor was based on data collected in the 1992 voluntary MACT survey of the industry. At proposal , model mills were used to estimate emissions and other regulatory impacts corresponding to the specific control options considered by the Agency. For the final rule, data from each mill were used to estimate emissions and regulatory impacts.
4.1.4 Legal Requirement to Re-propose
Comment: One commenter (20,027) contended that EPA is legally required to re-propose the standards after actual data is obtained in order to give the public the opportunity to comment on the new data and EPA's method for making the MACT determination. [Case law cited: National Lime Assoc. v. EPA, 62 7 F.2d 418, 433, 452-53 (D.C. Cir. 1980); Weyerhauser Co. v. Costle, 59 0 F.2d 1011, 1030 (D.C. Cir. 1978); Portland Cement

Assoc. v

. Ruckelhaus, 48 6 F.2d 375, 392-93 (D.C. Cir. 1973);

4-8Sierra Club v. Costle, 657 F.2d 298, 334 (D.C. Cir. 1981); Solite

Core v. EPA , 95 2 F.2d 473, 484 (D.C. Cir. 1991) quoting Connecticu t Light & Power v. NRC, 673 F.2d 525, 530-31

(D.C. Cir. 1982) ; Fertilizer Institute v. EPA, 935 F.2d 1303, 1311 (D.C. Cir. 1991) 

### .]

On e commenter (20,057A2) stated that the MACT standards should be re-proposed with EPA's proposed combustion source MACT standards. (A-92-40, II-I-13 and 11-I-18. Data provided: Appendix MACT 6.) Response: The EPA's position is that re-proposal is not required because notices of data availability for data received after the original proposal, EPA's assessment of the data, and proposed changes to the original proposal were published in the Federal Register February 22 , 1995 (60 FR 9813) and on March 8, 1996. The March 8, 1996 supplemental notice provided the public the opportunity to comment on the new information and on the approach under consideration by EPA in developing the final standards. These subsequent notices provided ample notice and opportunity to comment on all key elements of the standard, including data , potential floor levels of control, and potential
standards. In addition , EPA notes that it has provided actual notice and opportunity to comment to many key parties to the proceeding, including the pulp and paper industry and key environmental groups (A-92-40, section E). This ongoing dialogue again fully satisfies notice and comment obligations as to all persons having actual notice. The EPA cites Small Lead Refiners Phase Down Task Force v. EPA, 705 F.2d 506, 549 (D.C. M 83).

4-9The combustion MACT is a separate action and was proposed at promulgation of the pulp and paper mill rule. The EPA acknowledges that there are interrelations between this rule and the combustion MACT rulemaking. The EPA evaluated those interrelationships for the final rule (see chapter 16). The EPA maintains it is unnecessary to incorporate the combustion sources in this pulp and paper rule.
4.1.5 Control Devices Were Not Installed to Reduce HAP

Comment: Several commenters (20,011, 20,027, 20,043, 20,118) listed control devices (steam strippers and scrubbers) that should not have been considered MACT floor level of control technologies because they were not installed for the reduction of

HAP. Several commenters (20,027, 20,043, 20,118) pointed out that because steam strippers have never been calibrated or operated for the continuous emission reduction of HAP's, they should not have been considered a floor technology for HAP reduction from process wastewater. On e commenter (20,027) also noted that because scrubbers have not been installed in bleach plants to control methanol or total HAP's other than chlorine, they should not have been considered as the floor technology, as defined in section 112(d) (3) (A) of the Act. Response: Any technology that achieves HAP emission reduction can be considered a potential MACT control option regardless of whether or not the technology was installed for the purpose of HAP reduction. There is no language in section 112(d)(3) even suggesting that intent (i.e., the purpose for installing air pollution control devices) is relevant for purposes of establishing MACT floors. All that matters is the

"emission limitation achieved." In addition , as stated in

4-10sectio n 112(d)(2) of the Act, "Emission standards . . . shall require the maximum degree of reduction in emissions of the hazardous air pollutants that the Administrator, taking into consideration the cost of achieving such emission reduction, and any non-air quality health and environmental impacts and energy requirements, determines is achievable for new or existing

sources . . . through application of measures, processes, methods, systems, or techniques . . .'I Again, there is no suggestion that the purpose for which existing controls were installed is of any relevance. 4.1.6 Authoritv to Regulate Process Wastewater

Comment: Two commenters (20,027, 20,146) stated that the Act does not give EPA the authority to determine applicability for process wastewater provisions of the rule at the point of generation. Rather, emissions may only be regulated at the first air/water interface. The commenters (20,027, 20,146) contended that EPA has an obligation to state its theory on this issue, and support with data any arguments made to indicate that the HAP content in wastewater is indicative of air emissions that warrant regulation. Another commenter (20,011) stated that the regulation of process wastewater at "point of generation" is illegal unless EPA can demonstrate that it is infeasible to set an emission limit , and also prove that concentration-based limits are work practice standards under section 112(h) of the Act. One commenter (20,146) indicated EPA's conclusions that the control of HAP's from process wastewater was either a "floor" industry practice or was needed to protect public health or welfare was incorrect.

4-11Response: The Act does not place any restrictions on the Administrator as to where within the affected source the applicability determinations are made or where the controls are applied to achieve the desired emission reductions. (Indeed, controls can even be based on process changes, i.e., before a point of wastewater generation (see Act 112 (d)(2) (A)). Regarding air emissions from process wastewater, EPA's position on this issue has been presented in several places including the proposal BID (A-92-40 , II-A-35) and the March 8, 1996 draft Chemical Pulping Emission Factor Development Document (draft emission factor document) (A-92-40, IV-A-6). Additionally, the methodology of estimating air emissions associated with volatilization of compounds from process wastewater has been well documented in models such as EPA's WATER8. In general, EPA believes that pollutants volatize from wastewater upon contact with the atmosphere. This is consistent with standard laws of physics. Therefore, wastewater streams need to be controlled at the point of generation (i.e. , at the first air-water interface) if HAP emissions from wastewater are to be adequately controlled. Additionally, EPA has found that the best controlled mill s reduce the pollutant loading in the process wastewater streams prior to being recycled to process equipment or sent to subsequent

treatment. 4.2 DEFINITION OF SOURCE 4.2.1 Plant-wide Definition of Source

Comment: Several commenters (20,027, 20,049A3, 20,054A2, 20,056, 20,057A2, 20,059, 20,086, 20,089, 20,102, 20,103, IV-D2-15) provided input on the definition of source.

4-12Several commenters (20,027, 203-210, 20,054A2, 20,056, 20,057A2, 20,086, 20,089, 20,103, 20,146, IV-D2-14, IV-D2-3) supported a broad definition , stating that EPA should adopt a plant-wide definition of source to allow for integrated compliance with the proposed rule and to best comply with Act section 112(g) provisions. Additionally, another commenter (IV-D2-15) agreed with the broad single source definition which includes the pulping processes , the bleaching processes, the pulping and bleaching wastewater streams, paper machines, and causticizing equipment. This definition, according to the

commente r (IV-D2-15), reflects the physical realities of pulp and paper mills which consist entirely of technically and economically interdependent activities. One commenter (20,056) suggested a narrow definition would cause too many sources to become subject to the rule for minor modifications, which would cause continual tinkering with the emission control systems. Three commenters (20,049A3, 20,059, 20,102) indicated that the definition of source used by EPA was lax and would enable facilities to undertake major modernization projects without having to comply with the proposed standards. One commenter (20,059) stated that a broad source definition would delay by two years the date that new and reconstructed sources would have to comply with new source MACT. One commenter (20,092) supported the proposed narrow source definition. The commenter (20,092) stated that the final rule should clarify that the narrow source definition applies to new and modified area sources. Additionally , one commenter (20,102) suggested that the proposed definition be modified such that the

4-13source is defined as each of the process lines: pulping processes, bleaching processes , and wastewater processes. Response: The definition of affected source is used to distinguish: (1) the collection of equipment or groups of equipment that is subject to the emission limitations in the rule; (2) equipment that is subject to the new source MACT requirements ; and (3) equipment considered in determining
reconstructed sources. At proposal , EPA defined a single broad source for both existing and new source MACT. That single source included the pulping processes , the bleaching processes, and the pulping and bleaching process wastewater streams at a pulp and paper mill. The EPA also considered and solicited comments on the concept of multiple smaller sources that would be subject to the existing and new source MACT requirements. In defining the source at proposal, EPA considered the impact of the definition on mills making changes to existing facilities. In general , the narrower the definition of source, the more likely it is that changes to existing facilities would be deeme d "new sources" under the Act. With limited exceptions, these new sources must be in compliance with new source standards on the date of startup (or date the standards are promulgated, whichever is later). However, the Act and the CWA differ regarding applicability requirements and compliance deadlines for

new sources. As such , EPA was concerned that a pulp and paper mill planning to construct or reconstruct a source of HAP's between proposal and promulgation of these integrated regulations would find it necessary to plan for compliance with the rule

(required on the date of promulgation) without knowing the

4-14requirements of the effluent guidelines for the industry. This

situation appeared to be inconsistent with one objective of the integrated rulemaking: allowing facilities to do integrated compliance planning. The EPA thus determined that the best solution to these concerns was to define a single broad source at proposal in order to reduce the applicability of new source MACT. In the March 8, 1996 supplemental notice, EPA indicated a continuing inclination for a broad, single source definition. The EPA also discussed broadening the source definition further to include paper making systems and causticizing equipment and solicited comments on these additions. The EPA's reason for considering the addition of these two equipment systems was to facilitate implementation of the clean condensate alternative for kraft mills. Commenters on the December 17, 1993 proposal and on the March 8, 1996 supplemental notice largely agreed with the broad, single source definition. In considering how best to define the source, EPA did not want to define it so narrowly that changes to or additions of individual pieces of equipment would be subject to new source MACT and be required to be in compliance with new source MACT at startup. In fact, EPA was concerned that to do so could discourage mills from implementing pollution prevention changes as soon as practicable after promulgation of the proposed rule. Such changes might include replacing an existing rotary vacuum washer system with a low-flow washer system or installing an oxygen delignification system, both of which if subject to existing source requirements, would get the 8-year compliance time (see chapter 16). Once mills are complying with the existing source MACT requirements, it also did not seem

4-15reasonable that they should have to tear out and rebuild that vent collection system to accommodate small equipment changes in the future unless those changes occurred along with other substantial changes that would justify rebuilding the vent collection system. However, EPA also agrees with the commenter that at some point, changes to an existing mill are substantial enough that new source MACT should apply. For the final regulation , EPA is defining the affected source to which existing MACT requirements apply to include the total of all HAP emission points in the pulping and bleaching systems (including pulping condensates). In considering how mills might engineer their vent collection systems and control devices, EPA has concluded that the following construction actions occurring after proposal are substantial enough that new source MACT requirements will apply:

. A pulping or bleaching system at an existing mill is constructed or reconstructed; or

. A new pulping line or bleaching line is added to an existing mill. The proposal date for mills that chemically pulp wood is Decembe r 17, 1993. The proposal date for mills that mechanically pulp wood, pulp secondary fibers , or pulp non-wood materials is March 8, 1996. In selecting these actions, EPA determined that the costs of complying at startup are reasonable and will not discourage mills from implementing pollution prevention options to comply with the proposed rule. The final rule resolves the concerns of possible circumvention of new source MACT applicability by specifying the

4-16control requirements for (1) greenfield sites, (2) the addition of new equipment at existing sources , and (3) changes to existing equipment that could trigger reconstruction. By designating the exact equipment to be controlled at new and existing sources, the rule reduces confusion and misinterpretation over what actions trigger new source requirements. This approach preserves the advantages of the broadest source definition for compliance by existing sources while ensuring that new and reconstructed equipment are regulated as new sources consistent with section 112(a) and 112(d) of the Act. For example, under the final rule a weak black liquor storage tank is not regulated at an existing source. Nor would replacement of an existing tank be regulated. But a new tank would be regulated at a greenfield site or at an existing site if the new tank was installed contemporaneously with the construction or reconstruction of a new pulping system or an additional pulping line. The final regulation also provides for an alternative definition of source to facilitate implementation of the clean condensate alternative. For mills using the alternative to comply with the kraft pulping standards, the final regulation defines a single broad source that includes the total of all pulping, bleaching, causticizing , and paper making systems. These additions were made to the definition of affected source to allow for the application of advanced technologies to paper making and causticizing systems that typically receive recycled or reused condensates. This broader definition allows increased compliance flexibility while ensuring an equivalent level of HAP control on a mill-wide basis.

4-174.2.2 Definition Should Be Limited Within Each Subcategory

Comment: One commenter (IV-D2-14) cautioned that the definition of source should be limited within each subcategory. For example , a major change to a kraft mill should not draw a colocated thermomechanical pulping mill into the new source MACT standards. The commenter (IV-D2-14) suggested redefining source by using the major subcategory rather than the artificial divisions created within MACT I, MACT II, and MACT III. Response: The proposed rule defined the affected source as all pulping, bleaching , and wastewater components at a mill, in combination. The final rule has been restructured to define the affected source within each of six subcategories. The subcategories are kraft, soda, sulfite, semi-chemical, mechanical (wood) , and secondary or non-wood fiber pulping. The MACT new source provisions would be applied within each of these subcategories independently. For example , an affected source would be all the emission points in the pulping and bleaching systems of a kraft pulping system. If a sulfite-based pulping system was co-located at the same mill, then a second affected source would be all the pulping and bleaching emission points within the sulfite process. Under these definitions, no construction activities at the kraft system would affect the applicability of new or reconstructed source provisions to the sulfite system (and vice versa). The proposed MACT II rule covers the chemical recovery section of a pulping mill and would always be co-located with a
MACT I or MACT III source. The MACT II affected source covers different equipment than the pulping and bleaching system standards under MACT I and III. The affected source definitions

4-18do not overlap , and new source provisions of both rules, therefore, apply independently. For example , no construction activities on a kraft pulping or bleaching system would affect the applicability of new or reconstructed source provisions within the chemical recovery section of a kraft pulp mill (and vice versa). 4.2.3 Woodpiles, Power Systems, and (Methanol) Recovery
Comment: One commenter (IV-D2-3) suggested including the wood handling, power , and recovery components in the definition of source to ensure they are not included in 112(g). Another commenter (IV-D2-16) agreed with EPA's decision to exclude woodpiles from the definition of source because woodpiles are not significant HAP emission sources, emission controls are not currently practiced , and collection schemes would be totally cost prohibitive. Response: The EPA contends that it is unnecessary to include combustion devices in the source definition for this NESHAP because they are covered under a separate standard. The EPA agrees with the commenters that certain emission points which are excluded from the definition of affected source in today's rule , or are subject to a determination that MACT for these operations is no control , should not be required to undergo Act section 112(g) review. The sources that have been so identified are wood yard operations (including wood piles), tall oil recovery systems , pulping systems at mechanical, secondary fiber, and non-wood fiber pulping mills, and paper making systems. With regard to wood yard operations, tall oil recovery systems, and pulping systems at mechanical, secondary fiber, and non-wood fiber pulping mills , EPA has determined that these

4-19sources do not emit significant quantities of HAP's and EPA is not aware of any reasonable technologies for controlling HAP's from these sources. For paper making systems, EPA has not identified any reasonable control technology, other than the clean condensate alternative , that can reduce HAP emissions attributable to HAP's present in the pulp arriving from the pulping and bleaching systems. Additionally , EPA has determined that the use of paper making systems additives and solvents do not result in significant emissions of HAP's (A-95-31, IV-B-5). Therefore, based on the applicability requirements of section 112(g) [40 CFR 63 part B, 63.40(b)], wood yard operations ; tall oil recovery systems; pulping systems at mechanical , secondary fiber , and non-wood fiber mills; and paper making systems would not be required to undergo section 112(g) review. Any emission points that are specifically excluded from control in a section 112(d) standard would not be required to undergo section 112(g) or 112(j)(5) case-by-case MACT determinations. To qualify for this exclusion does not require that emission points be included in the affected source definition. It is sufficient that they are specifically addressed in the preamble or public record supporting the rule.
4.3 MACT 4.3.1 MACT Floor Level of Control Technologies
4.3.1.1 General Comments. Inadequate data used to determine the MACT floor level of

contro l technologies.
Comment: Two commenters (20,018A1, 20,122) disagreed about the information used to determine the MACT floor level of control technologies and the stringency of the resulting MACT floor. One

4-20commente r (20,018Al) indicated that incomplete industry and technology data and an abbreviated evaluation process for existing technologies resulted in the selection of MACT floor technologies that are more stringent than those currently used at any single pulp and paper facility. The commenter (20,018Al) indicated that some existing mills using proposed MACT technology on certain vents in the mill would be unable to meet the standards for all emission points included in the proposed rule; the control technologies that EPA selected do not perform at the levels which EPA has set at the mills where they are currently installed. The commenter (20,018Al) suggested that EPA reevaluate the proposed rule based on new industry data to better characterize control technology capabilities. Response: At proposal , EPA delineated vent streams and pulping wastewater streams controlled at the floor level of control from those not controlled at the floor level of control with numerical applicability cutoffs. The EPA used data available at proposal , along with engineering evaluation calculations to determine the performance capabilities of the control equipment on which the floor level of control was based. The EPA solicited comments and additional data on applicability determinations and on control technologies and performance. Since proposal , additional tests and studies were conducted by the pulp and paper industry to provide these data. The industry data received since proposal (A-92-40, IV-Dl-29, IV-Dl-29a, IV-Dl-31, IV-Dl-33, IV-Dl-34, IV-Dl-35, IV-Dl-38, IV-Dl-39, and IV-Dl-41) was considered by EPA and the Agency reevaluated the MACT floor by subcategories. As a result of this data consideration , EPA has replaced the numerical cutoffs from

4-21proposal with specifically defined equipment systems and associated named vents and pulping condensates. The EPA believes these named streams more accurately identify the vents and condensates being controlled at the best controlled sources. The EPA has also used this additional data to evaluate the performance capabilities of the controls on which the floor level of control is based. A detailed discussion of many changes related to determining applicability of the MACT standard and control technology requirements are presented in the March 8, 1996 supplemental notice. Additional changes are discussed in this document. (Commenters on the March 8, 1996 supplemental notice supported EPA's decision to subcategorize, which resulted in different MACT floor determinations.) In instances where the commenters disagreed with the notice, in particular, for new subcategories or provided additional data, EPA re-evaluated the MACT floor level of control if new data were received. The EPA maintains that the MACT floor level of control determination is based on the best data available. Cost-effectiveness is an improper criteria.

Comment: On e commenter (20,059) stated that EPA used costeffectiveness as the primary criteria for selecting control technology options , which they contended was improper. Response: Cost-effectiveness was not the primary criteria used to develop the MACT level of control. In developing the MACT standard , EPA first determined the floor level of control as defined in section 112(d) of the Act. Costs were not considered in developing the MACT floor level of control. For knotter and screen systems , limited data were available to characterize emissions. Cost-effectiveness was used as a means of supporting

4-22the emission limits developed from the emissions information. Options more stringent than the floor level of control were then identified. In evaluating the options more stringent than the floor level of control , EPA considered a range of factors including cost , emission reduction, energy impacts, and other environmental impacts. Cost-effectiveness was only one of the factors considered. This is precisely the type of evaluation required by section 112(d)(2) and (3). HAP-specific Effectiveness of Control Technology.

Comment: One commenter (20,059) stated that the prescribed control technologies in the proposed regulations are not effective for controlling all HAP's emitted from pulp and paper

processes. The commenter (20,059) also suggested that the implications of control options on individual HAP's was not evaluated by EPA. As an example , the commenter (20,059) reported that bleach plant scrubbing works well for methanol but does not provide control for other pollutants, such as chloroform, formaldehyde , and carbon tetrachloride. Response: The EPA recognizes that control devices may not reduce emissions of every compound equally. However, EPA asserts that the MACT standards for pulping vents and pulping wastewater streams (combustion and steam stripping followed by combustion, respectively) and bleaching vents (Cl O 2 substitution, elimination of hypochlorite use , and use of a caustic scrubber) represent the maximum achievable control for the mixture of HAP's at pulp and paper mills. The EPA evaluated other control technologies (such as incineration of bleaching vent streams) and determined that although some of the technologies could obtain better control of some pollutants they would get worse control of others. The EPA

4-23also determined that it was not cost feasible to require these other technologies in place of or in addition to the floor levels of control (e.g. , incineration of bleaching vents could achieve greater reduction of non-chlorinated HAP emissions, but applying a second technology in series with other controls would be cost-prohibitive). Detailed discussions of this issue are presented in section X.E. of the proposal, in the March 8, 1996 supplemental notice , and in chapter 20 of this document. The EPA made some changes in the promulgated rule for bleaching system control requirements. These changes were discussed in the March 8, 1996 supplemental notice and in the preamble to the final rule. General comment on new vs. existing floor level of control technology.
Comment: One commenter (20,027) stated that data do not support any distinction between the floor level of control technologies for new and existing sources. On the other hand, one commenter (20,059) argued that it was not credible for EPA to establish standards for new sources that were virtually identical to existing source standards. New source MACT should reflect the emissions limitation achieved by the best-performing similar

source. Response: A discussion of the analysis used to determine new source MACT is contained in section F of the December 1993 proposal preamble. As presented in the preamble, EPA considered whether there were controls applicable to new sources beyond the floor level of control MACT standard but concluded at proposal that more stringent controls were not reasonable. The Act does ificantly more stringen t not require new MACT standards to be sign

4-24than existing standards ; the two standards can be virtually equal if the best controlled source or similar source is virtually identical to the average of the best-controlled 12 percent of existing sources. Since proposal , EPA has based MACT floor decisions on specific named vents and wastewater streams controlled at each pulping subcategory. A discussion of changes in the existing and new source floor level of control determination since proposal is presented in the March 8 , 1996 supplemental notice. Additional changes are discussed in section 4.3.1.2 of this document. In the final rule , new source MACT differs from existing

source MACT. New sources are required to control additional vents including: knotter and screening systems with mass emission rates less than 0.05 kilograms of HAP per megagram of ODP produced and 0.10 kilograms HAP per megagram ODP produced, respectively (or less than 0.15 kilograms HAP per megagram ODP produced combined) , decker systems using process water other than fresh water or whitewater from paper machines or water with HAP concentrations less than 400 ppmw , and weak black liquor storage tanks at kraft mills; weak liquor tanks, strong liquor tanks, and acid condensate tanks at sulfite mills ; and pulp washing systems at soda and semi-chemical mills. 4.3.1.2 Pulping Area. MACT floor level of control needs to be determined by subcategories.

Comment: On e commenter (20,027) agreed with the EPA's proposed floor level of 98 percent HAP control for pulping emissions from kraft mills. Several commenters (20,027, 20,071, 20,072, 20,073) disagreed with the floor level of control

4-25technologies established for mills other than kraft. Two commenters (20,027 , 20,073) argued that the Act requires EPA to consider different technologies inherent in each process when determining the MACT floor level of control. The commenters

(20,027, 20,073 ) noted that failure to subcategorize mills by pulping type and failure to recognize the different control technologies and efficiencies for different pulping types caused EPA to improperly establish the MACT floor level of control for each pulping type. Response: Information available at proposal did not indicate a need to subcategorize the pulp and paper industry for the purpose of setting MACT standards. As a result of new operation, steam characterization , and control technology data received after proposal (A-92-40, IV-Dl-29, IV-Dl-29a, IV-Dl-31, IV-Dl-33, IV-Dl-34, IV-Dl-35, IV-Dl-38, IV-Dl-39, and IV-Dl-41), EPA established subcategories for mills according to pulping process (kraft, sulfite, semi- chemical, and soda). The data indicated that sufficient differences exist between kraft and sulfite, soda , and semi-chemical processes to warrant subcategorization. Accordingly , EPA revised the MACT floor level of control and MACT determinations for each subcategory. A discussion of development of pulping subcategories and respective floor level of control determinations is presented in the March 8, 1996 supplemental notice and received essentially unanimous support by commenters. Kraf t pulping MACT floor control technology. Knotter and Screening Systems.
Comment: Several commenters (IV-D2-8, IV-D2-7, IV-D2-15) requested that knotter and screening vents preceding brownstock

4-26washing should not be controlled by the rule. One commenter (IV-D2-15) explained that based on an erroneous interpretation of the 1992 MACT survey data , EPA has incorrectly concluded that knotter and screening systems are controlled by 7 percent of the systems and are therefore part of the floor level of control. The commenter (IV-D2-15) stated that following proposal NCASI contacted those mills which had indicated that: (1) their knotters were not vented or (2) vent gases from the knotters were collected and incinerated. The commenter (IV-D2-15) asserted that only 4 percent controlled knotter system vents. There were

n o "not vented" systems. Therefore, the commenter (IV-D2-15) stated that the pre-washer knotting and screening systems are not controlled at the floor level. Response: The EPA has reviewed available data on knotter and screen systems and has concluded that these systems are controlled sufficiently to establish a MACT floor level of control, and also that control more stringent than the floor level of control is not warranted. Data used to reach this conclusion include survey responses from the 1992 voluntary

survey, follow-up telephone surveys conducted by the NCASI, and emissions data from the NCASI 16-mills study. Although the data indicates that many of these systems are currently controlled to some degree, the survey responses were not detailed enough in their equipment system descriptions and the test data were too limited for the Agency to use these two sources of information alone to develop the MACT control requirements. Because equipment designs, nomenclature , and control configurations vary across the industry , the Agency decided that a HAP emissions
1s to determine which system s 1 imit would be the best way for mil

4-27would require control. The EPA lacks sufficient data, however, to pinpoint any single value that represents the MACT floor level of control. Rather, based on the survey and test data, there are a range of values from which EPA could choose. The EPA further considered the costs of control in choosing from this zone of reasonable values. Of the 171 knotter systems reported in the 1992 voluntary

survey, 12 knotter systems at 5 mills were reported as controlled

an d ducted into the noncondensible gas (NCG) collection system and another 49 knotter systems at 23 mills were reported as having no vents. NCASI followed up by telephone surveys with these 28 mills (A-92-40, IV-Dl-112, IV-Dl-114). The follow-up surveys indicated a moderate amount of misreporting at these 28 mills. NCASI did not resurvey all 171 knotter systems. Therefore , the following knotter system floor determination assumes that the mills not resurveyed that originally reported no knotter system controls did not control any vents. From the 28 mills resurveyed, it was determined that six knotter systems or 3.6 percent (6/171) route all vents into the NCG collection system ; another two knotter systems or 1.2 percent (2/171) route all knotter hood vents into the NCG collection system ; another eight knotter systems or 4.7 percent

(8/171) use only pressure knotters; and another two knotter systems or 1.2 percent (2/171) route all vents to the smelt dissolving tank scrubber. Industry collected data at seven pressure/open (also referred to as pressure/vibrating) knotter systems and found the methanol emissions to range from 0.005-0.07 kilograms per megagram of ODP produced, and collected data at one pressure knotter system and found the methanol

4-28emissions to be 0.0034 kilograms per megagram ODP produced. Emissions data are summarized in the Chemical Pulping Emission Factor Document (A-92-40, IV-A-8). Because the pressure knotter system emissions were lower than the emissions at the pressure/open systems , pressure systems can be considered a type of controlled system. Therefore, 18 or 10.5 percent (18/171) of the knotter systems have some level of emissions control. The Agency believes this estimate of number of knotter systems controlled may be somewhat low because it is uncertain how many of the mills not resurveyed may have had the lower emitting pressure systems. The 1992 voluntary MACT survey responses indicated that 96 screening systems out of the 199 reported are not vented. NCASI resurveyed by telephone 41 of these 96 mills. Assuming that the 55 mills not resurveyed look similar to the 41, the follow-up survey determined that 7 percent (6/41 x 96/199) route their vents to the NCG collection system and 41 percent (35/41 x 96/199) have closed screens that vent through auxiliary tanks. Therefore, 48 percent of the screening systems have some level of control. Industry collected data at one closed screen system and one open screen system. The closed screen system tested had methanol emissions of 0.004 kilograms per megagram of ODP produced. The open screen system tested had methanol emissions of 0.22 kilograms per megagram of ODP produced. The Agency considered how best to characterize the average emissions limitation achieved by the best controlled 12 percent of the knotter systems and screen systems given the wide variety of control scenarios present in the industry. Either collecting

4-29and controlling vents on an open system or using closed equipment

result in lower air emissions. The Agency decided to select the emissions limitation using the test data from the closed and open equipment systems. The Agency's decision is due in part to the fact that the effluent limitation guidelines and standards being promulgated will require that screening areas be closed for water discharge, which will require mills to move toward wider use of the lower air emitting pressure systems. Because there is only one test data point for the pressure knotter systems and that emissions value is similar to the low end of the range of data points for the pressure/open knotter systems, the Agency did not believe it would be appropriate to set the emission limit equal to the one pressure knotter system. Similarly, because there is only one test data point for closed

screens, the Agency did not believe it would be appropriate to use that single data point to set the emission limit for screening systems. The Agency could have selected any emission limit within the range of all available data for knotters (i.e., 0.0042 to 0.07 kilograms per megagram of ODP produced) and screens (i.e., 0.004 to 0.22 kilograms per megagram of ODP produced). However, recognizing the limited data available, the Agency also considered the cost-effectiveness of controlling these systems to aid in setting the emission limits within the range of reasonable values (A-92-40, IV-B-21). Based on consideration of all available data, the final rule requires that existing kraft sources are required to control all knotter systems with total mass emission rates greater than or equal to 0.05 kilograms of HAP per megagram ODP produced. Existing kraft sources are required to control all screening

4-30systems with total mass emission rates greater than or equal to 0.10 kilograms of HAP per megagram ODP produced. Since it is often difficult to distinguish between the knotter system and screening system at mills , a mill may also choose to meet a total emissions limit of 0.15 kilograms per megagram ODP produced across the knotting and screening combined system. New sources are required to control all knotter and screen systems, regardless of emissions level. Brownstock Washers.
Comment: Several commenters (20,027, 20,054A2, 20,066A3, 20,070Al) indicated that EPA's determination of floor level of control technology for brownstock washer control was erroneous because it failed to recognize the distinctions among types of washers. One commenter (20,066A3) indicated that EPA included the following equipment in one group: red stock washers at sulfite mills , which are enclosed but routed to a scrubber; low emitting washers (such as diffusion washers that cannot be used with batch digesters) ; and drum washers which require a major expense to enclose because they emit high-volume low-concentration streams.

One commenter (20,054A2) stated that EPA failed to recognize the significant differences between vacuum, pressure, and diffusion washers when establishing the floor level of control for washers. One commenter (20,070Al) suggested that a distinction should be made in the regulation between newer washer systems and the older vacuum drum washers. One commenter (20,027) also noted that diffusion washers are excluded from the kraft NSPS due to low emission rates. The commenter (20,027) added that new washers are expected to be non-rotary vacuum

4-31design. One commenter (IV-D2-7) noted that because of the low level of emissions from improved washer systems and because of the lack of existing controls on such units (2 of 21 operational chemi-washers), the MACT floor for improved washers (pressure washers, diffusion washers , and horizontal belt washers) should be no control. Response: The EPA recognizes the difference in emissions and flow characteristics among the different types of pulp washers. However, information collected in the 1992 voluntary MACT survey showed that greater than 25 percent of low flow washer systems (diffusion, pressure , chemi-) are controlled

(A-92-40, IV-B-8). Based on these data EPA determined that the control of pulp washers was part of the floor level of control for all types of washers at kraft and sulfite mills. As discussed in the March 8 , 1996 supplemental notice, EPA encouraged the use of low flow washer systems because of significant pollution prevention advantages and environmental benefits. The EPA has extended compliance with the kraft pulping standards for HVLC systems by 5 years in order to promote the use of low flow washer systems , as part of the strategy to encourage water pollution controls more stringent than BAT, and to provide sufficient time to design and construct these systems. Deckers.
Comment: One commenter (IV-D2-15) stated that control of the decker was beyond the floor level of control. The commenter

(IV-D2-15) said that all the deckers which were reported in the 1992 voluntary MACT survey as not being vented actually had vents somewhere in the system, either for the hood, for the filtrate tank, or for both. Vent gases from nine of the decker systems

4-32were collected and incinerated. Nin e deckers represent less than 5 percent of the reported systems. Therefore, the commenter (IV-D2-15) asserted that decker vents are not controlled at the floor level. The commenter (IV-D2-15) stated that industry will collect more information about the existing decker systems for the purpose of evaluating the cost-effectiveness of collecting and incinerating these vent gases. However, the commenter (IV-D2-15) speculated that it is not cost-effective to control emissions from the decker system. Response: The EPA evaluated the information submitted by the commenter and concluded that there were 170 decker systems in mills responding to EPA's industry survey questionnaires. All the decker systems are associated with bleached mills. Of the 170 decker systems , 14 are controlled (8 percent) (A-92-40, IV-B-22). Therefore, control of decker systems is in the MACT floor. The majority of decker systems controlled at the floor level of control (10 systems) are associated with oxygen delignification systems or are being used as an additional stage of pulp washing. The Agency believes that these types of decker systems are operated similarly to and have similar emissions as pulp washers. Decker systems used in this manner receive contaminated condensates or filtrates that may be recycled from other processes , such as the oxygen delignification system or combined condensate tanks. The process water may have a HAP concentration that would release significant amounts of HAP to the air from the air-water interface. The Agency characterized the emissions from this source to identify the types of decker

4-33systems with high emissions. Information supplied in NCASI Technical Bulletin No

. 678 provided a relationship between air emissions and methanol concentrations in process water used in rotary vacuum drums. The EPA evaluated this relationship and determined that decker controls and higher HAP emission rates were associated with deckers that used process water with HAP concentrations greater than or equal to 400 ppmw, or that did not use fresh water or "whitewater" from paper making systems

(A-92-40, IV-B-22). Therefore, the Agency has determined that it is appropriate to make a distinction among types of decker systems at existing sources for the purpose of setting the MACT standard. Decker systems at existing sources using fresh water or "whitewater" from paper making systems , or using process water with HAP concentrations less than 400 ppmw, are not required to be controlled. Decker systems at new sources are required to be controlled regardless of the HAP concentration in the process water introduced into the decker. Oxygen Delignification Systems.

Comment: Two commenters (20,027 , 20,054A2) asserted that EPA improperly determined that the floor level of control includes control of oxygen delignification systems. One commenter (20,027) stated that less than 6 percent of these systems are controlled even if mills with oxygen delignification systems are considered their own subcategory. Additionally, the commenter (20,027) contended that oxygen delignification systems should be considered part of the bleach plant since oxygen acts as a bleaching agent similar to chlorine or ClO 2.

4-34One commenter (IV-D2-5) asserted that requiring incineration of vent gases from oxygen delignification units is punitive to mills that have expended the extra effort to install these environmentally beneficial systems. The commenter (IV-D2-5) claimed that molecular oxygen is very effective at oxidizing pollutants such as TRS and organics such as methanol. The commenter (IV-D2-5) included data from their mill showing a low methanol emissions rate from their oxygen delignification system. Response: The EPA disagrees with the commenters and has determined that control of oxygen delignification systems is part of the floor level of control (A-92-40, IV-B-16) based on the data collected in the 1992 voluntary MACT survey. An evaluation of the number of oxygen delignification systems constructed after proposal and their controls (A-92-40, IV-Dl-29, IV-B-16) indicates that greater than 6 percent of the oxygen delignification systems are controlled. Therefore, the MACT floor level of control is control of oxygen delignification systems. With regard to the commenter's contention that oxygen delignification systems should be considered part of the bleach plant, information submitted to the Agency following proposal

(A-92-40, IV-Dl-97, IV-Dl-104) indicated that several commenters from the industry have revised their position and recommend that oxygen delignification systems be considered part of the pulping

process. The basis for this recommendation is that process waters from oxygen delignification systems are typically recycled or reused in other pieces of pulping equipment. Conversely, process waters originating in the bleach plant cannot be used in the pulping process without extensive treatment due to

4-35interferences in the chemical recovery process caused by the presence of chlorine and chlorinated compounds. Regarding the issue raised by the commenter that it is punitive to control air emissions from the environmentally beneficial oxygen delignification systems, EPA recognizes that some mills have already committed to using oxygen delignification systems. But, based on industry emissions data submitted after proposal (A-92-40, IV-Dl-29 and IV-B-16) oxygen delignification systems appear to be a significant source of HAP emissions, and greater than 6 percent of the existing oxygen delignification systems are controlled. A floor level of control is mandated by the Act. The EPA does not think that MACT compliance (which will apply to all sources with oxygen delignification) will discourage introduction of the technology. In fact, to encourage the pulp and paper industry to consider the benefits of oxygen delignification, as discussed in the March 8, 1996 supplemental notice, the final rule grants kraft mills a compliance extension of 5 years. There are also significant incentives provided in the effluent guidelines portion of the final rule to encourage use of oxygen delignification (or superior) technology. Weak Black Liquor Storage.

Comment: Several commenters (IV-D2-8, IV-D2-7, IV-D2-15) maintained that the MACT floor level of control for weak black liquor storage tanks is no control , noting that the cost of controlling these tanks far outweighs the environmental benefits and that add-on controls would threaten the structural integrity of these units. One commenter (IV-D2-15) explained that the NCASI survey provided ambiguous responses, which misrepresented the extent of control at existing weak black liquor storage tanks

4-36and that they are not part of the floor level of control. In order to resolve this ambiguity, NCASI contacted all the mills that had reported that vent gases from their weak liquor storage tanks were collected and incinerated. NCASI also sent a single page survey to 121 kraft mills in the industry and received 117 responses. From this information , the commenter (IV-D2-15) asserted that only 5 percent of weak black liquor storage tanks were controlled. Therefore, the commenter (IV-D2-15) asserted that weak black liquor storage tanks are not controlled at the floor level. The commenter (IV-D2-15) stated that control of the weak black liquor storage tanks beyond the floor level of control would not be cost effective , and the emissions from these tanks based o n NCASI's latest tests indicated that the quantity of emission is negligible. One commenter (20,027) asserted that

EPA's assumption that tanks could withstand a vacuum for routing vents to a control device was inappropriate for older tanks because the vacuum may cause the tanks to collapse. One commenter (IV-D2-4) suggested that it is appropriate that any weak black liquor storage tank strong enough to withstand sufficient vacuum (based on engineering analysis or the age of the tank) should be subject to control. One commenter (IV-D2-10) agreed with EPA's position (as outlined in the March 8, 1996 supplemental notice) that the age and, therefore, the structural integrity of the weak black liquor storage tanks should be considered as one parameter for determining control applicability of tanks. Several commenters (IV-D2-14, IV-D2-8), however, disagreed that the age of a tank is a good parameter for determining the control applicability for tanks.

4-37Response: The EPA evaluated the supplemental information submitted by NCASI (A-92-40 , IV-Dl-101) and concurs that control of weak black liquor storage tanks is not in the existing source floor level of control. Information submitted by the commenters indicated that of the 597 weak liquor storage tanks in the survey only 28 (4.7 percent) actually had emissions routed to a control device (A-92-40, IV-D-106). Some respondents had previously included other types of controlled tanks, such as washer filtrate tanks, in their totals because EPA's original survey did not provide a definition of weak liquor storage tanks. The Agency, therefore, has concluded that the MACT floor level of control for weak liquor storage tanks at existing sources is no control. While some tanks are controlled, available information does not support the supposition that age is a good parameter for distinguishing structural integrity. No other parameter could be identified for distinguishing between controlled and uncontrolled tanks. Therefore, no basis for controlling existing sources was determined. In addition , the Agency evaluated the cost of going beyond the floor level of control to control weak liquor tanks. The results of EPA's analysis indicated that a significant cost would be incurred for a limited emission reduction. This analysis is presented in chapter 20 of the background information document for the promulgated rule. The EPA concurs with the

comments that older tanks could not handle the vacuum caused by the closed-vent collection system without collapsing. Additionally, sweep-air systems that could be used to alleviate the vacuum problem are cost prohibitive for the amount of emissions reduction achieved by controlling the tanks.

4-38Therefore , the Agency agrees with the commenters that control beyond the floor is not justified. Although weak black liquor storage tanks are not controlled at the floor , the available data does indicate that some tanks are being controlled at some mills. Therefore, EPA has concluded that these tanks should be controlled at new sources since new tanks could be designed to withstand the slight vacuum associated with the collection system at a reasonable cost. Comments on sulfite pulping MACT floor level of control technology.
Comment: One commenter (20,027) stated that EPA incorrectly concluded that control technologies common in mills with one pulping process would be applicable to other pulping processes. The commenter contended that incineration is the common control technology for total reduced sulfur compounds. However, 14 of the 15 sulfite mills do not practice any form of vent gas incineration. The commenter stated that scrubbing and SO 2 recovery should be considered as the floor level of control technology for pulping vents at sulfite mills. The commenter

(20,027) stated that the sulfite process generates sulfur dioxide emissions which are typically recovered using scrubbers, for reuse as cooking acid makeup. The commenter (20,027) reasoned that since any HAP generated in a sulfite digester may pass through multiple process devices , each one capable of altering the HAP emission rate , the final HAP emission rate is a function of all of the equipment that exists between the point of generation and the eventual emission point. The commenter

(20,027) contended that to ascribe a removal or control efficiency to the final scrubber would be to ignore the entire

4-39control process. The commenter (20,027) concluded that for this reason EPA should establish the pulping component standard for sulfite pulping at the exit of the control device. Another commenter (20,151) suggested that the proposed rule should address emission control and discharge requirements on ClO 2 generating equipment and other replacement types of bleaching, such as hydrogen peroxide and ozone. The commenter

(20,151) indicated that consideration should be given to appropriate controls and discharge requirements on strong waste ponds, cooling towers , and aeration ponds. Response: Since proposal , EPA has established a separate subcategory for the sulfite process and has re-evaluated the floor determination for the sulfite process. The EPA agrees with the commenter that the floor level technology is scrubbing and

SO 2 recovery. A discussion of the analysis for determining the level of the standard for the sulfite process is presented in the March 8, 1996 supplemental notice. In the March 8 notice, EPA provided a control efficiency requirement and an emission limit requirement. For calcium-based sulfite pulping processes, the emission limit presented was 0.65 lb methanol/ODTP and the percent reduction was 92 percent. For ammonium- and magnesium-based sulfite pulping processes, the emission limit was 1.10 lb methanol/ODTP , and the percent HAP reduction was 87 percent. The Agency developed applicability cutoffs based on methanol because only methanol emissions data were obtained for all of the equipment systems and wastewater streams considered for control at sulfite mills. The test data from sulfite mills also indicated that for the equipment systems tested for other HAP's, methanol comprised the majority of HAP emissions.

4-40Therefore, the Agency believes that the maximum control of HAP emissions will be achieved by controlling methanol as a surrogate. Since the supplemental notice was published, EPA has further evaluated the industry's data regarding process variability. The data indicates that methanol emissions from individual process vents varied significantly over time (A-92-40, IV-B-20). The industry data that were used to develop the initial emission limit s cited in the March 8 , 1996 supplemental notice were based on limited information that did not account for this process variability. One of the compliance options for sulfite mills is a numerical emissions limit. The EPA determined that the appropriate limit should incorporate the process variability inherent in normal operation. The EPA determined the amount of variability associated with a 99.9 percent confidence level in the data supplied by the industry. This amount of variability

(confidence interval), therefore , was applied to the average emissio n limit s from the best controlled mills t o develop the final emission limit. After the close of the March 8, 1996, Federal Register supplemental notice comment period, additional information was provided to the Agency that indicated that the sodium-based sulfite pulping process i s in use a t some mills (A-92-40, IV-E-86, IV-E-94). No emissions information was available for this process. However, the Agency determined that due to the similarities in processes between calcium- and sodiumbased sulfite pulping processes , the same limit developed for calcium-base d mill s would be applicable to sodium-based mills. For sodium- and calcium-based sulfite pulping processes, the final emission limi t is 0.44 kilograms of methanol per megagram

4-41of ODP produced. For ammonium- and magnesium-based sulfite pulping processes , the final emission limit is 1.1 kilogram of methanol per megagram of ODP produced. Because the variability is included into the emission limits, these emission limits and corresponding monitoring parameters are never to be exceeded values.
Comment: On e commenter (IV-E-91) indicated that a mill they are working for uses a sodium-based sulfite process and the March 8, 1997 Federal Register supplemental notice does not appear to address this specific process. Response: This comment was submitted to EPA after the close of the comment period for the March 8 notice and shortly before promulgation; however , EPA has reviewed and evaluated the commenter's assertions. Based on a review of the information contained in the 1996 Lockwood-Post's Directory (A-92-40, IV-J-87) and discussions with mill operators (A-92-40, IV-E-94), EPA has decided that the pulping process used at the mill meets the definition of sulfite pulping proposed in the December 17 , 1993 Federal Register notice (see 58 FR 66176). The March 8, 1996 supplemental MACT notice did not propose to amend the sulfite definition. Although EPA does not have data specific to the sodium-based sulfite pulping process , EPA believes it is reasonable to group this process with the calcium-based sulfite pulping process for purposes of the MACT standard. This decision was made since the calcium- and sodium-based pulping process have similar equipment such as an acid making system and, unlike the ammonium- and magnesium-based sulfite processes, neither the calcium- nor the sodium-based sulfite process utilizes recovery furnaces.

4-42Therefore , the final rule specifies that the calcium-based sulfite process methanol emission limits and percent reductions are applicable to the sodium-based sulfite pulping process. The EPA believes that this is the only mill currently using a high-yield sodium-based sulfite pulping process, based on a review of the Lockwood-Post information. However, the information available to EPA also indicates that this mill utilizes some degree of mechanical refining in the pulping process and has a single peroxide bleaching stage. Based on this information, the Agency has assigned this mill to the semichemical pulping subcategory for purposes of the effluent limitation guidelines and standards , but is not setting revised effluent limits at this time for this subcategory in this promulgation. The EPA believes that grouping this pulping process into separate subcategories within the MACT and effluent limitation guidelines and standards is consistent with the regulatory intent of the two EPA programs since the high-yield sodium-based sulfite pulping process has characteristics of both the sulfite and semichemical pulping processes (sulfite from an emissions standpoint and semi-chemical from a liquid discharge standpoint). Comments on semi-chemical pulping MACT floor control technology.
Comment: Two commenters to the proposal (20,027, 20,071) maintained that the MACT floor level of control for pulping vent control at stand-alone semi-chemical mills should be no control, because none of the existing stand-alone semi-chemical mills are controlled.

4-43Regarding the information contained in the March 8, 1996 supplemental notice , in which the Agency discussed separate MACT standards under consideration for semi-chemical mills, one commenter (IV-D2-15) agreed with EPA that the collection and control of LVHC vents is a cost-effective control option and represents the floor for existing stand-alone and co-located semi-chemical mills. The commenter (IV-D2-15) also agreed that new source MACT for semi-chemical mills should be the control of the LVHC system plus the control of emissions from the pulp washing system. The commenter (IV-D2-15) agreed that the MACT for semi-chemical wastewater is no control. Response: Information provided by industry in survey responses and after proposal (A-92-40, IV-Dl-41, IV-Dl-80, IV-Dl-86, IV-Dl-89, IV-Dl-90 , and IV-Dl-93) confirmed that the MACT floor level of control at semi-chemical mills is collecting and controlling LVHC vents. The Agency determined that it was not reasonable to control other emission points at existing semi-chemical mills (A-92-40, IV-B-12). New source MACT is based on the best controlled at sources. Data indicate that the best-controlled semi-chemical mills combust LVHC emissions and emissions from pulp washers. New sources, therefore, are required to control LVHC vents and emissions from the pulp washers. A detailed discussion of the level of the standards for semi-chemical processes is contained in the March 8, 1996 supplemental notice and in the docket (A-92-40, IV-B-12). Comments on soda pulpin g MACT floor level of control technology.
Comment: Regarding the December 1993 proposal, one commenter (20,072) argued that since EPA has historically

4-44regulated kraft mills differently than soda mills, the MACT floor level of control would be significantly different between kraft and soda mills. The commenter (20,072) stated that by combining the two existing soda mills with over 100 kraft mills, the difference in the actual MACT floor was lost. With regard to the information contained in the March 8, 1996 supplemental notice , in which the Agency discussed soda mill requirements , one commenter (IV-D2-15) agreed with EPA that both the existing and new source MACT for the soda mill subcategory is the collection and control of LVHC vents. The commenter agreed that the MACT for wastewater at soda mills is no control. Response: Data available to EPA indicate that soda mills do not currently control any of the equipment that is subject to the MACT requirements for kraft mills. Therefore the floor level of control is no control. However , EPA has determined that the emissions from soda mills are similar to kraft mills (with the exception of TRS compounds) and control of LVHC vents is technically feasible and can be achieved at a reasonable cost. The EPA also determined that controlling additional vents beyond the LVHC vents at existing soda mills could not be achieved at a reasonable cost. However, controlling the pulp washing system at new soda mills could be achieved at a reasonable cost. Therefore, the final rule requires existing soda mills to collect and control LVHC vent streams and new mills to control LVHC vents and pulp washing system. The commenters are referred to the March 8, 1996 supplemental notice and (A-92-40, IV-B-12) for a detailed discussion of EPA's determination of soda mill requirements.

4-45Closed-vent collection system.

Comment: Two commenters (20,027 , 20,054A2) indicated that EPA did not evaluate the operational requirements and performance of the average of the best-performing 12 percent of sources when developing the proposed closed-vent collection system requirements. One commenter (IV-D2-15) requested that EPA reevaluate the calculation of the floor level of control technology for enclosure of pulping component sources and associated gas conveyance systems. Another commenter (IV-D2-7) asserted that no total enclosures and closed-vent systems are currently in place in the industry , and that their addition would not be cost effective in any existing facility. Two commenters (IV-D2-7 , IV-D2-15) requested that EPA scale back the visual inspection and leak detection requirements for the gas conveyance systems since the proposed regime does not represent the floor. In addition , since most conveyance systems operate at negative pressure, there is no need for leak detection. One commenter (20,027) stated that the proposed visual inspections for closed-vent collection systems were unnecessary due to the design (limited use of flanges) and type of materials of construction (stainless steel) used in LVHC and HVLC collection systems. Another commenter (20,057A2) stated that there were no data to support the inclusion of no detectable leaks from pulping and bleaching process vent collection systems as part of the MACT floor. One commenter (20,027) asserted that the best-performing 12 percent of sources do not seal or lock bypass vents. Response: The EPA proposed requirements that the Agency deemed reasonable to ensure that the closed-vent collection

4-46systems are properly operated and that the affected vent

emissions are conveyed to the control devices. The EPA has evaluated the comments submitted after the December 1993 proposal and the March 1996 supplemental notice, and several revisions were made to the closed-vent collection system requirements. The requirement for demonstration of negative pressure has been revised to apply only to enclosures and hoods. The requirement for demonstration of no detectable leaks has been revised to apply only to positive pressure systems or portions of systems. The EPA concluded that the leak detection requirements are necessary to verify that enclosures are collecting all emissions from applicable emission points in these systems. The EPA agrees with the commenters that leak detection for negative pressure systems is not useful since any leaks in the collection system will draw air into these systems. The bypass line requirements were also revised. The proposed rule language requiring lock-and-key type seals was replaced with language specifying car-seals or seals that can easily be broken in case of emergencies, yet still indicate when the bypass valve position has changed. Additionally, the final rule specifies the use of log entries to record valve position. The EPA disagrees with the commenters that the visual inspections are not necessary. No changes were made to the proposed visual inspection requirements for closed-vent collection systems since the intention in the rule was to inspect for bypass valve position, clogged drains, broken fan belts, etc. These problems are not necessarily affected by the design or material of construction of the system. A related issue on downtime and back-up controls is discussed in section 4.3.4.

4-474.3.1.3 Bleaching. Suggested alternative MACT floors for bleaching.
Comment: Several commenters (20,018A1, 20,027, 20,036A1, 20,045, 20,051, 20,056, 20,057, 20,115A2, IV-Dl-4, IV-Dl-8, IV-Dl-15, IV-Dl-16) discussed the floor level of control for chlorine, chlorinated HAP's , and non-chlorinated HAP's. With regard to the December 1993 proposal, several commenters (20,027 , 20,056) agreed that scrubbing is the correct control technology for bleach plants but that EPA did not correctly establish control efficiencies or pollutants controlled. Several commenters (20,018A1, 20,027, 20,036A1, 20,045, 20,051 , 20,056) reasoned that because existing bleach plant scrubbers are not effective on any HAP except chlorine, the floor level of control for methanol and HAP's other than chlorine should be no control. One commenter (20,027) concluded that to go beyond the floor of no control , the cost-effectiveness should be evaluated. (Data provided: Table 10 p. MACT-190, Table 11 p.P* MACT-191, Table 12 p. MACT-194 , and Appendix MACT 22.) Two commenters (20,056 , 20,070Al) indicated that the control efficiency selected had not been shown to be achieved in practice by the best-performing 12 percent of mills. One commenter

(20,115A2) argued that reduction of chlorine and methanol by 99 percent using a scrubber , as specified in the proposed regulations , would not be possible in the pulp and paper industry or any other industry. One commenter (20,057) stated that EPA failed to consider methanol generation rates or scrubber removal efficiencies when they established the proposed MACT standards for bleach plant vents.

4-48Several commenters to the March 8 , 1996 supplemental notice (IV-D2-15, IV-D2-16, IV-D2-8) agreed with EPA's conclusion that the data provided by NCASI supports the control of chlorinated loor shou .ld b e HAP only in the bleaching component and the MACT f control of only chlorinated HAP's. Several commenters (20,018A1, 20,027, 20,080 , 20,149, IV-Dl-3, IV-Dl-4, IV-Dl-8, IV-Dl-10, IV-Dl-15, IV-Dl-16, IV-Dl-17, IV-Dl-18) discussed the MACT floor based on process changes and effluent guidelines BAT requirements. With regard to comments solicited on the MACT control technology basis for bleach plants in the December 1993 proposal,

one commenter (20,018Al) indicated that complete Cl02 substitution should be MACT for the bleaching component because the effluent guidelines required complete substitution of chlorine with Cl02 for kraft bleaching, and Cl02 bleaching has lower emissions of chlorine and C102. Two commenters (20,027, 20,059) supported emission limit s for chlorinated organic compounds set based on the reductions obtained by process changes. One commenter (20,071) suggested compliance for both chlorine and chloroform could be demonstrated by elimination of hypochlorite and complete Cl02 substitution. Several commenters

(20,049A2, 20,091, 20,102, 20,103, 20,127, 20,129) stated that chloroform emissions should be minimized by using process changes or through the use of advanced innovative technologies, such as biofiltration following gas scrubbing. One commenter (20,149) indicated that the proposed rules did not control chloroform emissions which they state posed a significant health risk. One commenter (20,118) suggested deferring the requirement to control chloroform emissions until the impact of 100 percent Cl02

4-49substitution and elimination of hypochlorite stages has been evaluated. Another commenter (20,027) reported that reliable data are not available regarding the effect of process changes on HAP emissions from bleach plant vents; consequently, it would not be appropriate to use a combination of process changes and gas scrubbing to set the MACT floor level of control for bleach plant

vents. Several commenters (20,091, 20,138, 20,141, 20,143, 20,156) indicated that the rules should be written as a guide for a complete phaseout of processes using chlorine or Cl02 compounds to bleach pulp. One commenter (20,091) indicated that if a complete phaseout is not possible, they prefer maximum Cl02 substitution to alternatives that do less to reduce the formation of organochlorines. Two commenters (20,027 , 20,115A2) stated that a chloroform emissions limitation is not needed for the bleach plant because process modifications will reduce chloroform. One commenter (20,031) suggested, however, that EPA rewrite the bleaching component standards to allow the continued use of hypochlorite as a bleaching agent on a site-specific basis to address other environmental concerns. Regarding the information presented in the March 8, 1996 supplemental notice , several commenters (IV-D2-15, IV-D2-17, IV-D2-16, IV-D2-8) agreed with EPA's intent to consider compliance with the effluent guidelines BAT option equivalent to MACT compliance for chloroform. One commenter (IV-D2-4) supported the EPA Office of Water's requirements to eliminate hypochlorite bleaching through Cl02 substitution for all paper grades where it is technically feasible.

4-50Several commenters (IV-D2-18, IV-D2-10, IV-D2-3, IV-D2-8) agreed with the MACT floor level of control as outlined in the March 8, 1996 supplemental notice. In response to EPA's solicitation of comments on whether an alternative equivalent numerical limit for chloroform is needed, the commenters asserted that compliance with the BAT water standards will virtually eliminate chloroform emissions and that a numerical limit is neither needed nor desired. One commenter (IV-D2-4) expressed concern over EPA's decision to move away from using methanol as a surrogate for organic HAP from bleaching processes and whether organic HAP's will be adequately controlled from the bleaching process. The commenter (IV-Dl-4) indicated that most of the organic HAP emissions that would remain after the elimination of hypochlorite originate from the use of dirty wash water and that organic HAP emissions could be reduced by limiting the organic HAP content of the wash water. The commenter urged EPA to clearly define how the chosen approach will control the organic HAP and TRS emissions from the bleaching process. Response: In the March 8, 1996 supplemental notice, the Agency revised the proposal for the bleaching system requirements based on information and comments received after proposal. The new data indicated that caustic scrubbing reduces emissions of chlorinated HAP compounds (except chloroform), but does not control non-chlorinated HAP emissions. The Agency determined that no other option was feasible to control non-chlorinated
HAP'S. Although chloroform emissions could not reasonably be reduced by use of one add-on air pollution control technology,

4-51chloroform emissions can be reduced using process modifications, such as Cl02 substitution. In the March 8 , 1996 supplemental notice, the Agency proposed to require chlorinated HAP emissions other than chloroform to be controlled by 99 percent using a caustic scrubber (with chlorine as a surrogate for chlorinated HAP). As an alternative to the percent reduction standard, the Agency also proposed an emission limit of 10 ppmv HAP at the caustic scrubber outlet (with chlorine as a surrogate for chlorinated HAP). The Agency also solicited comments on providing a mass emission limit alternative to the percent reduction and the outlet concentration
standards. Commenters on the March 8 , 1996 supplemental notice supported the changes to the scrubber requirements in the proposed rule. Several commenters also supported development of a mass emission limit alternative for the scrubber outlet. The Agency evaluated data supplied by the commenters and data in sampling tests. The results of the evaluation indicated that sufficient data exist to develop an appropriate mass emission limit (A-92-40, IV-B-29). Therefore, the final rule includes a mass emission limit alternative of 0.001 kg of total chlorinated HAP (not including chloroform) per Mg of ODP produced for bleaching system scrubbers. After proposal , the Agency also evaluated the effect of process modifications on chloroform emissions. The results of this analysis indicated that the technology basis for MACT control of chloroform was 100 percent Cl02 substitution and reduction of hypochlorite as a bleaching agent. These process modifications were determined to reduce chloroform emissions

4-52significantly. The technology basis for BAT under the effluent limitation guidelines and standards also require 100 percent Cl02 substitution and elimination of hypochlorite. Since BAT and MACT are essentially the same , EPA therefore proposed in the March 8 notice that chloroform emissions be controlled by complying with the BAT requirements

. No adverse comments were received to this proposal. In the March 8 , 1996 supplemental notice, the Agency solicited comments on whether an alternative numerical limit for chloroform (i.e. , besides complying with BAT) was needed. Some commenters contended that a numerical limit for chloroform would be unnecessary because the BAT requirements would achieve the requisite reductions. The Agency did not receive any indication of any benefit from a numerical limit for chloroform. Additionally the Agency did not have sufficient data and did not receive any further data after the March 8 notice to develop a numerical limit. Therefore, the final rule does not include a numerical limit for chloroform. Consequently , EPA has concluded that the existing and new source floor level of control for chlorinated HAP's is caustic scrubbing with 100 percent Cl02 substitution and elimination of hypochlorite use. Compliance with the effluent guidelines BAT option is at least as stringent as the MACT floor level of control. Therefore, the final rule requires mills to comply with the BAT requirements in the effluent limitation guidelines and standards, or eliminate the use of hypochlorite and chlorine. For non-chlorinated HAP's , the existing source and new source floor is no control since no emission reduction from the current

4-53baseline for non-chlorinated HAP's is being achieved with the bleach plant control technology. Because MACT for new sources is equivalent to MACT for existing sources , the new source MACT standards for bleaching systems require compliance with BAT/Pretreatment Standards for Existing Sources (PSES) requirements (or implementation of 100 percent substitution and elimination of hypochlorite). This requirement applies even if the mill or bleaching system also meets the definition of new source under the effluent guidelines limitations and standards , and thus is required to meet the more stringent new source effluent requirements of NSPS/Pretreatment Standards for New Sources (PSNS). Although the NSPS/PSNS may require installation of technologies that reduce effluent loading beyond what is achieved by 100 percent substitution and elimination of hypochlorite , EPA is not aware that these advanced technologies will provide air emission reductions beyond what the BAT/PSES requirements will achieve. The EPA evaluated the cost of going beyond the floor to control non-chlorinated HAP's (see proposal preamble) using a scrubber or a combustion device but determined that these options had a substantial cost and environmental impact for limited emission reduction. Therefore, EPA determined these options were not warranted.
Comment: Three commenters (20,049A2, 20,080, 20,127) argued that zero use of chlorine compounds should be the baseline standard for MACT. In support of this position, one commenter

(20,080) cited the fact that there is at least one place in the world where all grades of paper are produced using chlorine-free technology. One commenter (20,122) argued that EPA should have

4-54evaluated the top 12 percent of mills in other countries, not just the United States. The commenter (20,122) stated that totally chlorine free (TCF) technologies at paper-grade kraft mills in other countries were not reflected in the proposed rule. The commenter (20,122) contended that EPA should revise the proposed regulation and evaluate the appropriateness of TCF technologies. One commenter (20,059) argued that the references in the Act to the elimination of emissions and its emphasis on elimination of dioxin emissions should have led EPA to select totally chlorine free technologies as the basis for the bleaching area MACT standard. The commenter (20,059) provided technical and legal support for their argument in their comments on the proposed effluent guidelines. One commenter (20,129) contended that in addition to TCF processes EPA should have also focused on emerging technologies, such as biofiltration, to minimize toxic HAP emissions. Response: The EPA interprets the Act as requiring EPA to establish the MACT floor level of control based on available data from the source category to be regulated (best-performing 12 percent of the existing sources for which [EPA] has emissions information) 'I. Control devices or technologies in use in other countries may be evaluated for determining control options beyond the MACT floor level of control. The use of TCF technologies in the U.S. is limited (currently only one mill has implemented the TCF process and this mill does not produce a full array of products). Therefore, it does not constitute the MACT floor level of control for existing

sources. The use of TCF technology has not been sufficiently

4-55demonstrated to produce the wide variety of U.S. pulp and paper products for EPA to conclude that the technology can be used widely. Therefore, EPA determined that it was inappropriate for TCF technologies to be the new source MACT. A detailed discussion of TCF is presented in the effluent guidelines portion of the promulgation preamble (VI.B). The installation and operation of the TCF bleaching process meets all the bleaching MACT standards for paper-grade bleaching and would constitute compliance with the final rule. Therefore, TCF bleaching is an alternative compliance option for the bleach plant. Also, the effluent guidelines portion of the final rule provides incentives for mills to adopt TCF technologies. The EPA should defer requirements for dissolving grade mills.
Comment: One commenter (IV-D2-17) suggested that a separate MACT floor level of control for chloroform should be developed for dissolving-grade pulp production. The commenter (IV-D2-17) anticipated that the dissolving-grade MACT would be similar to

EPA's requirements for paper-grade production (i.e.,C102 substitution and elimination of hypochlorite use in order to control chloroform, alkaline scrubbing for chlorinated HAP). The commenter (IV-D2-17) also anticipated that numerical emission limits for chlorinated HAP emissions would not be applied. Other commenters (IV-D2-15 , 25,538) recommended that EPA defer chloroform control requirements for dissolving-grade mills until BAT is established for those mills. Response: The EPA has concluded that MACT for chlorinated

HAP's is caustic scrubbing and process modifications (100 percent substitution and elimination of hypochlorite) for paper-grade

4-56mills. The effluent limitation guidelines and standards BAT requirements are at least as stringent as the MACT requirements. Therefore , the final rule requires bleach plants to control emissions using a caustic scrubber and comply with the BAT requirements or eliminate the use of chlorine and hypochlorite. As stated in the July 15 , 1996 Federal Register notice (61 F R 36835), EPA is evaluating new data on the technical feasibility of reducing hypochlorite usage and implementing high levels of Cl02 substitution on a range of dissolving-grade pulp products. Therefore, EPA is deferring issuing effluent limitation guidelines and standards for dissolving-grade mills until the comments and data can be fully evaluated. The EPA expects to promulgate final effluent limitation guidelines and standards for dissolving-grade subcategories at a later date. The EPA has decided to delay establishing these MACT standards for chloroform and for other chlorinated HAP's for dissolving-grade bleaching operations until promulgation of effluent limitation guidelines and standards for those operations , for the following reasons. With respect to the MACT standard for chloroform, first , as explained above and in the March 8, 1996 notice , the control technology basis for the effluent limitation guidelines and standards and the MACT requirements will be the same. Second, at present , the Agency is unsure what level of chlorine substitution and hypochlorite use is achievable for dissolving-grade mills. Thus, although EPA has a reasonably good idea what the technology basis of MACT and effluent limitation guidelines and standards is likely to be for dissolving-grade mills , the precise level of the standards remains to be determined. Consequently, at present, EPA is

4-57unable to establish what the MACT floor would be for chloroform emissions from bleaching systems at these mills, and there is no conceivable beyond-the-floor technology to consider. The EPA will make these determinations based on data being developed, and then promulgate for these mills effluent limitation guidelines and standards and, concurrently, MACT standards based on those effluent limitation guidelines and standards. Covered mills would therefore be required to comply with the MACT standards reflecting performance of the effluent limitation guidelines and standards no later than 3 years after the effective date of those standards, pursuant to Act section 112(i)(3)(A). The basis for delaying MACT requirements for chlorinated HAP's other than chloroform (again , from dissolving-grade bleach operations only) differs somewhat. As noted above, the technology basis for control of these HAP's is use of a caustic scrubber. However, when plants substitute for chlorine and eliminate hypochlorite (in order to control chloroform emissions and discharges to water, as explained above), a different scrubber will be needed that can adequately control both the Cl02 emissions for worker safety reasons and the emissions of chlorinated , non-chlorofor m HAP's. The Agency's concern (shared by the commenters who addressed this question) is that immediate control of the non-chloroform chlorinated HAP's could easily result in plants having to install and then replace a caustic scrubber system in a few years due to promulgation of effluent limitation guidelines and standards and MACT requirements for chloroform. This result is an inappropriate utilization of scarce pollution control resources.

4-58The EPA notes that an affected bleached paper-grade mill must comply with the MACT requirements no later than 3 years from publication in the Federal Register , even if the mill's existing CWA National Pollutant Discharge Elimination System

(NPDES) permit does not yet reflect the corresponding effluent limitation guidelines and standards because its existing terms have not expired or it has been administratively extended. Put another way , even if a mill's existing NPDES permit serves as a shield (until reissuance) against imposition of new limits based on new effluent limitation guidelines (see CWA section 402(k)), the MACT requirement for bleached paper-grade mills to control chloroform emissions through compliance with all parameter requirements in the effluent limitation guidelines and standards takes effect to satisfy the requirements of the Act. Similarly, if a bleached paper-grade mill's NPDES permit is reissued sooner than the expiration of the 3-year compliance schedule authorized for the chloroform MACT requirements and calls for immediate compliance with the BAT limitations , that deadline would prevail. The same principles will apply when effluent limitation guidelines and MACT standards are promulgated for dissolvinggrade mills. Incineration followed by scrubbing.

Comment: In the preamble to the proposed rule, EPA requested comment or data on the use of combustion followed by scrubbing to control emissions from the bleach plant. In response to EPA's request , on e commenter (20,027) claimed they were not aware of any mill that used a combination of incineration followed by scrubbing to control bleach plant emissions; therefore , it should not be considered a floor level

4-59of control technology for bleaching vents. The commenter (20,027) further stated that combustion of certain gas streams followed by gas scrubbing of others would not be cost effective as a beyond-the-floor level of control technology for bleaching vents, based on a cost analysis presented in the submitted

comments. Response: The EPA agrees with commenters that the combination of incineration followed by scrubbing is a technology that is more stringent than the MACT floor. The EPA determined that combustion followed by scrubbing could be achieved at a cost-effectiveness greater than $8,000/Mg HAP (see proposal preamble). The EPA determined that the costs were not reasonable given the level of emission reduction and the additional environmental impacts (increased water discharge and use) from this option. Therefore, the technology was not adopted for MACT. MACT floor for non-kraft mill bleach plants.
Comment: Two commenters on the proposed rule (20,053A1, 20,072) suggested alternative MACT floor levels of control for the bleaching area for mills other than kraft. Based on a project they undertook to understand methanol generation and control at a soda mill , one commenter (20,072) indicated that the MACT floor level of control for the bleaching component at soda mills should be equivalent to the proposed rules with the exception that the performance of the treatment device should be based on 95 percent removal of chlorine and Cl02 rather than 99 percent removal of total HAP. Response: Based on current data , EPA has decided not to create subcategories for the bleaching processes based on the type of pulping technology. The differences in the bleaching

4-60processes between mills using different pulping technologies does not appear to be great enough to warrant separate control requirements. The final rule requires mills to control chlorinated HAP's using caustic scrubbing and by meeting the effluent limitation guidelines and standards BAT requirements or by eliminating hypochlorite and chlorine use. Regarding one commenter's concern about the bleach plant scrubber requirements, data reviewed by EPA (A-92-40 , II -I-24) show that bleach plant scrubbers in pulp and paper mills achieve 99 percent control of chlorinated HAP's. The commenter did not provide support for requiring a lower percent reduction (95 percent). Therefore, the bleach plant scrubbers are required to achieve 99 percent control of chlorinated HAP's in the final rule (excluding chloroform). 4.3.1.4 Wastewater. Steam strippers are not appropriate as floor level of control technology.
Comment: Several commenters (20,027, 20,051, 20,054A2, 20,146) disagreed with the conclusion that steam stripping is a floor level of control technology for process wastewater. The commenters (20,011, 20,027, 20,051 , 20,054A2) explained that steam strippers currently in place were used for reducing odor and BOD loadings to the biological treatment plant, and for generating hot water for use in other process areas, but they were not used for HAP or VOC emissions control. The commenters

(20,027, 20,051 , 20,054A2) indicated that for these reasons, steam strippers have never been calibrated or operated for the type of continuous emission reduction that EPA has proposed. However, one commenter (20,059) supported EPA's proposal of steam

4-61stripping as the floor level of control technology for wastewater

treatment. The commenter (20,059) cited the fact that the American Paper Institute (API)/NCASI survey identified 31 mills that currently use steam strippers to control emissions from wastewater as support for this position. Two commenters (20,027 , 20,066A4) indicated that steam stripping for the process wastewater component should be considered as beyond-the-floor level of control and must be cost justified. One commenter (20,146) stated that EPA vastly underestimated the costs of steam stripper installation and operation. According to one commenter (20,027), the costeffectiveness of controlling wastewater components using steam stripping would not be reasonable based on EPA or industry cost and emission reduction estimates (A-92-40, 11-B-20, 11-B-28, 11-B-43, 11-C-10, 11-I-13, and 11-I-18). Several commenters (20,027, 20,045 , 20,066A4) claimed that because methanol is the principal HAP and biological treatment systems typically achieve greater than 90 percent reduction of methanol, biological treatment should be the floor level of control technology. One commenter (20,027) stated that there are no sulfite mills that currently use steam strippers. However, one commenter

(20,123A6) provided data on an existing steam stripper that is used to recover SO 2 at a sulfite mill. Two commenters (20,027, 20,076) declared that there are no sulfite mills that currently capture all emissions from process wastewater collection and

treatment. One commenter (20,027) submitted that because of this, the MACT floor level of control for the process wastewater component at sulfite mills should be no control. Other

4-62commenters (20,045 , 20,076) indicated that biological treatment should be the appropriate MACT floor control for sulfite mills. Two commenters (IV-D2-15 , IV-D2-16) agreed with EPA's conclusion that the floor level of control for sulfite wastewater emissions is no control. One commenter on the March 8 , 1996 supplemental notice (IV-D2-7) agreed with EPA's conclusion that MACT for semi-chemical wastewater is no control. Another commenter

(IV-D2-15) agreed with EPA's conclusion that MACT for bleaching wastewater is no control. Response: The March 8, 1996 supplemental notice presented a detailed discussion of revisions made to the steam stripping requirements since proposal. The EPA concluded that steam stripping is the floor level of control for kraft wastewater

streams. This conclusion was based on information collected in the 1992 voluntary MACT survey and other industry data submitted after proposal (A-92-40, IV-B-10, IV-Dl-3, IV-Dl-82, IV-Dl-91, and IV-J-32). Based on this information, EPA determined that greater than 20 percent of kraft mill s practice steam stripping. Therefore, the MACT floor level of control for kraft wastewater is steam stripping. For sulfite, semi-chemical and soda mill s and bleaching

processes , EPA has determined that process wastewater is not controlled at the floor level of control. Steam stripping is not required as a beyond-the-floor option due to the high cost required for a limited emission reduction. With regard to the comment that steam strippers were not installed for HAP or VOC emissions reduction, the Act requires that EPA determine MACT based on the best-performing facilities

4-63(i.e., the facilities with the lowest achievable emissions rate; see discussion under section 4.1 , Statutory Interpretation). The specific technologies in place at a best performing mill or the reasons for their existence are not relevant to the MACT determination. The commenters ' concern that steam strippers have never been calibrated or operated for the type of continuous emission reduction proposed by EPA is addressed in section 4.3.4 on downtime. Enclosure of wastewater streams should not be in the floor level of control.
Comment: Several commenters (20,027, 20,018A1, 20,051, 20,054A2, 20,146) stated that EPA failed to demonstrate that any

sources , much less 12 percent of sources, practice universal enclosure of all wastewater streams. One commenter (20,027) also stated that the use of covers in the industry was not sufficiently widespread enough to be considered a floor level of control technology; therefore , universal enclosure should be considered a beyond-the-floor option. In addition , the commenter

(20,027) indicated that EPA did not provide any record of the costs or benefits associated with enclosing wastewater streams. Two commenters (20,027 , 20,146) reasoned that since surface impoundments and clarifiers emit very small amounts of HAP's, the requirements to cover and control emissions from these units are totally unwarranted and should be removed from the final regulation. One commenter (IV-D2-7) noted that covering and venting to a control system all the equipment and tanks associated with wastewater treatment would be costly, impractical, and completely

4-64unreflective of current industry practice. Th e commenter (IV-D2-7) believes that covering these units does not represent a floor level of control practice and that EPA has not provided a cost-effectiveness analysis to substantiate a "beyond-the-floor" level of control. Response: As discussed previously in this section, EPA determined that steam stripping is the floor level of control for kraft mill condensates (A-92-40, IV-B-8). The EPA determined that a well-operated biological treatment system can achieve equivalent control if the wastewater conveyance system is enclosed to prevent volatilization of HAP's from the wastewater

(A-92-40, IV-Dl-75). At proposal , the covering and enclosure requirements were set forth for mills that wanted to use their existing sewer system to convey the wastewater to the biological treatment system. Failure to enclose conveying pipes and trenches would vitiate the rules effectiveness, since volatile HAP's would be released by the time wastewater reaches the biological treatment unit. See 56 FR at 33495, 33530 (necessity of controlling volatile wastes at the point of generation). The final rule requires that mills choosing to use biological

treatment must hardpipe the effluent to the treatment unit using a condensate collection system meeting the individual drain system requirements specified in subpart RR §§ 63.960, 63.961, 63.962, and 63.964. 4.3.2 MACT Floor Control Applicability 4.3.2.1 Named Strea m Approach Versus Applicability Cutoffs.
Comment: Many commenters (20,027, 20,054A2, 20,056, 20,057, 20,057A2, 20,059, 20,07OAl, 20,074, 20,118, 20,146) disagreed with the levels chosen for the applicability criteria in the

4-65December 1993 proposal for the pulping, bleaching, and process wastewater components. Most of the commenters (20,027, 20,054A2, 20,056, 20,057, 20,057A2, 20,070Al, 20,074, 20,118) objected that the d e minimis levels for the applicability criteria were too low, did not represent the MACT floor level of control, and would result in sources being subject to the MACT standards beyond the floor level of control. One commenter (20,059) indicated the applicability level was set too high. Three of the commenters

(20,027, 20,059 , 20,146) objected that EPA lacked sufficient data and quantitative information to support the numerical values or cutoffs. One commenter (20,010) supported the proposal as set forth because it required the control of all significant emission points from the bleaching process. One commenter (20,059) contended that EPA did not evaluate a range of applicability levels, nor did it assess the environmental implications of the proposed cutoff levels, or any alternatives. The commenter (20,059) was concerned that some LVHC concentration vents that should be controlled would not be. The commenter (20,059) suggested a sliding scale combination of flow and concentration to determine applicability rather than excusing a vent because either flow or concentration were low. Several commenters (20,027, 20,054A2, 20,056, 20,057A2, 20,066A4, 20,118) suggested specific levels for de minimis flow and concentration rates. Several commenters (20,027, 20,056, 20,066A4) proposed approaches for re-determining the floor level of control applicability levels. One commenter (20,027) strongly recommended that EPA use the control and stream characterization information submitted by industry to set applicability levels

4-66(A-92-40, II-B-20, II-B-21, II-F-27). Two commenters (20,027, 20,066A4) suggested that EPA establish de minimis flow and emission rates for pulping and bleaching process vents using the
data fro m deckers and screens , sources for which the proposal determined to have no control at the floor level of control. One commenter (20,027) suggested limiting the use of de minimis criteria to the floor level of control emission points, revising the criteria to annual averages , and allowing for engineering evaluations to determine source applicability. The commenter

(20,027) also suggested using a total resource effectiveness (TRE) equation to determine applicability as cited in the HON. The commenter's (20,027) rationale was that a TRE brings in a third parameter (i.e. , cost-effectiveness) in determining applicability. Several commenters (20,027, 20,046A2, 20,059, 20,07OAl, 20,071, 20,074 , IV-D2-15) supported naming the emission points in the pulping component that must be controlled. One commenter

(IV-D2-15) noted that this approach would make the rule easier for the regulated community to understand and implement, eliminate the need for widespread testing to determine applicability , and would guarantee the treatment of those streams with significant HAP concentrations. The commenter (IV-D2-15) also stated that this approach will simplify preparation, review, and enforcement of permits for pulp and paper mills, as well as result in significant reductions in implementation costs to mills while resulting in emission reductions equivalent to those proposed. One commenter (20,056) stated the only process equipment that should have been considered for control in the floor was as follows: (1) digester or NCG system; (2) digester

4-67relief system; (3) evaporator NCG and hotwell gases; (4) oxygen delignification unit (blow gases and washer); (5) foam breaker or filtrate tanks ; and (6) weak black liquor storage tanks. The commenter (20,056) indicated that dewatering devices other than deckers should also be exempt from control. One commenter (20,043) explained that for quality assurance

purposes, samples are collected throughout the processing of pulp and paper and requested that the sample pots and their associated air and water emissions be considered de minimis in the final rule. Response: At proposal , EPA had limited data to characterize some of the smaller emission points and condensate streams within the pulping component. In the absence of more specific data, the applicability values were identified as a way to distinguish between the emission points that were controlled at the floor level of control and those that were not. Since proposal, industry has submitted additional data (A-92-40, IV-Dl-29, IV-Dl-29a, IV-Dl-31, IV-Dl-33, IV-Dl-34, IV-Dl-35, IV-Dl-38, IV-Dl-39, IV-Dl-41, and IV-Dl-41). This new information allowed EPA to identify which vent and condensate streams are actually controlled at the floor level of control. The EPA reanalyzed the floor level of control based on these designations. The EPA then revised the format of the proposed rule to account for the new data and the results of the floor level of control analysis. The format for the final rule names specific streams to be controlled. The EPA also determined that applicability values were appropriate for decker, knotter, and screen systems. The EPA is not regulating all decker , knotter and screen systems because control of all these streams are not in the floor level

4-68of control , only the high emitting ones. No further control is justified. Commenters are referred to section 4.3.1.2 for a discussion of the applicability determinations for decker, knotter, and screen systems. The different approach used in the final rule does not significantly change the number of emission points controlled from those intended to be controlled in the proposed rule. The emission points and condensate streams that are being controlled in the final rule are fundamentally the same emission sources that EPA intended to be controlled in the proposed rule. The EPA concluded that the revised approach is easier and less costly to implement, for both the affected industry and the enforcement officials, since extensive emission source testing is not required to identify the vent and condensate streams to be controlled. MACT floor level of control applicability for condensate

streams.
Comment: Regarding the December 17, 1993 proposal, one commenter (20,027) declared that the applicability format selected for wastewater streams presumed that all streams in the mill (except the bleach plant acid and caustic sewers) would require control unless they are tested to prove they are below the cutoff thresholds. The commenter (20,027) stressed that this format would require unnecessary testing and evaluation in areas of the mill where control is not warranted. Two commenters (20,027 , 20,056) suggested that EPA specify by name or class which wastewater streams are exempt and which streams must be sampled to prove they are de minimis. One

4-69commenter (20,027) suggested specific format changes for the process wastewater area. One commenter (IV-D2-3) requested that the rule specifically allow stripped condensates or condensates not listed for control to be reused at any location in the mill or be sewered without additional control requirements. Regarding EPA's approach of naming condensate streams subject to the MACT control applicability in the March 8, 1996 supplemental notice , one commenter (IV-D2-15) agreed with EPA's decision to name the specific pulping process wastewater streams that will be subject to control. The commenter (IV-D2-15) stated that this approach eliminates the need for an expensive open-ended sampling program to show what streams did not meet the concentration and flowrate applicability criteria. The commenter

(IV-D2-15) stated that the control of the named streams will treat more HAP-containing water than is currently being treated; therefore it will provide a level of control beyond the floor. While the commenter (IV-D2-15) did not take exception to this particular requirement , the commenter felt it should be noted. The commenter (IV-D2-15) added that the rule should also state explicitly that the treated condensates should be available for reuse throughout the mill without any further restrictions. One commenter (IV-D2-14) disagreed with EPA's decision in the March 8, 1996 supplemental notice to define pulping process wastewater streams requiring control as those achieving a 65 percent or greater methanol recovery. The commenter (IV-D2-14) noted that evaporator or condenser systems that do not currently achieve 65 percent methanol recovery cannot simply readjust th e interna l configuration of the equipment and that

4-70improved recovery would require extensive modification or replacement of equipment. The commenter (IV-D2-14) also suggested that newly installed systems may or may not be able to achieve the 65 percent methanol level and the commenter proposed to redefine pulping process wastewater streams to be controlled as those with a minimum of 50 percent methanol recovery. Two commenters (IV-D2-3 , IV-D2-20) agreed that pulping process wastewater to be controlled should contain 65 percent of the methanol present in the vapor from the first weak liquor feed stage(s). The commenters (IV-D2-3 , IV-D2-20) suggested that because they aggregate pulping process wastewater on more than the weak liquor feed stage(s), the definition needs to be clarified or else the mill will have to cease collection of methanol from evaporator stages other than weak liquor feed stage(s). The commenters (IV-D2-3 , IV-D2-20) recommended that the rule make it clear that the 65 percent requirement applies to the system as a whole and not to every individual evaporator stage where condensate segregation is practiced. Response: In the final rule , EPA has decided to retain the approach of requiring named streams to be controlled. This approach is the most efficient method of specifying applicability of the rule and will eliminate unnecessary testing and compliance burden on the affected industry. The final rule requires that the entire volume of the named streams must meet MACT, expressed as one of several treatment options. However, the rule includes an option for reducing the volume of condensate to be treated from specified streams. Most mills currently practice some degree of condensate segregation on the pulping process wastewater streams. Condensate segregation is

4-71the practice of generating, producing , or isolating a high-HAP concentration/low flow rate condensate stream from process vent vapors or gases in order to maximize the HAP mass and minimize the condensate volume sent to subsequent treatment. If a mill utilizes condensate segregation to produce the pulping process condensate streams , only the high-HAP fraction stream must be treated according to the options specified in the standards. If condensate segregation is not practiced, the entire volume of the pulping process condensate stream must be treated. Based on the information obtained in the 1992 voluntary NCASI survey , the floor level of control for kraft pulping process condensates is 92 percent removal of total HAP (based on the performance of steam stripping) from the high-HAP fraction condensates from the digester, turpentine recovery, and evaporator systems. However , no standard definition (e.g., HAP concentration, flow rate, mass , etc.) exists for designating the high-HAP fraction condensate streams from these systems. Consequently , EPA developed the percent mass split criteria for designating the high-HAP fraction condensate streams. As discussed in the March 8 , 1996 Federal Register supplemental notice (61 FR 9390), EPA determined that condensate segregation can generate a high-HAP fraction stream containing 65 percent of the overall HAP mass present in the process vapor stream. The 65 percent mass split was developed based on information provided by industry during a meeting with EPA (A-92-40, IV-E-15). The information contained example mass balances for digester, turpentine recovery , and evaporator system condensates before and after condensate segregation was implemented. The before-and-after mass balances were used to estimate the typical

4-72mass split found in the high-HAP fraction condensate streams that was achievable using segregation. In their comments on the March 8, 1996 Federal Register supplemental notice and in additional correspondence to EPA (A-92-4, IV-Dl-97), industry indicated their support for the definition of the high-HAP fraction condensate stream. However in correspondence to EPA regarding suggestions to the MACT standard definitions (A-92-40, IV-Dl-107), industry indicated that a high-HAP fraction condensate stream should be designated by a 50 percent mass split (instead of 65 percent). This revision was necessary, according to industry, since some of the mills with the best-performing steam stripper systems could not meet the 65 percent mass split , even though they were sending a large amount of HAP mass to the stripper system for treatment. To resolve the discrepancy between the EPA and industry percent mass split designations , additional data were evaluated to confirm the percent mass split values presented in the March 8, 1996 notice (A-92-40, IV-B-24). Based on the evaluation , EPA disagrees with the percent mass split recommended by industry (50 percent) , and has decided to keep the 65/35 percent mass split. In their correspondence , industry also suggested that an additional option be added to the MACT standard that would allow for either the percent mass split to be achieved or for a minimum HAP mass be sent to treatment. Some commenters also indicated that they would not be able to achieve the 65/35 percent mass split without extensive and costly modifications to their Based on the analysis presented in this imum mass existing equipment. memorandum, EPA be 1 ieves that achieving the min

4-73requirements would also achieve their intent of controlling only the low volume, high-HAP fraction condensate streams. The minimum mass requirements were based on the steam stripper performance requirements (i.e., percent and mass removal) developed for the MACT standard. The development of the steam stripper performance requirements is presented in a separate memorandum (A-92-40, IV-B-10). For both bleached and unbleached mills , the final rule requires 92 percent removal of

HAP. For bleached mills , the mass removal requirement is 5.5 kilograms or more of total HAP (measured as methanol) per megagram of oven-dried pulp (kg HAP/Mg ODP); for unbleached mills, the mass removal requirement is 3.6 kg HAP/Mg ODP

(measured as methanol). The minimum mass requirements for each type of mill (bleached and unbleached) were obtained by dividing the required mass removal by the required percent removal. For example, the mass removal required for bleached mills (5.1 kg HAP/Mg ODP) divided by the percent removal (92 percent) yields a minimum mass removal of 5.5 kg HAP/Mg ODP. The minimum mass removal for unbleached mills (3.6 kg HAP/Mg ODP) was obtained using the same procedure. MACT floor level of control should be applicable to chlorine dioxid e preparation equipment.

Comment: One commenter (20,110) asserted that the proposed rule did not address ClO2 preparation equipment. Two commenters

(20,091, 20,110) asserted that the rule should require control of Cl02 preparation equipment and emission points. One commenter

(20,091) contended that Cl02 is more toxic than chlorine and the generation of Cl02 is likely to increase in the future as the use of Cl02 substitution becomes more prevalent in the industry.

4-74Response: The final rule does not require control of Cl02 generation equipment. No information has been submitted to the Agency to suggest that Cl02 generation is a significant source of

HAP emissions (Cl02 is not a listed HAP) or that controls exist at the floor level of control. Based on an engineering review of process flow diagrams of Cl02 generation processes supplied by commenters, EPA has concluded that these processes are essentially closed processes without significant atmospheric

vents. Facilities storing over 1,000 pounds of Cl02 would be subject to the 112(r) requirement of an approved accident prevention and response plan. Using applicability levels.
Comment: One commenter (20,059) argued that the use of cutoffs or applicability levels based on cost-effectiveness considerations would be illegal in light of Congress' rejection of cost-benefit and cost-effectiveness as a basis for setting MACT standards. The commenter (20,059) suggested that EPA eliminate the cutoff applicability criteria that exempt emission points from control. One commenter (20,114) contended that the cutoff level of 500 ppmv for capture and incineration of vent gases contained in the proposal should be increased. The commenter (20,114) argued that the 500 ppmv cutoff was apparently developed using data from the synthetic organic chemical industry. The commenter (20,114) argued that application of data from a different industry must be justified by EPA. Response: In the proposed rule , the applicability criteria were not chosen on the basis of cost-effectiveness but rather to delineate between vents and wastewater streams that are

4-75controlled at the MACT floor level of control. Section 112(d)(2) of the Act requires the Administrator to establish standards based on the maximum degree of reduction in emissions of HAP's "taking into consideration the cost of achieving such emission reduction. . .'I This mandate was followed by EPA and the
standard was set at the floor. Applicability cutoffs were used to distinguish between vents that were and were not controlled at
the floor level of control. Regarding the comments on the 500 ppm cutoff , the commenter appears to be confused with regard to the applicability cutoffs specified at proposal. The 500 ppmw

(not volume) cutoff in the proposed standard applied to process

wastewater streams. Regarding the commenter's concern about applying data from different industries, EPA interprets this comment to address the 20 ppmv outlet concentration specified for incinerators used to comply with the pulping process standards. The EPA has concluded that the outlet concentration is achievable for well designed and operated incinerators (A-92-40, IV-B-19). Since proposal , industry submitted additional data (A-92-40, IV-Dl-29, IV-Dl-29a, IV-Dl-31, IV-Dl-33, IV-Dl-34, IV-Dl-35, IV-Dl-38, IV-Dl-39 , and IV-Dl-41) that was used by EPA to revise the format of the proposed rule. The format for the final rule names specific streams to be controlled. The EPA also determined that applicability values were appropriate for knotter and screen systems. A more detailed discussion of this issue is presented in the March 8 , 1996 supplemental notice. Commenters are referred to section 4.3.1.2 for a discussion of the applicability determinations for knotter and screen systems. MACT floor level of control applicability for sulfite mills.

Comment: One commenter (20,027) reasoned that the MACT

4-76floor level of control at sulfite mills should exclude the control of nonhalogenated HAP's from hot caustic extraction stages, and the control of digester or evaporator condensates because sulfite mills do not control these processes. Response: The EPA agrees with the commenter. As discussed in the March 8 , 1996 supplemental notice, the available data supports the establishment of separate emission standards for bleaching at paper-grade and dissolving-grade pulping processes but not on the type of pulping process (e.g., kraft, soda, sulfite, or semi-chemical pulping). The data also indicated that bleach plant scrubbers are ineffective at removing non-chlorinate d HAP's. In the final rule, sulfite mills are required to comply with the respective bleaching standards for paper-grade or dissolving-grade processes, which set requirements for chloroform and other chlorinated HAP's. Regarding the control of digester or evaporator condensates, EPA concurs that no existing sulfite mills control these streams. Therefore, control of these streams is not included in the MACT floor level of control. Considering cost and impacts, the EPA considers the option to steam strip these streams beyond the floor level of control, to be unreasonable.
Comment: One commenter (IV-D2-14) asked that the identity of the specific vents to be included in the mill systems be more explicitly stated. The commenter (IV-D2-14) provided a list of sulfite mill vents proposed to be included in digester, evaporator, an d redstock washer systems. Response: The EPA appreciates the commenter's support for requiring specific named streams to be controlled. The EPA evaluated the types of equipment controlled at existing sulfite

4-77mills in developing the MACT floor level of control and MACT requirements (A-92-40, IV-B-8). The final rule requires existing sulfite sources to control digester systems, evaporator systems, and pulp washing systems. New sulfite sources are required to control the same equipment as existing sources plus weak liquor storage tanks , strong liquor storage tanks, and acid condensate storage tanks. The emissions from these named systems must be collected in a closed-vent system and routed to a control device. Both the total methanol emissions from these named systems and condensate streams from equipment used to reduce methanol emissions at sodium- and calcium-based sulfite processes are to meet an emission limit of 0.89 lb/ODTP or are to be reduced by 92 percent. Similarly, both the total methanol emissions from magnesium or ammonium-based sulfite processes are to meet an emission limit of 2.2 lb/ODTP or are to be reduced by 87 percent.

Wastewater reuse.
Comment: One commenter (20,057A2) stated that EPA improperly determined the floor level of control for brownstock washers to be collection and incineration of vent gases. The

commente r (20,057A2) asserted that if condensates that are recycled to the washer are required to be treated, then the emissions from the washer will be reduced when the cleaner condensate is used. According to the commenter (20,057A2), requiring treatment of condensates and collection and incineration of brownstock washer vents is tantamount to going above the floor level of control. The commenter (20,057A2) indicated that EPA should perform a cost analysis for going beyond the floor.

4-78One commenter (20,057A2) recommended that wastewater emission reductions be measured on a "mill-wide" basis because of the complex processes of recycle and reuse found throughout the mill. Response: While EPA agrees with the commenter that reducing the HAP concentration of shower water will reduce atmospheric emissions from brownstock washers , EPA does not agree that steam stripping is a beyond the floor level of control option. Based on data submitted after proposal (A-92-40, IV-J-32), EPA concluded that the streams that are typically recycled to brownstock washers are not the sam e as the named streams that are required to be treated in the stea m stripper by the final rule. Additionally, the final rule includes a control option allowing mill s to recycle the named condensate streams, without subsequent treatment, to a controlled piece of process equipment. Since the final rule requires pulp washers to be controlled, condensate streams recycled to this piece of equipment are not required to be treated.
Comment: One commenter (20,027) commented critically that the prohibition of wastewater stream dilution would require wholesale repiping of established process water flow patterns in the industry in order to avoid the impermissible "dilution." Response: The part 63 general provisions prohibit sources from circumventing the control requirements of the part 63 standards. The general provisions specifically prohibit circumventing standards by dilution. Therefore, EPA does not consider it necessary to include similar requirements in the rule, and the final rule does not include this language.

4-794.3.3 Beyond the MACT Floor Level of Control.
4.3.3.1 MACT Se t Beyond the MACT Floor Level of Control.

Comment: Two commenters (20,027 , 20,146) stated that while the Act allows EPA, in certain cases , to set MACT beyond floor levels of control , EPA did not establish a foundation for such a decision for the proposed standards. (Case law cited: Portland Cement Assoc. v. Ruckelhaus, National Lime Assoc. v. EPA, and Sierra Club v. Costle; A-92-40, II-C-10.) Response: Based on information available at the time of proposal and the statutory interpretation of the MACT floor level of control , EPA did not propose requirements beyond the MACT floor level of control. The EPA agrees with the commenter that if controls beyond the level of the MACT floor level of control were proposed , then they must be supported by sufficient information on the balance of costs, energy, and environmental impacts. In the final rule , the only MACT requirements for existing sources that are beyond the MACT floor level of control are for soda pulping processes. Data available to EPA from the 1992 voluntary MACT survey and information received after proposal indicate that soda mills do not currently control any of the equipment that is subject to the MACT requirements for kraft mills (A-92-40, IV-B-8). However, EPA has determined that the emissions from soda mill s are similar to kraft mills and that the control costs are similar to stand-alone semi-chemical mills. Therefore, EPA considers going beyond the MACT floor level to control LVHC vent emissions at soda mills to be an appropriate level of control for MACT for these mills , taking into consideration the costs of achieving the controls as well as the

4-80other factors , such as energy and environmental impacts (A-92-40, IV-B-12) . 4.3.4 Downtime and Back-up Control Technologies

Comment: Several commenters (20,027, 20,043, 20,054A2, 20,057, 20,066A3, 20,146) indicated that downtime of equipment is part of the natural variability of operation, and should have been considered by EPA when determining the MACT floor. One commenter (20,027) further stated that continuous compliance without downtime , as required by the proposed standards, would be beyond the MACT floor level of control since no mil l currently operates with this type of continuous compliance. One commenter

(20,102) contended that based on past experiences of controlling NCG and brownstock washer gases in power boilers and lime kilns, existing control devices may not even be capable of providing continuous compliance. One commenter (20,027) indicated that if no allowance for excess emissions is provided in the final rule, EPA must conduct a cost-effectiveness analysis for the use of backup control devices, since these control devices would be needed and the costs and secondary impacts of backup control devices for combustion sources and steam strippers were not addressed in the proposed standards. Two commenters (20,027, 20,115A2) concluded that because the downtime occurrence (and therefore the emission reduction) would be small and the costs for backup control devices would be large , the use of these backup control systems cannot be justified as cost effective as a beyond-the-MACT-floor level of control. One commenter (IV-Dl-15) stated that very few mills have HVLC controls and only a small percentage of those mills have

4-81backup controls; therefore , backup controls are not part of the MACT floor level of control for HVLC systems. One commenter

(20,149) indicated that existing combustion devices are down enough that it is reasonable to expect a backup device. One commenter (20,150) requested that new backup controls be required by all mills using the Cl02 bleaching process. One commenter

(20,110) stated that the proposed rule should be amended to require backup incineration devices. The commenter (20,110) indicated that backup emissions controls are already in place in a portion of the industry. Several commenters (20,027 , 20,057A2) disputed whether the general provisions to part 63 would cover maintenance and troubleshooting downtime , since the industry and regulatory officials do not generally consider these events malfunctions. Another commenter (20,054A2) stated that EPA had assumed that the startup, shutdown, and malfunction allowance would cover those events that resulted in venting of LVHC and HVLC gases from closed-vent systems. The commenter (20,054A2) stated that not all of the maintenance downtime associated with lime kilns and power boilers necessarily cause a shutdown in pulp mill operation since facilities can continue to operate the pulp mill at various rates depending on liquor inventories and chemical make up systems. One commenter (IV-D2-2) noted that any time that both the mill and the NCG system are down should not be counted toward downtime. Two commenters (20,066A3, 20,146) requested that EPA specifically identify in the final rule which types of startup, shutdown, and malfunction events will not require compliance with the air emission standards. Another commenter (20,059) contended that the general provisions were too lenient in allowing the

4-82emissions associated upsets, startup, shutdown, and maintenance and urged EPA to close this loophole in the regulation. Two commenters (20,027 , 20,146) indicated that excess venting is an essential safety practice, and that it would occur even with transfer to a backup control device. One commenter

(IV-D2-11) suggested that by-pass allowances are needed for unavoidable and safety venting events that are sometimes difficult to define in advance. Another commenter (20,151) indicated that uncontrolled pulping emission from bypass collection systems should be controlled. Several commenters (20,027, 20,043, 20,054A2, 20,057, 20,057A2, 20,066A4, 20,07OAl, 20,118, IV-D2-2) presented suggestions as well as estimated and measured downtime for certain processes and equipment at their facilities. Several commenters (20,027, 20,054A2, IV-Dl-15, IV-D2-15) requested a venting allowance for the pulping component standards ranging from 2 to 4 percent outside of startup, shutdown, and malfunction provisions in the general provisions; this would be similar to the allowance contained in the pulp and paper NSPS. One commenter (20,027) indicated that backup control devices would not be needed to comply with the rule if a 4 percent allowance is included.
One commenter (20,054A2) asserted that LVHC gas flows cannot be automatically diverted to backup devices due to explosion hazards. The commenter (20,054A2) stated that: (1) the burners used in the backup devices must go through startup checks that may result in venting for 15 to 30 minutes per episode; (2) the frequency for diverting to a backup device varies from 1 to 10 events in a quarter (e.g. , 15 to 300 minutes of venting); and

4-83(3) the operation of backup devices are checked by most mills at least once per month. Another commenter (IV-D2-11) recommended incorporating by-pass allowances of 2 percent for LVHC control systems.
One commenter (20,054A2) stated that their current primary source of combustion for LVHC gases was the lime kiln. The

commente r (20,054A2) indicated that: (1) lime kilns typically require approximately 1.5 to 2 percent of the available annual operating hours for rebricking ; and (2) operating variabilities

(such as flame outs, ring formation, and problems with the product removal system and wet end processes) can result in additional downtime of 0.5 to 1 percent of the available annual operating hours. The commenter (20,054A2) further asserted that a minimum of one maintenance shut down per year (1 to 1.5 percent of the available annual operating hours) is required by the mill and that operating variables (such as variable steam load, fuel feed system problems) can result in venting of LVHC gases from 0.5 to 1 percent of the available annual operating hours. One commenter (IV-Dl-15) stated the HVLC streams are vented to the atmosphere during boiler or recovery furnace downtime, which is normally down about 10 percent of the time the mill is in operation. One commenter (IV-D2-2) suggested that a downtime of 10 percent for HVLC systems is warranted, as these systems are typically single line/single combustion point systems as opposed to LVHC control systems. Another commenter (IV-D2-11) recommended incorporating a by-pass allowance of 5 percent for HVLC control systems.

4-84Two commenters (20,027 , 20,043) recommended an allowance of downtime for excess emissions from bleach plant scrubbers of approximately 2 percent. One commenter (20,011) stated that the need for backup control devices to account for steam stripper downtime or biological treatment system upsets has not been addressed by EPA. One commenter (20,071) stated that all mills, even those with backup control devices , will vent steam stripper overheads for some percentage of the time. Another commenter (IV-D2-3) suggested an allowance of 5 percent of the operating year for steam stripper downtime. One commenter (IV-D2-2) suggested a downtime of 5 percent for more reliable stand-alone stripping systems but a downtime of 10 percent for integrated stripping systems. One commenter (IV-D2-3) noted that downtime should only be considered those periods when condensates are unable to be treated and must be sewered. The commenter (IV-D2-3) also requested that the rule explicitly state that sewering during periods of steam stripper downtime is acceptable. Another commenter (IV-Dl-15) also indicated that the rule should take into consideration steam stripper downtime and that mills currently route those streams to the sewer during periods when the stripper is not functioning and the stripper feed tanks are full.
One commenter (20,054A2) stated that the industry recommendation for a measure of continuous compliance is venting time for a closed-vent system with an allowance for short term venting which occurs due to inherent process variability. The

commente r (20,054A2) provided information on how several States regulate continuous comp l iance, and indicated that the kraft pulp

4-85mill NSPS (subpart BB , 40 CFR part 60) allows two TRS exceedances per quarter excluding startup, shutdown, and malfunctions. One
commenter (IV-D2-15) stated that excusable excursions are also need for parameter monitoring and should be determined on an annual basis as a percentage of the time that the process is in operation. Response: Since proposal , EP A has re-evaluated the need to incorporate downtime or excess emissions allowances for LVHC,

HVLC , and steam stripper systems into the final rule. Based on the information collected in the 1992 voluntary MACT survey, EPA concluded that some allowance for excess emissions is part of the MACT floor level of control. For the final rule, EPA established excess emissions allowances to approximate the level of downtime and backup control at the best performing mills and the associated period of time which no control device is available

(A-92-40, IV-E-83) . The excess emissions allowances in the final rule include periods when the control device is inoperable and when the operating parameter values established during the initial performance test are not maintained at the appropriate
level. Based on an analysis of the public comments and the available data regarding excess emissions and the level of backup control in the industry , EP A has determined that an appropriate excess emissions allowance for LVHC systems would be 1 percent of the operating hours on a semi-annual basis for the control devices used to reduce HAP emissions. The best-performing mills achieve a 1 percent downtime in their LVH C system control devices. For control devices used to reduce emissions from HVLC systems, EP A has concluded that an appropriate excess emissions

4-86allowance would be 4 percent. The best-performing mills achieve

a 4 percent downtime in the control devices used to reduce emissions from their HVLC system to account for flow balancing problems and unpredictable pressure changes inherent in HVLC systems. For control devices used to control emissions from both LVHC and HVLC systems, the Agency has determined that a 4 percent excess emissions allowance is appropriate. This decision was made because the control device would be used for the HVLC system, which has the higher emissions allowance. For LVHC and HVLC system control devices, the excess emissions allowances do not include scheduled maintenance activities that are discussed in the part 63 general provisions. The allowances address normal operating variations in the LVHC and HVLC system control devices for which the equipment is designed. The variations would not be considered startup, shutdown, or malfunction under the part 63 general provisions (Air Docket A-92-40, IV-Dl-103, IV-Dl-110, IV-Dl-115, IV-E-83, and IV-E-85). Although industry commenters suggested a downtime allowance of excess emissions from bleach plant scrubbers of approximately 2 percent, no data were provided to support their suggestion. The commenters did not address bleach plant scrubbers in their recommendation for control device downtimes in subsequent data submittals. Therefore, the final rule does not include downtime allowances for bleach plant scrubbers. The Agency determined the appropriate excess emissions allowance for stand-alone and integrated steam stripper systems to be 10 percent. The allowance accounts for stripper tray damage or plugging, efficiency losses in the stripper due to contamination of condensate with fiber or black liquor, steam

4-87supply downtime and condition control device downtime. This downtime allowance includes all periods when the stripper systems are inoperable including scheduled maintenance and malfunctions, startup, and shutdowns. The stripper emissions allowances include the part 63 general provisions allowances because information was not available to differentiate these emissions from normal stripper operating emissions. Regarding the commenters' discussion of whether the general provisions to part 63 would cover maintenance and troubleshooting downtime, EPA has taken public comment and is currently revising the requirements of the general provisions. Among the changes to the language , EPA intends to incorporate safety-related venting requirements into the general provisions. However, scheduled maintenance activities are not considered by EPA to qualify for excess emissions allowances. The EPA contends that the startup, shutdown, and malfunction plan provisions specified in the general provisions to part 63 should address the periods of excess emissions that are caused by unforeseen or unexpected

events. 4.4 FORMAT OF THE STANDARDS 4.4.1 General Comments 4.4.1.1 A Percent Reduction Requirement is Unenforceable.

Comment: One commenter (20,059) objected to the use of a percent reduction requirement as an emissions standard since a reduction requirement cannot be enforced and verification cannot be determined without measurement both before and after control. The commenter (20,059) argued that non-complying companies could manipulate the estimate of pre-controlled emissions to avoid detection of violations. The commenter (20,059) indicated that

4-88EPA should establish numerical , pound-per-hour emission rates on a continuous basis for the standards. Response: The EPA disagrees with the commenter. Percent reduction formats were specified in the rule only in cases where it was not feasible to prescribe a numerical emission rate. The most common emission rate format generally is one expressed as mass-per-unit-of-production, since pound-per-hour rates vary with production capacity and utilization rate. For this rule, however, it was not always feasible to develop a mass-per-unit-of-production format because of lack of data or because of the degree of variability of uncontrolled emissions. Since proposal , additional test data have been submitted to EPA (A-92-40, IV-Dl-29, IV-Dl-29a, IV-Dl-31, IV-Dl-33, IV-Dl-34, IV-Dl-35, IV-Dl-38, IV-Dl-39 , and IV-Dl-41) to better characterize HAP emissions from the pulp and paper processes. Although the test data were a significant improvement over the data available at proposal , the data were not adequate for developing numerical emission standards for all pulping and bleaching processes at all pulping subcategory types. The EPA disagrees that a percent reduction format is unenforceable. Percent reduction requirements have been included in numerous NSPS and NESHAP and have been demonstrated to work. State and Federal enforcement officials are accustomed to enforcing these types of standards. Additionally, the general provisions to part 63 specifically prohibit circumvention of the standard by the use of diluents to achieve compliance. Surrogate for HAP.
Comment: Several commenters (20,027, 20,056, 20,057A2, 20,071, IV-Dl-15) supported the use of methanol as a surrogate

4-89measure for total HAP. One commenter (IV-Dl-15 ) also agreed with using methanol as a surrogate for total HAP for pulping and wastewater sources since methanol typically constitutes 90 percent or more of the total HAP's in these sources. For bleach plants , the commenter (IV-Dl-15 ) also agreed with EPA's intent to use chlorine as a surrogate for compliance determinations since only chlorinated HAP's are controlled by MACT technologies. Several commenters (20,102, 20,110, 20,111, 20,129) suggested that EPA establish pollutant-specific emissions limitations for bleaching equipment such as chloroform, chlorine, and C102. Several commenters (20,022, 20,049A3, 20,059, 20,090, 20,122, 20,132 , 20,133) requested pollutant-specific limit s on air pollutants. One commenter (20,110) indicated that EPA should ensure that HAP's other than methanol and chlorine, such as phenol and chloroform , are controlled to an efficiency of at least 90 percent. One commenter (20,102) indicated that EPA has the authority to implement pollution prevention opportunities such as source reduction through the MACT development process. The commenter (20,102) suggested EPA might improve that ability through some pollutant-specific limitations in addition to total HAP emissions. One commenter (20,059) argued that EPA authorized a form of interpollutant trading by failing to establish emission limits for individual pollutants. The commenter (20,059) indicated that proposed process changes and control technologies differ in the amount of specific HAP's they reduce , yet EPA lumped all of the pollutants together regardless of toxicity. Two commenters

(20,102, 20,103) stated that EPA should give special attention to

4-90chloroform due to its toxicity and because it is a carcinogen. The commenters (20,102 , 20,103) requested that EPA provide more technical guidance on its evaluation and control. On e commenter

(20,129) stated that emissions of carcinogenic compounds from bleaching vents should be controlled to low5 to 10-6 inhalation risk levels with BACT air cleaning technology. Response: The final rule is a technology-based standard with the MACT level of control based on the performance of technologies that achieve the greatest level of emissions reduction. The pulping process emits non-chlorinated HAP's

(predominantly methanol) while the bleaching process emits chlorinated HAP's (such as chloroform, chlorine) and nonchlorinate d HAP's. Each of these types of HAP (non-chlorinated and chlorinated) has different applicable control technologies (i.e., combustion and caustic scrubbing, respectively). For this reason, EPA reevaluated the floor level of control for each of these types of HAP as discussed in the March 8, 1996 supplemental notice. As a result, pulping standards were based on combustion with methanol as the surrogate compound. For the bleaching process, standards were developed for chloroform , and other chlorinated HAP's (with chlorine as the surrogate compound). The EPA maintains that methanol is an appropriate surrogate for non-chlorinated HAP's since methanol is the majority of the non-chlorinated HAP's found in pulping process vents and wastewater based on the available data (A-92-40, IV-A-8). Chlorine was designated as a surrogate for chlorinated HAP's

(other than chloroform) because the MACT floor level of control technology, caustic scrubber , was installed primarily for

4-91chlorine control. Therefore, control of chlorine should indicate proper operation of the caustic scrubber. Chloroform is controlled through process changes such as Cl02 substitution and elimination of hypochlorite. The EPA contends that the control technologies selected for the pulping and bleaching processes and the surrogate compounds selected for measurement ensure the adequate control of total HAP compounds. With regard to the commenters' discussion of pollutantspecific limits , EPA asserts that the level of the standards would not be significantly different, if at all, had the standard been based on specific HAP's. The rationale for this assertion is that EPA evaluated all of the reasonably applicable control technologies and determined that the technologies chosen in the final rule would achieve the maximum emission control of total
HAP'S. Some other technologies (e.g., incineration of bleach plant vents) may achieve greater control of a specific HAP, but would achieve lesser control of other HAP's. The EPA determined that it was not cost feasible to require these technologies in addition to the floor level of control technologies. Additionally, EPA does not have sufficient data to establish pollutant specific limits for all HAP's from all emission

sources. Regarding the relative toxicity between HAP's, EPA is not authorized under section 112(d) of the Act to establish MACT using any type of toxicity weighing. In any case, the MACT standards will control all HAP's. The EPA does not believe that pollutant-specific emission limits are needed to encourage pollution prevention. The final rule contains provisions for a compliance alternative that focuses on achieving the required emissions reduction from

4-92process vent emissions by reducing the HAP content of process waters recycled or reused in various mill processes. The EPA contends that this alternative adequately encourages mills to pursue pollution prevention options since a specific control technology is not identified in the compliance option. Additionally, the effluent guidelines portion of the final rule provides incentives for adopting pollution prevention technologies.

Comment: One commenter (20,059) stated that EPA failed indicate the time period over which the percent reductions specified in the standard are to be achieved. The commenter to

(20,059) also stated that the averaging times should be short to limit cumulative exposure and to protect the public from shortterm exposure to highly toxic pollutants. Response: The language in the final rule has been clarified to identify the averaging times for the specific parameters to be monitored. The final rule specifies that mills must conduct performance tests to determine the necessary operating parameters such that the specified emission reduction will always be achieved. Consequently , a violation of the parameter(s) becomes a violation of the standards. Innovativ e pollution control systems as equivalent to MACT.
Comment: One commenter (20,102) stated that pollution prevention opportunities should be encouraged in the MACT standards. The commenter (20,102) indicated that a method to generate pollution credits by using a non-polluting technology might be a good incentive. The commenter (20,102) suggested that EPA allow mills to use a non-polluting technology to receive credit for a percentage of the pollution that would be emitted by

4-93a facility with the same capacity using conventional technology with emissions at the level of the MACT standards. Response: The EPA welcomes innovative pollution control systems and does not prohibit sources from using a different method to achieve pollution prevention or reduction. In aneffort to encourage pollution prevention and maximize the multimedia pollution prevention , EPA provided a 5-year compliance extension to kraft mills for controlling HVLC vents and oxygen delignification systems. Rationale for providing the extension was presented in the March 8 , 1996 supplemental notice. A source may petition for equivalency based on the amount of pollution reduction it achieves. The EPA must, however, base its MACT standards on the reductions achievable by existing technologies and a source must be able to demonstrate those reductions for enforcement purposes. Process modification should not be used as environmental control.
Comment: One commenter (20,039) stated that it was counterproductive to require process modifications as a means of environmental control if the existing manufacturing process can achieve the same environmental protection without the required modification. The commenter (20,039) also indicated that EPA should not set standards for points within operating systems as complex as those found in the pulp and paper industry. The commenter (20,039) added that standards should be established at the intersection of the emission or discharge and the environment. Response: The EPA disagrees with the commenter's assertion that it was counter-productive to require process modifications

4-94as a means of environmental control if the existing manufacturing process can achieve the same environmental protection without the modification. The process modification referred to by the commenter is BAT in the effluent limitation standards and guidelines for the paper-grade bleaching process. The BAT requires the substitution of Cl02 and elimination of hypochlorite. The MACT level of control for paper-grade bleaching systems is control of chloroform and the other chlorinated HAP emissions through a combination of caustic scrubbing , 100 percent Cl02 substitution, and eliminating the use of hypochlorite. The BAT requirements are at least equal to the MACT requirements. Therefore, this level of control is required for compliance. The EPA is not aware of any other control technology that would achieve the same level of control. The general provisions to part 63 [§ 63.6(g)], however, provide directions for obtaining approval of alternative control technologies. Limitations should be set in terms of total HAP oer ton of production.
Comment: Two commenters (20,027 , 20,045) suggested that the emission standards should be stated in terms of a total HAP emissions rate per ton of production, which one commenter

(20,045) stated would be similar to the effluent guidelines. Response: The final rule contains compliance alternatives that include a total HAP per ton of production emission limitation for the sulfite pulping subcategory due to the complexity of these systems and the problems that may occur when testing these sources for compliance with the standard. The final rule also includes a total HAP per ton of production

4-95emission limit for knotter and screen systems at kraft mills. This limit was included in the final rule because EPA did not have data other than mass emission rates to identify knotter and screen systems with high emissions. The EPA does not consider a total HAP per ton of production emission limitation to be necessary for other pulp and paper processes. Regarding the commenter's suggestion of using the effluent guidelines to set total HAP emission rates, the effluent limits are set for one or two points. There are many more air emission points that need to be controlled. The EPA does not have sufficient data to set pound per ton standards in most cases. Support and comment on the named streams approach.
Comment: Several commenters (IV-D2-14, IV-D2-10, IV-D2-3, IV-D2-8, IV-D2-7) agreed with the concept of selecting named vents and streams for control. One commenter (IV-D2-15) stated that EPA should list vents and streams for the sulfite pulping subcategory whose MACT floor level of control should be no control for non-halogenated HAP. The commenter (IV-D2-15) suggested the following: bleach stage washers, tower vents and seal tank vents , continuous digester steaming vessel, batch digester fill/evacuation vent, knotter vents, screen vents, decker (including thickeners and rewashers) vents, unwashed stock tanks vents , intermediate filtrate tank vents, evaporator condensate tank vents , spent sulfite liquor tanks, acid condensate storage tanks, evaporator condensates, digester blow gas condensates , digester relief gas condensates, and wastewater collection, storage , and treatment vents (except to determine the amount of methanol volatilized).

4-96Response: The EPA appreciates the commenter's support for the approach of naming streams to be controlled. The EPA does not intend to identify streams and vents not requiring control. This would make the rule more confusing and is unnecessary. The final rule specifies exactly which streams are to be controlled. Alternativ e compliance determinations.

Comment: One commenter (IV-D2-15) supported EPA's intention to allow sulfite mills t o use any combination of controls to achieve either the specified percent reduction or emission limit, where applicable. Another commenter (IV-D2-16) agreed with EPA's decision to incorporate a mas s emission rate in addition to a percent reduction standard into the final rule for sulfite mills. Response: The EPA appreciates the commenters' support. As discussed in the March 8 , 1996 supplemental notice, EPA did not intend to specify the technology to be used to satisfy the standards for sulfit e mills. Rather, a mas s emission s limit was established for selected vents and wastewater emissions. This format was intended to provide sulfite mill s with flexibility in complying with the sulfite rule. The final rule also includes

a percen t mas s reduction compliance option for additional flexibility. Sulfit e pulping

- statistica l arguments concerning emission limit s and data variability.

Comment: One commenter (IV-D2-15) stated that EPA did not establish the mass emission limits for sulfite mill s properly. The commenter stated that the mass limit s are based only on " a handful of ballpark values " and not a rigorous assessment of emission rates. The commenter also stated that the variability

4-97of the processes and scrubbers must be considered because the

sulfite mills use variations in process parameters to make a wide range of products. The commenter provided several sets of data to support concerns about process variability. The commenter also provided several statistical analysis of the data and arrived at the conclusion that the mass emission limit for selected vents from magnesium and ammonium-based mills should be greater than 2.0 lb methanol/ODTP. Two commenters (IV-D2-6, IV-D2-14) supported the argument that to take the variability inherent in the industry into account, the emission limit should not be set at the average emission level but at an upper confidence limit based on the relative standard deviation of the data sets. Response: The EPA concurs with the commenters that process variability should be incorporated into the sulfite rule mass emission limit compliance option. Establishing the appropriate mass emission limit was critical for the sulfite subcategory since a reference control technology for these mills was not identified in the standard. As discussed in the March 8, 1996 supplemental notice, EPA established mass emissions limits from selected vents and wastewater for sulfite mills. At the time the supplemental notice was published, the numerical mass limits were based on a limited amount of data. Since that time, EPA has received test data from several facilities (A-92-40, IV-Dl-96 and IV-Dl-100) documenting the variability of process emissions over time. These data were used to estimate the variability of the original

4-98data set used to develop the mass emission limits presented in the March 1996 supplemental notice. The variability analysis was based on the 99.9 percent confidence interval of the data supplied by the pulp and paper industry. This amount of variability (confidence interval), therefore, was applied to the average emission limits from the best controlled mills to develop the final emission limit. After the close of the March 8, 1996 , Federal Register supplemental notice comment period , additional information was provided to the Agency that indicated that the sodium-based sulfite pulping process is in use at some mills (A-92-40, IV-E-86, and IV-E-94). No emissions information was available for this process. However, the Agency determined , that due to the similarities in processes between calcium- and sodium-based sulfite pulping

processes, the same limit developed for calcium-based mills would be applicable to sodium-based mills. For sodium- and calcium-based sulfite pulping processes, the final emission limit is 0.44 kilograms of methanol per megagram ODP produced. For ammonium- and magnesium-based sulfite pulping processes, the final emission limit is 1.1 kilograms of methanol per megagram ODP produced. Since the emission limits include the variability allowance, they are never-to-be exceeded values. Calculation of mass percent reduction.
Comment: One commenter (IV-D2-14), noted that EPA had not determined how to measure and calculate the mass percent reduction for sulfite mills. The commenter (IV-D2-14) proposed the following approach:

4-99mass percent = 100 * (uncontrolled emissions

- controlled emissions) reduced uncontrolled emissions

where: uncontrolled emissions =

controlled emissions = the sum of methanol emitted from uncontrolled selected vents and control equipment vents for the selected vents , methanol in gases directed to combustion sources , and methanol in wastewater streams from selected vent control equipment; and

the sum of methanol emitted from control equipment vents for the selected vents, and methanol emitted from wastewater treatment that can be attributed to wastewater streams from selected vent control equipment. Response: In the March 8, 1996 supplemental notice EPA proposed to provide a mass emission limit and percent reduction option in the final rule. The EPA evaluated commenter's suggested equation and agreed the equation is appropriate for determining mass percent reduction at sulfite mills. The final rule incorporates this equation. Comoliance should be determined on test and annual averages.

Comment: One commenter (IV-D2-16) agreed that compliance for sulfite mills should be based on test averages and that compliance should not be based on the results of any one test. The commenter (IV-D2-16) also suggested that compliance with any pounds per ton emission limit should be expressed as an annual average to account for process and testing variability. Response: The determination of compliance, conducted with the initial performance test , is based on the average of three

4-100l-hour tests. During the initial performance test, the mill must select the appropriate parameters for monitoring compliance. The EPA does not concur with the commenter that an annual average would be sufficient for demonstrating continuous compliance especially since the required reporting periods are typically semi-annual or quarterly.
4.4.2 Pulping System 4.4.2. 1 Operating Scenario as Compliance Alternative.

Comment: One commenter (IV-D2-5) noted that their brownstock washers do not use condensates for washing, and as a result, the emissions are relatively low. The commenter included test data from the washers and requested that EPA allow this operating scenario as a control option in place of incineration. Response: The EPA maintains there would be significant HAP emissions from these washers even if they did not use recycled condensates (see the final emission factor document, A-95-40, IV-A-8). In addition , the final rule contains a compliance option for a HAP outlet concentration for thermal oxidizers. If emissions from the brownstock washers are less than emissions specified in the rule , then they would not need to meet the percent reduction requirement. 4.4.3 Bleaching System 4.4.3.1 Alternativ e Compliance Determinations.

Comment: Several commenters on the proposal (20,027, 20,07OAl, 20,118) requested that EPA specify alternative compliance demonstrations for the bleaching component similar to the options given for pulping and wastewater components. Several commenters (20,027, 20,057A2, 20,059, 20,07OAl, 20,071) suggested the following alternatives in addition to the proposed standard

4-101(percent removal): outlet concentration-based limits, mass per unit production-based limits , design scrubber specifications, process changes and/or stipulation that bleaching without elemental chlorine constitutes compliance. One commenter (20,071) indicated that an outlet concentration would be more desirable because the determination of scrubber efficiency could be difficult for devices run in series and/or parallel. Another commenter (20,057A2) suggested that EPA revise the bleach plant scrubber removal efficiency specification to a numerical limit of 5 ppmv chlorine. Two
commenter s (20,057A2, 20,071) indicated that the removal efficiency of 99 percent would be impossible to measure or achieve as the amount of chlorine is reduced due to Cl02 substitution.
One commenter (20,070Al) stated that EPA should establish an alternative compliance demonstration for mills that do not use elemental chlorine. The commenter (20,070Al) argued that the proposed process changes would greatly reduce the concentration of elemental chlorine at the inlet to bleach plant scrubbers which would, in turn , make demonstrating the high removal efficiency for chlorine difficult. One commenter on the March 8 , 1996 supplemental notice (IV-D2-15) supported the bleach plant applicability requirements and agreed with EPA that an outlet concentration below 10 ppmv of HAP from the scrubber exhaust is equivalent to the 99 percent reduction standard. Three commenters (IV-D2-10, IV-D2-3, IV-D2-8) supported the concept of a concentration limit on the bleaching component for control of chlorinated HAP, noting that a concentration limit in place of a percent reduction limit would

4-102not require two sampling events (inlet and outlet) and would eliminate several potential problems in compliance determination if the inlet is of very low concentration. Additionally, one commenter (IV-D2-3) asked EPA to make clear that only elemental chlorine need be measured to demonstrate compliance with the "total chlorinated HAP" control requirement. Two commenters (IV-D2-14, IV-D2-15) recommended establishing an alternative mass standard for cases where low flow systems are used and would have difficulty meeting the concentration limit. One commenter

(IV-D2-15) recommended an equivalent mass flow rate would be equal to or less than 0.01 kg/Mg air-dried pulp (ADP)

(0.025 lbs/air-dried ton of pulp (ADTP)) and provided data to support this limit. The commenters (IV-D2-14, IV-D2-25) expressed concern that bleaching systems with new low-flow vent systems would not be able to meet either the percent reduction or the outlet concentration standards. Therefore, these standards would discourage the use of new low-flow bleaching vent technologies

. Based on this concern, one commenter (IV-D2-15) advocated a chlorinated HAP mass emission limit for bleaching systems of 0.023 lb of chlorinated HAP (excluding chloroform) per ODTP produced. The commenter (IV-D2-15) claimed that a mass emission limit would not penalize new low-flow bleaching vent systems. One commenter (IV-D2-14) noted that new bleaching sequences should not be measured against the performance standards of existing bleaching sequences. The commenter (IV-D2-14) also noted that the chlorine scrubbing technology proposed should not be required.

4-103Response: At proposal , the bleach plant requirements were control of chlorinated HAP emissions (or chlorine as a surrogate) by 99 percent. This determination was based on industry data on scrubber performance (A-92-40 , II-I-24) and irrespective of the effect of process changes also required by the proposed rule. After reviewing the comments on the proposal EPA analyzed the effect of Cl02 substitution and elimination of hypochlorite use on emissions. Based on this analysis, EPA determined that, in

some cases , emissions after process changes are enacted would be lowered such that 99 percent reduction could not be achieved. As stated in the March 8 , 1996 supplemental notice, EPA determined that a standard of 10 ppmv of total chlorinated HAP (other than chloroform) is equivalent to the outlet of scrubbers achieving 99 percent removal (A-92-40, II-I-24). Chlorine may be used as a surrogate. Regarding the commenter's request for a mass emission limit standard, EPA reviewed the information provided by the commenter and emission information from sampling tests conducted on bleaching systems. Based on available data, the Agency has concluded that low-flow bleaching vent systems can achieve the 99 percent reduction and the 10 ppmv outlet concentration requirements for total chlorinated HAP (other than chloroform). Based on a review of the information provided by the commenter and the available data on bleaching system emissions, the Agency has concluded that the commenters recommended mass emission limit of 0.023 lb of chlorinated HAP (excluding chloroform) per ODTP produced is too high. The Agency evaluated the available data used to develop the percent reduction and outlet concentration requirements for bleaching systems (A-92-40, II-I-24). From this

4-104evaluation , the Agency determined that a scrubber outlet mass emission rate of 0.001 kg of total chlorinated HAP (other than chloroform) per Mg ODP produced (0.002 lb/ODTP) would provide reductions equivalent to 99 percent reduction standard (A-92-40, IV-B-29). The mass emission limit of 0.001 kg of chlorinated HAP (other than chloroform) per Mg ODP produced represents a mass emission limit achievable by all units that also achieved 99 percent reduction of chlorine. Furthermore, the available data show that some of the scrubbers achieving the 99 percent chlorine reduction standard , and the 10 ppmv outlet concentration limit, were also operating on low-flow bleaching vent systems. For the final rule , the Agency has provided a mass emission limit option for bleaching systems of 0.001 kg of chlorinated HAP (excluding chloroform) per Mg ODP produced (0.002 lb/ODTP). The Agency maintains that this option allows more flexibility for sources affected by this rule , does not penalize bleaching systems operating with low-flow technology, and will provide reductions in chlorinated HAP emissions (other than chloroform) equivalent to the 99 percent reduction standard. 4.4.4 Process Wastewater System 4.4.4.1 Design steam stripper

Comment: Two commenters (20,000 , 20,056) recommended that a parametric design steam stripper not be specified in the standards. One commenter (20,000) indicated that if mills cannot install a steam stripper in the manner they determine to be most cost effective there will be a heavy penalty in energy costs and CO2 emissions. The other commenter (20,056) recommended that each mill be allowed to develop engineering calculations or

4-105perform testing to indicate stripper operating ranges which correspond to 90 percent reduction. Response: The EPA agrees with the commenters. In an effort to provide sources with flexibility to comply with the wastewater requirements the design steam stripper specified in the proposed regulation is not required in the final rule. Sources are free to design their own steam strippers as long as they are able to

mee t the required control level (92 percent reduction, mass removal, or outlet concentration). Support for compliance alternatives.

Comment: One commenter (IV-D2-15) supported the inclusion of other compliance options for the treatment of pulping process condensates, namely , recycling to enclosed equipment or hardpiping to a mill' s biological treatment plant. The commenter also supported EPA's decision to allow mills t o choose any wastewater treatment device for compliance purposes as long as either the percent reduction, mas s removal, or outlet concentration i s met. One commenter (IV-D2-16) suggested requiring all pulping and bleaching effluents be sent to a well-operated secondary treatment plant , realizing that a well controlled operation of this type will perform as well as possible to biodegrade methanol and related compounds. Response: The EPA appreciates the commenters' support of compliance alternatives. Hardpiping the affected streams to biological treatment is a compliance option for kraft pulping wastewater streams in the final rule. The MACT floor level of control for non-kraft wastewater and bleaching systems wastewater is no control.

4-106Miscellaneous clarifications to the wastewater rule.

Comment: One commenter (20,027) requested that EPA include the following requirements in the process wastewater standards for sulfite mills: (1) an enclosed transport system is not
needed for a wastewater stream that has been treated to below
500 ppmw HAP by one of the proposed compliance options; and (2) after the mandated 90 percent HAP reduction has occurred, a treated process wastewater stream is acceptable for reuse anywhere within the mill or for disposal in open sewers. Response: At proposal , EPA did not establish a sulfite subcategory. Sulfite mills were required to meet the kraft mill requirements , including wastewater. Since proposal, EPA has developed a sulfite subcategory. The EPA determined that control of sulfite wastewater was not in the MACT floor level of control, and it was cost infeasible to go beyond the floor level of control. Therefore, the final rule does not include wastewater requirements for sulfite mills. However, the HAP emissions from any effluent associated with any device used to reduce vent HAP emissions must be included in the selected vent emission limit. Air emissions from biological treatment are unmeasurable.

Comment: One commenter (20,057A2) suggested that the 90 percent removal efficiency for biological treatment systems be modified to pertain only to a 90 percent efficiency in water, and should exclude de minimis air emissions. The commenter (20,057A2) indicated that procedures do not exist to measure d e minimis air emissions from biological treatment. Response: In the final rule, biological systems at kraft mills are required to remove 92 percent of HAP in the wastewater system. This efficiency was revised from 90 percent based on

4-107EPA's re-analysis of steam stripping performance (A-92-40, IV-B-l0). Kraft mills are required to demonstrate that the removal is actually destruction of the HAP's rather than HAP reduction due to volatilization to the air, adsorption, or HAP loadings lost in discharge. The EPA considers this a necessary requirement in order to ensure that kraft mills choosing the biological treatment option are achieving the requested HAP reduction. Methanol from wastewater should not be included in overall emission requirements.

Comment: One commenter (IV-D2-16) strongly disagreed with EPA's proposal to include methanol emissions from the wastewater treatment plant in its overall emission requirements. The commenter (IV-D2-16) asserted that there is no practical or costeffective way to change the methanol removal efficiency of the wastewater treatment system and noted that the only "measurement" of the system output is determined by a model. The commenter

(IV-D2-16) requested that if a model is required, then the model parameters must be spelled out explicitly to that they will not change in the future. Response: The wastewater control requirements are only for kraft mills. Biological treatment of kraft wastewater is not required in the final rule , but it is one of the control options a mill can choose. If a mill chooses the biological treatment option, it will need to account for the HAP emissions from the biological treatment system. The EPA did not specify parameters for estimating emissions using emission models because the parameters need to be developed on a site-specific basis.

4-108Regarding the methanol removal efficiency of biological treatment systems, data analyzed by EPA (A-92-40, IV-Dl-75) indicate that a well-operated biological treatment system can easily achieve a methanol destruction greater than 92 percent. Therefore, the methanol removal efficiency of biological treatment systems does not need to be changed. Site-specific basis for compliance determination.

Comment: One commenter (IV-D2-8), noting the site-specific variability in model inputs to determine volatilization rates, asserted that EPA must allow facilities to develop site-specific rates to determine compliance. The commenter (IV-D2-8) , noting the difficulty of such an implementation, recommended deleting the emissions limit requirement for wastewater systems. Another commenter (IV-D2-16) recommended that EPA only regulate process vents and not regulate wastewater treatment plants. Response: The EPA disagrees with the commenters. A MACT floor level of control analysis conducted on the kraft pulping process condensate streams shows that the average emission limitation is control of specific condensate streams with a steam stripper (A-92-40, IV-B-8). Therefore, the kraft pulping process condensate streams from the digester system, turpentine recovery system, and the weak liquor feed stages in the evaporator system are required to be controlled. Additionally , EPA has decided to name streams to be controlled in the final rule (see March 8, 1996 supplemental notice for a detailed discussion); therefore, no concentration or flow cut-offs have been included in the rule. The EPA considers this change to simplify compliance determination.

4-109The EPA also believes that it has provided sufficient

alternatives in the wastewater requirements (hardpiping, steam stripping achieving 92 percent reduction, or mass limit or concentration limit) to provide sources with flexibility to meet the standard.

4-1105.0 PULPING AREA

5.1 CONTROL OPTIONS 5.1.1 General
Comment: One commenter (20,081) objected to EPA's listing of preferential control technologies in the December 17, 1993 proposed rule. The commenter (20,081) contended that biofiltration should be included as a viable alternative and listed as one of the preferred technologies. The commenter (20,08lAl, 20,081A2) provided several reasons why biofiltration should be used instead of incineration and condensation, and provided comparisons of cost for the technologies. The commenter

(20,08lAl, 20,081A2) also provided control efficiencies for a pilot-scale test of biofiltration. Two commenters (20,029 , 20,041) requested that other types of oxidizers be evaluated , such as regenerative thermal oxidizers and catalytic oxidizers for controlling emissions from the pulping area. The commenters (20,029 , 20,041) claimed that these devices could achieve the same reduction in emissions as thermal incinerators and may be less costly. Response: Based on test data , and information summarized from the 1992 voluntary MACT survey (A-92-40, IV-B-16), a level of control was selected as MACT for each pulping subcategory. These control levels were expressed as percent reductions or

5-lemission limits. Any control technology that can be demonstrated to meet the requirements specified in the rule can be used. The rule provides several options for demonstrating compliance. For example , owners or operators of kraft, semichemical and soda mills may comply with the pulping provisions by controlling emissions from named streams by 98 percent, or by routing named vents to lime kilns, boilers, or to a thermal oxidizer meeting specified requirements. These control technologies are control options in the rule because they have been demonstrated to achieve at least 98 percent control when operated under the specified conditions. Compliance testing to demonstrate 98 percent reduction is not required when using these technologies. Therefore, specifying these technologies reduces the compliance burden. However, any alternative technology that can be demonstrated to achieve 98 percent control may be used to comply with the rule. In cases where the rule specifies a design, equipment, or operating standard , 40 CFR 63.6(g) includes procedures for obtaining approval by the Administrator of the use of alternative control technologies that can be demonstrated to perform as well

as, or better than , a technology specified in a rule.

Comment: One commenter (20,072) recommended that MACT for soda mill pulping components be limited to 95 percent methanol capture of digester blow gases, screen room closure, using mill water supply for the brownstock washers, and no internal recycling of digester and highly contaminated evaporator condensates which will be directed to a mill's wastewater treatment system. The commenter (20,072) provided estimates for their proposed control of soda mill pulping components, which

5-2they estimate would reduce emissions by 85 percent at an estimated capital cost of 4.1 million dollars. The commenter

(20,072) stated that their cost estimates are substantially lower than EPA's estimate. The commenter (20,072) provided costeffectiveness data. Response: Data that EPA has collected on soda mills indicate that none are currently controlling pulping or

wastewater vents. Information supplied since proposal of the rule has allowed EPA to characterize emissions and possible emission controls for soda mills. Based on this new information, EPA has determined that controlling the LVHC system is reasonable considering the cost and other impacts; controlling additional vent streams beyond the LVHC system or controlling the wastewater collection and treatment system is not reasonable considering costs and impacts. Information submitted by the industry supports EPA's conclusions (A-92-40, IV-Dl-77, IV-Dl-90). Therefore , the final rule requires that owners or operators of soda mills control only the LVHC vents at existing mills. Commenters are referred to supporting memorandum (A-92-40, IV-B-13) and chapter 20 of this document for a detailed discussion of the control options and impacts analyses. Control cost estimates provided by the commenters outlined results for selected control scenarios based on using mill water supply for the pulp washers. This option would increase mill wastewater discharge and be counter to EPA's plan to achieve a "closed mill " from an effluent standpoint. The commenters' recommended controls did not address all equipment included in the LVHC system. Other equipment in the LVHC system, such as evaporators , may emit significant HAP's. The EPA lacked

5-3sufficient information to verify the commenter's claim that their control suggestions would achieve 85 percent reductions in HAP emissions. The EPA determined that control of the LVHC system

(of which the digester flow gases are only a part) will result in a significant amount of HAP emission reduction at a reasonable cost (see discussion in March 8 , 1996 supplemental notice).

Comment: Two commenters (20,053A1, 20,018) were opposed to the floor including control of HVLC vents in the pulping system, specifically citing brownstock washer vents, oxygen delignification vents , and vents in the bleaching process prior to the addition of chlorinated bleaching agents. (These bleaching stages were included in the pulping component definition at proposal.) Both commenters supported their argument by pointing out potential drawbacks of controlling these

HVLC vents , citing secondary impacts such as SO 2 and NO x emissions, plus additional fuel requirements for incinerator operation. One commenter (20,053Al) argued that the proposed emissions standards for the bleaching and wastewater components, combined with collection and incineration of LVHC gas streams within the pulping system , would result in substantial reductions in HAP emissions. One commenter (20,018) contended that the current state-of-the-art kraft mill does not collect and incinerate the oxygen stage vents. Response: The NESHAP are required by the Act to reflect (at a minimum) the average emission limitation achieved by the bestcontrolled 12 percent of sources. As stated in the December 17, 1993 proposal , brownstock washers , oxygen delignification units, and bleach systems are controlled at the floor for kraft mills. A reevaluation of this floor determination was conducted using

5-4data received since proposal. These data indicated that the best-controlled kraft mills control HVLC vents, including vents on pulp washing systems, decker systems , oxygen delignification systems, and knotter and screen systems. The best-controlled mills control chlorinated HAP's from the bleaching system vents using caustic scrubbers and process modifications. Data indicate that the best-controlled bleaching systems do not control nonchlorinate d HAP's; therefore , control of non-chlorinated HAP's at bleach stages is not required in the rule. Commenters are referred to supporting memoranda (A-92-40, IV-B-8, IV-B-16) and chapter 20 of this document for a detailed discussion of these analyses. The Act requires cost and environmental impacts to be considered only when going beyond the floor level of control. Therefore, SO 2 and NO x generation , and increased fuel use were not considered in determining the MACT floor level of control, but were considered when evaluating controls beyond the floor. Readers are referred to the economics assessment (A-92-40, V-A-2) for a detailed discussion of the benefits and impacts of the final rule.

Comment: Three commenters (20,027, 20,0531Al, 20,054A2) expressed concern over including oxygen delignification in the pulping system , rather than as part of the bleaching system. Two commenters (20,027 , 20,054A2) stated that because oxygen is a bleaching agent , oxygen delignification may be more appropriately considered as part of the bleaching system. On e commenter

(20,053Al) stated that , based on the proposed bleaching system definition , TCF mills that do not apply chlorine or chlorinecontaining compounds at any stage in the bleaching system do not

5-5have a bleaching component. Thus, all bleach plant emissions would apparently be regulated under the pulping system. The

commenter (20,053Al) indicated that EPA should identify a point in the TCF bleaching process where the pulping system ends and the bleaching system begins. Response: Oxygen delignification was included in the pulping component because of similar control technologies and condensate re-use practices (e.g., much of the emissions from the oxygen delignification system are attributable to pulping-area condensates applied to the post-oxygen delignification washers). For the final rule , oxygen delignification is still being defined as part of the pulping component. Information submitted by two commenters (A-92-40, IV-Dl-97 , IV-Dl-71) after the close of the comment period on the proposed rule indicates that the commenters have reversed their position on this issue. The commenters agreed with EPA that oxygen delignification should remain in the pulping component due to the water recycling that occurs between the pulping component and the post-oxygen delignification washers. The commenters ' reaction to the proposed rule may have been due to the historical classification by the pulp and paper industry of oxygen delignification as part of the bleach plant. The inclusion of oxygen delignification in the pulping component may have caused confusion. The final rule specifies vent streams that are required to be controlled, including oxygen delignification system vents. Therefore, whether oxygen delignification is defined as part of the pulping system or bleaching system does not affect the control requirements.

5-6The final rule sets standards only for chloroform and other chlorinate d HAP's in the bleaching system; therefore, TCF mills would already be in compliance with the bleaching system standards. For mills utilizing TCF bleaching processes along with an oxygen delignification stage , EPA defines the end of the pulping section as the screened stock chest that follows the oxygen delignification unit. Pulping processes upstream of the screened stock chest would be subject to NESHAP requirements for pulping

processes , while processes downstream of the stock chest would be subject to NESHAP requirements for bleaching.
5.1.2 Existing Combustion Devices

Comment: Several commenters (20,011, 20,027, 20,018, 20,118) maintaine d that mills lack the existing combustion capacity to handl e the quantities of gases that would require incineration unde r the December 19, 1993 proposed rule. One commenter (20,018 ) maintained that current combustion units are operating at thei r capacity. One commenter (20,027) indicated that combustion o f HVLC streams would increase the sensible heat loss and therefor e decrease steam production capacity in existing power boilers. One commenter (20,118) added that many mills are steam limited and would have to add new boiler or incinerator capacity to burn additional HAP's. The commenter (20,118) concluded that EPA must support their assumptions on existing combustion capacities with data. One commenter (20,027) supported the use of boilers, lime kilns, and recovery furnaces as appropriate combustion units for the destruction of HAP's. However, the commenter (20,027) did express concern over HVLC flow variations and how they would affect boiler stability. The

5-7commenter indicated that this was of greater concern in semichemical and soda pulp mills where no alternative combustion devices are present. Response: The capacity concerns expressed by several commenters may have been due to the fact that the rule, as originally proposed , required the control of all vent streams except those with very low volume and low concentrations. Therefore, the commenters may have concluded that most streams in the pulping system were required to be controlled. The March 8, 1996 supplemental notice specifically defined the vent streams that are required to be controlled. The EPA has maintained the approach of naming specific systems to be controlled in the final rule. This approach will reduce confusion as to which equipment needs to be considered for control , and will alleviate many of th e commenter's concerns on capacity. An analysis of the effects of HVLC streams being combusted in an existing power boiler determined that a 5 percent increase in fuel usage was needed to control the HVLC (A-92-40, II-B-31). The results of this analysis were based on the assumption that the boiler would maintain the same level of heat release, thus the same level of steam production. In response to comments received after proposal, EPA also conducted surveys with several mills regarding their capacity to combust additional vent streams at existing combustion devices. Results of the survey (A-92-40 , IV-E-93) indicate that two-thirds of the surveyed mills have the capacity in the existing combustion devices to handle combustion of the named HVLC

streams. The remaining one-third would construct a thermal oxidizer. The assumption that two-thirds of all mills will use

5-8existing combustion devices , and one-third will use new thermal oxidizers to control vent streams was used in determining the national cost and environmental impacts of the final rule (see chapter 20 of this document). Regarding the commenter's concern about HVLC system vent flow variability , EPA does not expect there to be significant variability in HVLC system flows such that the operation of the power boiler or lime kiln would be disrupted. However, if a mill encounters significant HVLC system flow rate variability that would affect the performance of the boiler, these occurrences should be addressed in the downtime and malfunction allowances provided in the final rule. The final rule does not require control of HVLC vents at existing semi-chemical and soda mills. Currently, only LVHC systems at semi-chemical mills and soda mills are being controlled.

Comment: Two commenters (20,115A2, 20,054A2) contended that introducing LVHC gases into a recovery boiler could result in a smelt water explosion due to moisture entrained in the gases.

On e commenter (20,054A2) stated that combustion of LVHC gases in a recovery furnace is not recommended by the Black Liquor Recovery Boiler Advisory Committee. Response: The EPA understands the commenters' concerns, and agrees that a possibility exists that introduction of some vent gases into the recovery boiler could have adverse results. However, information supplied in industry questionnaire responses indicates that some mills are successfully routing LVHC gases to recovery furnaces (A-92-40, IV-B-8, IV-B-16). The proposed and final rule do not require vent streams to be combusted in recovery furnaces. If a facility is concerned with the safety

5-9issues associated with controlling vent streams in a recovery furnace, the facility can choose to control the vent streams in the other acceptable control devices specified in the rule.

Comment: Several commenters (20,011, 20,027, 20,115A2, 20,118) opposed the proposed compliance option for existing combustion devices that required vent gases to be introduced with the primary fuel or into the flame zone. One commenter (20,027) asserted that this requirement did not accurately reflect the floor level of control since NCG systems utilize a separate burner or introduce the HVLC streams with the combustion air. Other commenters (20,011 , 20,118) contended that the feasibility of introducing vent gases in the primary fuel or into the flame zone of a combustion device was not adequately evaluated and may not be appropriate in all cases

. One commenter (20,118) cited their mill as an example ; it introduced TRS compounds separately into boilers and lime kilns, not with primary fuels. One commenter (IV-D2-15) recommended allowing the HAP laden gas streams to be introduced with the "air supply" in order to control emissions via a combustion device, since most mills do not currently introduce such gases with the primary fuel or into the flame zone. Response: The proposed rule provided owners or operators the option to achieve compliance with the combustion requirements by introducing vent streams with the primary fuel or into the flame zone. The intent of this stipulation in the proposed rule was to prevent circumvention of the combustion requirements by introducing the vent gases at a stage that would not allow for complete combustion. The requirement to introduce the vent streams with the primary fuel or into the flame zone is still

5-10necessary. Therefore, these requirements are included in the final rule. The EPA reference s "Reactor Processes in the Synthetic Organic Chemical Manufacturing Industry--Background Information for Promulgated Standards," EPA-450/3-90-016b, March 1993 to support this conclusion. This document provides information that shows when vent streams are introduced into the flame zone , over 98 percent reduction is achieved. However, when vent streams are not introduced into the flame zone, complete combustion is uncertain.

Comment: Several commenters (20,011, 20,059, 20,102) disagreed with the 98 percent control requirement for pulping

vents. One commenter (20,011) stated that there were no data to indicate existing pulp mill combustion devices are capable of achieving 98 percent HAP removal efficiency or a 20 ppmv HAP incinerator outlet concentration. One commenter (20,102) opposed using the 98 percent control requirement for incinerators for all toxic compounds because some HAP's may be more carcinogenic or more toxic than others and should be controlled more stringently. One commenter (20,059) asserted that EPA provided no evidence to support the contention that a 98 percent control efficiency for vents is the highest that can universally be achieved by incineration. The commenter (20,059) contended that with proper operating procedures and maintenance, a higher level of emissions reductions is achievable. The commenter (20,059) also stated that EPA had not evaluated the relative effectiveness of alternate combustion devices such as flares, lime kilns, or chemical recovery furnaces. The commenter (20,059) contended that EPA had not explored variability in load size and

5-11composition common in the paper industry. Th e commenter (20,059) stated that this analysis could assess performance or establish more specific control requirements. Response: Information from industry surveys showed that the best-controlled kraft mills route vent streams to combustion devices (A-92-40, IV-B-8, IV-B-16). Historically, EPA has conservatively assumed that combustion devices such as thermal oxidizers, power boilers , and lime kilns achieve 98 percent destruction of total organic compounds based on specified temperatures and residence times (A-79-32, II-B-31). Data provided by industry indicates that existing thermal oxidizers can achieve 98 percent destruction of HAP's or reduce HAP emissions to 20 ppmv at 10 percent oxygen (A-92-40, IV-B-18). Some devices may achieve higher destruction efficiencies for some compounds depending on various mill-specific factors (such as operation, fuel use, manufacturer, etc.). These factors cannot generally be duplicated at all mills. Additionally, a study of VOC reduction in incinerators concluded that a 98 percent reduction of VOC is the highest control level that is consistently achievable by an incinerator considering the range of vent stream conditions that are likely to occur (A-79-32, II-B-31). 5.1.3 Design Incinerators
Comment: Several commenters (20,000, 20,011, 20,027, 20,041, 20,051, 20,056, 20,057A2, 20,070Al, 20,074, 20,118, 20,144, IV-D2-11) objected to the design incinerator specifications in the December 17, 1993 proposed rule. Most of the commenters (20,000, 20,011, 20,027, 20,041, 20,051, 20,057A2, 20,070A1, 20,074 , 20,118) claimed that the incinerator

5-12requirements were erroneously based on the SOCMI industry incinerator requirements of 1600 OF and 0.72 seconds residence time rather than on the existing kraft pulp mill NSPS standards for TRS. Other commenters (20,041, 20,102, 20,129) claimed that the design incinerator parameters are inadequate to ensure high combustion of HAP's and should be more stringent. Several commenters (20,027, 20,051, 20,056, 20,057A2, 20,07OAl, 20,074, 20,118, 20,144, IV-D2-11, IV-D2-3) contended that EPA should change the incinerator operating provisions to the NSPS requirements of 1200 OF and 0.5 seconds residence time.
One commenter (20,057A2) recommended that the NSPS operating requirements and the alternative 20 ppmv HAP emissions limit be included in the rule to ensure that current incinerators can be used for continued control of LVHC gases. The commenter

(20,057A2) stated that this would minimize new incinerator costs by maintaining the viability of existing equipment. One commenter (IV-D2-11) noted that if the 1600 OF and 0.75 second criteria are promulgated for LVHC incinerators, the n the criteria should only apply to new units so existing incinerators will not have to be replaced. Two commenters (20,000 , 20,070Al) provided examples of incinerators that achieve high destruction efficiencies, while operating at a temperature of 815 OC (1500 OF) and a retention time of 0.15 seconds. One commenter (20,070Al) provided data from tests conducted at a mill that showed methanol destruction greater than 99 percent. The commenter (20,070Al) stated that preliminary results indicate that destruction efficiencies of 99 percent are being achieved for TRS and methanol on gas streams having significant concentrations. The commenter (20,070Al)

5-13referred to NCASI for further data on HAP control efficiencies. One commenter (20,000) claimed that the combustion efficiency was maintained in these incinerators by using a high-intensity combustion chamber. The chamber ensures that pollutants are thoroughly mixed into the flame. Two commenters (20,102 , 20,129) claimed that the design incinerator operating requirements do not offer a significant margin of safety for high combustion efficiency combustion of

HAP'S. The commenters (20,102 , 20,129) recommended requiring an incinerator temperature of 1800 OF and a residence time of 1 second. Another commenter (20,111 ) indicated that a temperature of 1600 OF does not provide an adequate margin of safety against the formation of dioxin and should therefore be re-evaluated. Three commenters (20,102, 20,129, 20,144) stated that a higher combustion efficiency should be specified, such as a minimum of 99.9 percent or 100 ppm CO corrected to 7 percent

oxygen. One commenter (20,129) noted that these are the requirements for thermal destruction of HAP's in the RCRA regulations. One commenter (20,144) suggested that the rule allow streams to be segregated , and require those streams containing chlorinated HAP's to have a higher temperature and residence time, but those that do not contain chlorinated HAP's to meet the NSPS required temperature and residence time. Another commenter

(20,041) requested that the proposed design incinerator requirements be deleted from the final rule. The commenter

(20,041) contended that the design incinerator operation provisions in the proposal were based on the average operating parameters for thermal incinerators and concluded that some HAP's

5-14would be destroyed while others would require higher time/temperature conditions to achieve the desired destruction

rate. The commenter (20,041) cited methyl ethyl ketone as an example; methyl ethyl ketone requires 1 second and 1780 OF to achieve 99 percent destruction. The commenter (20,041) concluded that a properly designed thermal incinerator would reduce HAP emissions by 98 percent , but indicated that an incinerator meeting the proposed operating requirements would not. Response: The final rule retains the incinerator operating parameters of 1600 OF and 0.75 seconds residence time. The EPA has decided not to change the proposed design incinerator operating parameters for the final rule because the parameters are necessary to meet the MACT floor level of control. The EPA would first like to clarify that the final rule does not limit owners or operators of incinerators to operate at the specified temperatures and residence times. Any control device that is demonstrated to achieve 98 percent destruction of HAP's or any thermal oxidizer that reduces HAP emissions to a concentration of 20 ppmv at 10 percent oxygen will comply with the rule. (The outlet concentration limit option has changed from 20 ppmv at 3 percent oxygen, at proposal , to 20 ppmv at 10 percent oxygen. This issue is discussed later in this section.) The 98 percent destruction requirement represents the control level achieved by well-operated combustion devices. The 20 ppmv limit represents the performance achieved by well-operated combustion devices on low concentration vent streams. Second, EPA has made this part of the rule as flexible as possible while still achieving a level of control reflecting

MACT. In the December 17 , 1993 proposal and in this final rule,

5-15EPA developed compliance alternatives in order to reduce the compliance testing burden. The compliance alternatives (i.e., operating thermal oxidizers at a temperature of 1,600 OF and a residence time of 0.75 seconds) were developed to ensure that the thermal oxidizers perform at a level that would meet the destruction efficiency requirements. Information in industry survey (A-92-40, IV-B-8, IV-B-16) responses indicates that the best-controlled sources are controlling vent streams using an existing boiler as a combustion device. Power boilers operate at much higher temperatures and residence times than the incinerators required in the kraft mill NSPS and can achieve at least 98 percent destruction of HAP's. The incinerator operating parameters of 1600 OF and 0.75 seconds residence time required in the proposed rule are based on previous Agency studies (A-79-32, II-B-31) which show that these conditions are necessary to achieve 98 percent destruction of

HAP's. However, the NSPS operating parameters (1,200 OF and 0.5 seconds residence time) do not destroy HAP's to this extent. The EPA's analysis indicates that while the NSPS requirements of 1200 OF and 0.5 seconds residence time are sufficient to achieve 98 percent destruction of TRS compounds, kinetic calculations for methanol (the majority of HAP in pulping vent gases) show that the NSPS criteria will not provide the required 98 percent reduction of HAP's (A-92-40, IV-B-18). Additionally, EPA evaluated incinerator performance data submitted by industry (A-92-40, IV-J-33). The data indicated that the NSPS operating parameters were not sufficient for achieving 98 percent destruction of methanol. This conclusion was reached by EPA since the operating conditions (i.e.,

5-16temperature and residence time) of the incinerators that achieved 98 percent methanol destruction were greater than the levels specified in the kraft NSPS. Therefore, the NSPS specifications will not meet the requirements of MACT for new and existing

sources. Information supplied by industry does show that some existing thermal oxidizers are currently meeting the 98 percent reduction or 20 ppmv standard (A-92-40, IV-B-18). Historically, the EPA has conservatively assumed that combustion devices such as incinerators, power boilers, and lime kilns achieve 98 percent destruction of total organic compounds based on specified temperatures and residence times (A-79-32, II-B-31). Some devices can achieve higher destruction efficiencies for some compounds due to various mill specific factors (such as operation, fuel use, manufacturer, etc.). Due to the variability of combustion devices, it would not be appropriate to require higher destruction efficiencies for all devices based on unique characteristics of control devices at some mills. The EPA maintains that no significant amount of dioxin will be generated from the combustion of these vent gases. There is no significant level of chlorine in the pulping vents. The final rule does not require bleaching vents, which do contain chlorine, to be routed to a combustion device.

Comment: Three commenters (20,027, 20,07OAl, IV-D2-11) disagreed with the requirement to correct gas concentrations to 3 percent oxygen. Two commenters (20,027, 20,070Al) did not consider any oxygen correction factor (other than the normal oxygen content of the gas stream) to be justified for incineration. On e commenter (20,027) stated that normal oxygen

5-17content was 10 percent. Two commenters (20,07OAl, IV-D2-11) stated that for HVLC streams , the oxygen content can be between 15 to 20 percent prior to incineration and methanol content can be less than 100 ppm. The commenters (20,07OAl, IV-D2-11) claimed that a correction to 3 percent oxygen could reduce the 20 ppmv standard for such streams to less than 5 ppmv after correction. One commenter (20,070Al) stated that for low concentration substances in high volume gas streams, such as HAP/methanol in brownstock washer hood gases, a 10 percent correction may be appropriate. The commenter (20,070Al) asserted that the correction to 3 percent oxygen would be appropriate for combustion units that efficiently operate at 3 percent oxygen and are burning other fuels , or in cases where the gas stream has a high Btu value. Response: The final rule does not require mills to operate combustion devices at a specified percent oxygen content. The oxygen correction factor is used as a means of standardizing concentration measurements to demonstrate compliance. This standardization ensures that sources are not complying with the concentration limit by artificially reducing the concentration by introducing excess air into the vent stream. The correction factor at proposal was based on previous EPA studies for other industries. Th e EP A has re-evaluated the 3 percent correction factor to ensure that it is appropriate for the pulp and paper industry. Based on thermodynamic calculations of excess air and flame temperature relations, EPA has decided to change the oxygen correction factor to 10 percent in the final rule (A-92-40, IV-B-19). Therefore, the final rule allows

5-18combustion devices to be in compliance if they reduce HAP concentrations to 20 ppmv at 10 percent oxygen. 5.1.4 Enclosures and Gas Collection Systems
Comment: One commenter (20,027) pointed out that the assumed closed vent system requirements for the pulping area are not practiced at any existing mill. The commenter stressed that brownstock washers could not be tightly sealed due to the need for frequent quality control sampling of brownstock. The commenter (20,027) reported that EPA overestimated the extent to which a brownstock washer can be enclosed and the amount of gas flow that will be conveyed to a combustion device. Response: Information received from an industry survey (A-92-40 , II-D-27) shows that several pulp mills have successfully enclosed brown stock washers (A-92-40, IV-B-8, IV-B-16). Based on this information , EPA has decided to keep the brownstock washer enclosure requirements in the final rule. The EPA does not intend to prevent pulp sampling activities with the enclosure requirement. Mills which have successfully enclosed brownstock washers have access areas to allow for pulp sampling. At mills with negative pressure enclosures, access areas do not present emission leak concerns; however , access areas on positive pressure enclosures will still have to pass the leak test requirements.

Comment: One commenter (20,115A2) claimed that there is no way to enclose the inlet to the lime kiln and simultaneously direct air through the product coolers , a necessary conservation step, while allowing the free flow of product lime out of the kiln.

5-19Response: The commenter appears to have misinterpreted the enclosure requirement. Under this regulation, the lime kiln is not part of the pulping component and, therefore, not required to be enclosed. The lime kiln was listed as an alternative control device for vent stream gases in the pulping system.

Comment: One commenter (20,110) supported extending the gas collection techniques required for kraft mills to the non-kraft sector of the industry , particularly to control the potential for heavy sulfur dioxide emissions during batch digester blowdowns. Response: The proposed rule requires that kraft, soda, semi-chemical , and sulfite mills comply with the gas collection requirements. Although EPA subcategorized mills by pulp type for the final rule , the gas collection and control requirements are still applicable to all sources that are required to be controlled, which includes batch digesters at sulfite mills. 5.2 COSTS
Comment: Two commenters (20,000 , 20,070Al) contended that the proposed incinerator design criteria would increase costs unreasonably. One commenter (20,000) contended that proposed design criteria would require existing incinerators to be increased in size by a factor of five, thereby limiting improvements to existing methods , precluding development of other technologies to control HAP's , and adding unnecessary costs to incinerators. Another commenter (20,070Al) stated that the proposed design fuel costs. Response: of incinerators standards would require higher capital costs and

The final rule does not limit owners or operators to operate at the specified temperatures and residence times. The final rule allows any combustion device

5-20that can be demonstrated to achieve 98 percent destruction of HAP's or any thermal oxidizer that reduces HAP emissions to a concentration of 20 ppmv at 10 percent oxygen. Information supplied by the pulp and paper industry shows that many of the existing thermal oxidizers can meet either the 98 percent destruction option or the 20 ppmv outlet concentration (A-92-40, IV-J-33). Therefore, no additional cost or design is necessary for these thermal oxidizers. The capacity concerns expressed by several commenters to the proposed rule may have been due to the fact that the proposed rule required all vent streams to be controlled, except those with very low flow and low concentrations. Therefore, the commenters may have concluded that all pulping vents were required to be controlled. The March 8, 1996 supplemental notice specifically defined the vent streams that are required to be controlled. The specific list will reduce initial estimates of gas volume routed for combustion. Additionally, EPA conducted surveys (A-92-40, IV-E-93) with several mills regarding their capacity to combust additional vents streams at existing boilers. Results of the survey indicate that two-thirds of the surveyed mills have the capacity in the existing boilers to handle combustion of the named HVLC streams, and therefore , would not need to construct thermal oxidizers. The remaining one-third would construct thermal oxidizers. This information was used in determining the national cost impacts of the final rule (see chapter 20 of this document and A-92-40, IV-B-13).
Comment: Several commenters (20,011, 20,014, 20,027, 20,071, 20,123Al) claimed that EPA had significantly

5-21underestimated the cost of controlling pulping emissions and should reassess the cost for the promulgation package. Several commenters (20,014, 20,027, 20,057A2, 20,123A1, 20,123A7) asserted that the costs for gas collection and treatment systems were significantly underestimated. Three commenters (20,014, 20,027, 20,123A7) specified that EPA had underestimated the cost of ductwork. These commenters (20,014, 20,027, 20,123A7) asserted that using stainless steel ductwork was standard for the industry and EPA underestimated the cost by not assuming the use of stainless steel duct work. Three commenters (20,027, 20,057A2, 20,118) contended that EPA incorrectly predicted that there would be no fuel penalty for combusting HVLC vent streams and did not include the costs of control valves for gas collection systems which are essential for pulp and paper operations. Response: In response to public comments, the cost estimates for the gas collection systems were revised. The gas collection system used in estimating cost impacts of the final rule included stainless steel ductwork, fans, a mist eliminator, a condenser , flame arrestors , liquid sampling taps, a condensate storage tank , and rupture disks. Additional equipment (mist eliminator, condenser , condensate storage tank) was added for reducing moisture in the vent stream prior to combustion

(A-92-40, IV-B-13). The revised cost impacts also included the cost of 1,500 feet of stainless steel ductwork to an existing combustion device and 500 feet to a new stand-alone combustion device. The duct lengths were based on engineering judgement and information collected during several site visits to pulp and paper mills.

5-22The EPA considers these duct lengths to sufficiently characterize the lengths of ducts at typical pulp and paper mills. Energy and auxiliary fuel costs were also accounted for in the revised impacts. The costs and equipment designs were based on algorithms in the Office of Air Quality , Planning and Standards (OAQPS) Control Cost Manual (OCCM). These algorithms have been widely used in developing other NESHAP , and have been used by Federal, State, and local air pollution control agencies to estimate costs.

Comment: One commenter (20,123A7) stated that EPA's assumption that indirect costs are included in the vendor's cost estimate may be erroneous. The commenter (20,123A7) provided cost factors for installed cost and asserted that indirect costs are generally 35 to 50 percent of the total installed cost depending on the client and the type of estimate. Response: For consistency , EPA estimates pollution control costs using standardized cost procedures specified in the OCCM. The EPA realizes that estimates made through the OAQPS Control Costs Manual may be different from actual costs at individual facilities. However, the procedure provides a reasonable estimate of control costs on a national basis. Indirect costs were not assumed to be included in the vendor's cost. Indirect costs are equipment specific and range from 30 to 57 percent of the total direct costs. 5.3 SECONDARY IMPACTS OF PULPING CONTROLS
Comment: Several commenters (20,053A1, 20,057A2, 20,059, 20,07OAl, 20,103 , 20,114) opposed combustion as a means of controlling HAP's because the secondary emissions of other pollutants would increase. Several commenters (20,018, 20,053A1,

5-2320,057A2, 20,059 , 20,103) stated that EPA's approach to control HAP's by combustion would increase emissions of criteria pollutants regulated under the Act. One commenter (20,114) specifically noted that combustion of NCG containing reduced sulfur compounds would result in increased emissions of sulfur dioxide. Another commenter (20,010) supported using incineration to control emissions from pulping vents. However, the commenter

(20,010) insisted that no exceedances of the existing sulfur dioxide emissions standard should be allowed from incinerating pulping off-gases. One commenter (20,114) asserted that the costs and environmental impacts associated with the by-products resulting from combustion-based control equipment must be further assessed. The commenter (20,114) argued that the economics assessment erroneously indicated that the adverse effects of secondary impact increases cannot be quantified. The commenter (20,114)stated that EPA must explain such statements when combustion byproducts are criteria pollutants for which there are existing ambient air quality standards. One commenter (20,103) questioned whether tradeoffs between HAP's and criteria pollutants had even been considered. Response: In the final economics assessment, (A-92-40, V-A-2), EPA outlined the estimated emission reductions resulting from this rule (139,000 Mg/yr HAP's, 409,000 Mg/yr VOC's, 78,50 0 Mg/yr TRS compounds). Estimated increases in secondary emissions due to using combustion sources for HAP control were also presented (94,500 Mg/yr SO2, 5,230 Mg/yr NO x , 8,660 Mg/yr CO). The EPA judged that the secondary impacts, due to the use of combustion control for HAP's, were reasonable and

5-24were outweighed by the benefits of the HAP emission reductions achieved. The readers are referred to the economics assessment for a detailed discussion of the benefits analysis.

Comment: One commenter (20,053Al) contended that incineration of HVLC streams would increase energy requirements because HVLC streams do not contain compounds with sufficient heating value to support combustion. The commenter (20,053Al) added that increased energy consumption would have adverse environmental effects and increase mill operating costs. The
commente r (20,053Al) concluded that these impacts were not incorporated into EPA's analysis. Response: The EPA agrees that some of the named vent streams will not have sufficient fuel value to support combustion. The environmental and cost impacts for the final rule were revised to include increases in fuel and energy requirements (see chapter 20 of this document).

Comment: One commenter (20,011) contended that the secondary impacts (such as energy use) from back-up incinerators were not assessed in the proposal. The commenter (20,011) stated that these impacts should be addressed in the promulgation package. Response: Impacts were calculated assuming that the primary combustion device was operating 100 percent of the time. The EPA considers that if the primary device was down and a backup device was used, similar energy and emissions would occur. Therefore, the impacts from backup devices have implicitly been incorporated into the impacts analysis.

Comment: One commenter (20,122) requested that EPA clarify whether chlorinated sludge may be incinerated. The commenter

5-25(20,122) stressed that it is necessary to prevent the incineration of chlorinated compounds that form dioxins, furans, and other organochlorines. Response: This NESHAP does not require the incineration of chlorinated sludge. Solid waste handling is addressed under RCRA regulations , and it is not in the scope of MACT regulations.

Comment: On e commenter (20,027) stated that the economics of combusting HAP's in a boiler with an SO 2 scrubber are less favorable than combustion in a stand-alone combustion unit because the flue gas volume of a boiler is larger, which makes the cost of control greater. Response: While the rule does not require SO 2 control on the boilers or incinerators used for HAP control, some existing boilers already have SO 2 control. To avoid adverse air quality impacts locally , some of these facilities may be required to install SO 2 control on the boilers or incinerators that are used for HAP control. The EPA agrees that SO 2 control costs on an incinerator may be less than SO 2 control costs on a boiler due to differences in flue gas volume. However, the rule allows a facility to control HAP's in a boiler or in an incinerator, and the facility can make the control option decision based on their preference. The interaction between the NESHAP and other existing regulations associated with collateral emissions increases are addressed in chapter 16 of this document.

5-266.0 BLEACHING AREA

6.1 CONTROL OPTIONS 6.1.1 Scrubbers
Comment: Several commenters (20,027, 20,029, 20,054A2, 20,074, 20,118 , 20,149) discussed the chlorine removal efficiency of existing bleach plant scrubbers. One commenter (20,027) argued that there were no data to support EPA's assumption that scrubbers can control 99 percent of chlorine emissions from the bleach plant on a continuous basis. The commenter (20,027) objected that EPA used NCASI Technical Bulletin No. 616 as the basis for specifying 99 percent removal because the data in that bulletin indicated that scrubbers occasionally attained the 99 percent control level, not continuously. Another commenter (20,074) suggested a continuous chlorine/C10 2 removal efficiency of 95 percent rather than the proposed value of 99 percent, and provided data on three existing bleach plant scrubbers to justify the recommendation. Two commenters (20,118 , 20,054A2) stated that removing 99 percent of chlorine emissions may not be possible at mills with 100 percent Cl02 substitution due to low concentrations of chlorine that would enter the scrubber. One commenter (20,029) supported EPA's assumption that the bleach plant chlorine scrubber could remove 99 percent of

6-1chlorine and Cl02 emissions. The commenter (20,029) acknowledged scrubbers achieving as high as 99.9 percent control efficiency. Response: As discussed in the March 8, 1996 Federal Register supplemental notice , data available to EPA (A-92-40, 11-I-24) support the 99 percent chlorinated HAP reduction requirement for existing bleach plant scrubbers that use a caustic medium and operate with high recirculation rates. The EPA reviewed the data submitted by commenter 20,074 and found three of the six bleach plant scrubbers analyzed by the commenter had estimated chlorine/ClO 2 reductions of 99 percent with the remaining three dropping off to a low of 50 percent. The three scrubbers that did not achieve 99 percent reduction were not caustic scrubbers and, therefore , not representative of MACT. Moreover, the data received from commenter 20,074 was not used to help justify the final rule because the reported reductions were estimated and not based on test results. The EPA agrees that a continuous 99 percent reduction of chlorinated HAP's across a caustic scrubber may not be achievable on streams with low concentration levels of chlorine, such as
when Cl02 substitution is used. Therefore, in the final rule, EPA has included a chlorinated HAP (other than chloroform) outlet concentration limit of 10 ppmv and a chlorine mass emission limit of 0.001 kg total chlorinated HAP (other than chloroform) per Mg ODP produced as alternate compliance options. The EPA has concluded that these compliance alternatives will achieve chlorinated HAP reductions (other than chloroform) equivalent to the 99 percent reduction standard (A-92-40, IV-B-29).
Comment: In regard to the December 17, 1993 proposal, several commenters (20,024, 20,028, 20,036A1, 20,043, 20,057A2,

6-220,071, 20,074, 20,111 , 20,114) stated that EPA incorrectly determined the level of control achieved by bleach plant scrubbers for HAP's other than chlorine. Several commenters (20,043, 20,057A2, 20,071, 20,074, 20,111, 20,114, 20,146) contended that data indicated that bleach plant scrubbers are ineffective at removing methanol from vent gases. One commenter (20,027) provided data to demonstrate that methanol and other non-chlorine HAP's are not removed by existing bleach plant scrubbers. In addition , the commenter (20,027) also presented data on the amount of methanol released from existing bleach plant scrubbers. Another commenter (20,028) reported a methanol removal efficiency of 40 percent with their existing bleach plant scrubber (using weak wash as the scrubbing medium). One commenter (20,027) pointed out that bleach plant scrubbers typically use alkaline media rather than water as the scrubbing fluid. Two commenters (20,027 , 20,071) stated that a second scrubber utilizing water as the scrubbing media could be installed to remove methanol ; one commenter (20,027) provided cost information, but stated that such an option would not be cost effective. In response to the proposed use of incineration following scrubbers, three commenters (20,057A2, 20,114, 20,146) claimed that incineration following bleach plant scrubbers would not be cost effective. In response to the March 8, 1996 Federal Register supplemental notice , several commenters (IV-D2-8, IV-D2-10, IV-D2-15, IV-D2-16 , IV-D2-17) agreed with EPA's decision to drop the control of non-chlorinated HAP's from the bleaching control requirements. However , one commenter (IV-D2-4) expressed concern

6-3over EPA's decision to only require chlorinated HAP control for the bleaching area: Response: As discussed in the March 8, 1996 Federal Register supplemental notice , the proposed requirement for control of non-chlorinated HAP's from the bleaching system was dropped for the final rule

. Evaluation of existing bleach plant scrubber performance data provided by industry indicated that existing scrubbers are not effective at removing non-chlorinated
HAP'S. Other control scenarios , such as incineration followed by caustic scrubbing or a second scrubber for the control of methanol, were evaluated for reducing non-chlorinated HAP's, but EPA determined that these control techniques were cost prohibitive or had adverse environmental impacts (see proposal preamble). For example , the cost of adding a second scrubber for the control of methanol would not be reasonable considering the relatively low emission reduction achieved and the significant increased generation of process wastewater requiring treatment.

Comment: Two commenters (20,059 , 20,091) claimed that the December 17 , 1993 proposal may promote cross-media transfers of certain pollutants. For example , pollutants absorbed in scrubbing liquid may be released back to the atmosphere from the wastewater treatment process. One commenter (20,059) also claimed that although scrubbers may effectively remove 99 percent of highly soluble compounds , the overall reduction of these compounds is estimated at only 75 percent because these pollutants re-volatize in the wastewater treatment process. Similarly, the commenter (20,059) stated that scrubbers remove 60 percent of medium solubility compounds but the actual removal is only 35 percent because of re-volatilization.

6-4Another commenter (20,091) expressed concern over emissions

of bleach plant pollutants from spent white liquor that has been used as scrubbing media in the bleach plant. The commenter (20,091) questioned whether the spent scrubbing media would be sent to the white liquor storage tank where bleach plant pollutants could be emitted to the atmosphere. Response: Based on an evaluation of the industry data collected in the 1992 NCASI voluntary questionnaire, the floor level of control for bleach plant vents was determined to be control of total chlorinated HAP's (other than chloroform) using caustic scrubbing and process modifications (elimination of hypochlorite and 100 percent substitution of chlorine). Bleach plant scrubbers typically use white liquor as a scrubbing media to remove chlorinated compounds. Data indicate that caustic scrubbing can control the emissions of chlorine by 99 percent or below 10 ppmv or to an emission limit of 0.001 kg per Mg ODP (A-92-40, IV-B-29). Re-volatilization of chlorinated HAP's is not considered a concern because chlorinated compounds react with the scrubber media to form a precipitate and would not be emitted from the spent caustic. Typical industry practice for spent scrubbing media is to send the stream to the sewer followed by biological treatment. Other control devices were evaluated for reducing non-chlorinated HAP's but EPA determined that these control techniques were cost prohibitive. The EPA does not have data on chlorinated HAP emissions from white liquor storage tanks, but maintains that they are insignificant due to the reactions between the chlorinated compounds and the white liquor that form a precipitate.

6-56.1.2 Incineration

Comment: With regard to the December 17, 1993 proposal, several commenters (20,027, 20,059, 20,071, 20,114) expressed concerns over the potential requirement for incineration of emissions from bleach plant vents. Three commenters (20,027, 20,071, 20,114) maintained that the incineration of emissions from bleach plant scrubber overheads would not be cost effective due to energy penalties and large increases in collateral emissions. The commenters (20,027, 20,071, 20,114) also stated that this option would not be legally defensible because the cost-effectiveness of such a requirement could not be justified. One commenter (20,027) stated that existing combustion devices could not be used to combust emissions from scrubber overhead vents because there would be periodic exposure to chlorinated streams if the scrubber experienced downtime, or continual exposure if the combustion device were installed prior to scrubbing. Therefore, the commenter (20,027) concluded that a stand-alone incinerator would have to be installed after the scrubber. The commenter (20,027) indicated additional fuel would be required for the incinerator, leading to collateral emission increases and energy penalties. One commenter (20,059) supported a control option that would require combustion of scrubber off-gases to remove insoluble organic compounds such as chloroform. The commenter (20,059) contended that some pollutants in the bleaching vent streams would not be effectively reduced with a scrubber alone. The commenter (20,059) also asserted that EPA did not consider intermediate options, such as the combustion of selected vent streams with high organic content followed by scrubbing.

6-6Response: As presented in section X.E.2 of the preamble to the December 17, 1993 proposal , EPA considered two options for incinerating bleach plant vent gases: (1) combustion of scrubber off-gases, and (2) combustion of emissions from bleach plant vents followed by scrubbing. However, EPA rejected these options because they were not reasonable considering the cost and environmental impacts. Cost data and comments received after proposal supported the conclusion that incineration of bleach plant vent gases is not a viable option (20,027). The final rule requires caustic scrubbing for total chlorinated HAP's , other than chloroform, for both paper-grade and dissolving-grade mills. For paper-grade mills, the final rule requires process modifications (e.g., 100 percent Cl02 substitution and elimination of hypochlorite) for chloroform emissions. The chloroform requirements for dissolving-grade mills are still under study and are being deferred. As indicated in the March 8 , 1996 supplemental notice, compliance with the requirements of the effluent limitation guidelines and standards will constitute compliance with the air standards for chloroform emissions. The EPA recognizes that these requirements do not provide efficient control of non-chlorinated HAP's. However, additional technologies that could reduce non-chlorinated HAP's, such as incineration , were determined to not be reasonable based on their cost and impacts (see proposal preamble). 6.1.3 Process Modifications

Comment: On e commenter (20,027) claimed that EPA did not systematically review industry data to predict the emission reductions of HAP's other than chloroform from process changes (e.g., peroxide reinforcement of the second bleaching stage,

6-7installation of oxygen delignification, extended digester delignification, improved brownstock washing, etc.). The commenter (20,027) concluded that, based on the ineffectiveness of scrubbers in controlling some species of HAP emissions, it would not be appropriate to include gas scrubbing in the development of the MACT floor level of control. However, the commenter (20,027) suggested that it may be appropriate to set emission limits based on reductions obtained through process changes. Several commenters (20,054A2, 20,059, 20,071, 20,102, 20,144) suggested that the elimination of hypochlorite and 100 percent substitution of Cl02 would reduce emissions of chloroform and other HAP's. Therefore, the commenters (20,054A2, 20,071) indicated that scrubbers would not be needed for HAP control. Response: The EPA evaluated the industry test reports, including the NCASI report , and prepared a document that summarizes the calculated emission factors (A-92-40, IV-A-6). Evaluation of these data indicate that high levels of Cl02 substitution and elimination of hypochlorite reduce chloroform emissions, but may not significantly reduce other non-chlorinated
HAP'S. Information obtained from the 1992 NCASI voluntary questionnaire (i.e. , the MACT survey) indicated that the floor level of control for bleach plants is caustic scrubbing and process modifications (100 percent substitution and elimination of hypochlorite) to control chloroform emissions. The effluent limitation guidelines and standards will require (as a minimum) 100 percent Cl02 substitution and no hypochlorite use. The EPA

6-8considers these requirements to be at least as stringent as the process modifications in the floor level of control. Therefore, as explained in detail in the March 8, 1996 Federal Register supplemental notice , the final rule for bleach systems is a combination of the effluent limitation guidelines and standards requirements (or MACT process modification requirements) and the bleach system vent scrubber requirements outlined in the proposed
rule.
Comment: One commenter (20,059) recommended that EPA examine whether 100 percent Cl02 substitution for dissolving kraft mills , as opposed to the 70 percent substitution recommended at proposal , could achieve greater reductions in chloroform and other HAP emissions. The commenter (20,059) asserted that if it is more effective , then EPA should require 100 percent substitution combined with oxygen delignification as the basis for controls in the dissolving kraft industry. Response: The final rule contains standards for total chlorinated HAP's , other than chloroform, based on scrubbing and process modifications ; either elimination of hypochlorite and 100 percent Cl02 substitution or the effluent limitation guidelines and standards for paper-grade and dissolving-grade mills. However, as stated in OW's July 15, 1996 Federal Register notice, EPA is deferring issuing effluent limitation guidelines and standards for dissolving-grade mills until the comments and preliminary new data affecting dissolving-grade subcategories can be fully evaluated. Therefore, the compliance date for dissolving-grade mills to comply with the bleaching system standards has been delayed until the 3 years after the effluent limitation guidelines and standards are promulgated.

6-9Oxygen delignification is not being required as MACT because it would not achieve significant additional air emission reductions in the bleaching system beyond those achieved by the final rule, and would increase emissions of HAP from the pulping

area. Comment: Several commenters (20,036A1, 20,059, 20,110, 20,121) stated that TCF bleach plants should be exempt from the proposed bleaching area control requirements. One commenter

(20,036Al) agreed with the requirement for enclosures in the bleaching area if a mill uses a combination of chlorine and Cl02 to bleach; but they argued if a mill uses a TCF bleaching

process, enclosures should not be required.

One commenter (20,036Al) requested that the requirements for scrubbers to control chlorine/C10 2 emissions be eliminated if TCF bleaching is implemented. Response: In the December 17 , 1993 proposed rule, TCF bleach systems would have fallen under the pulping component definition , and therefore , would be required to control all

vents. In the final rule , TCF systems are included in the bleaching system. Bleaching systems are only required to control total chlorinated HAP's. Since TCF systems do not use chlorinated HAP's , TCF bleach systems are not required to be controlled.
Comment: One commenter (20,138) requested that EPA ban the use of chlorine to bleach pulp , and require the use of oxygen delignification. The commenter (20,138) indicated that Cl02 substitution may not be good enough. One commenter (20,110) objected to the requirement for Cl02 substitution since it has a greater inhalation toxicity than chlorine and Occupational Safety

6-10and Health Administration (OSHA)/National Institute Occupational Safety and Health (NIOSH) exposure limits are one fifth those of chlorine. Response: Based on an evaluation of industry data collected in the 1992 NCASI voluntary survey (A-92-40, IV-B-8), and data received after proposal , EPA determined that the MACT floor for bleach plant vents is scrubbing of total chlorinated HAP's, other than chloroform, 100 percent substitution with ClO2, and elimination of hypochlorite. Therefore, substitution is required in the final rule. The data also show that bleaching substitution with Cl02 reduces chloroform and other chlorinated HAP emissions. However, the data indicate that there are no significant increases in non-chlorinated HAP emissions. Readers are referred to the revised emission factor document (A-92-40, IV-A-8) for a more detailed discussion of this issue. While Cl02 is a highly toxic compound , mills that use Cl02 substitution also have scrubbers in place to control Cl02 because of worker safety

concerns. 6.2 MISCELLANEOUS BLEACHING COMMENTS
Comment: On e commenter (20,029) advocated the possible use of catalytic oxidation units with appropriately formulated catalysts to control bleaching component halogenated VOC, citing their effectiveness in other industrial applications. Response: A discussion of the rationale for determining the level of control for the bleach plant is presented in chapter 4.0 of this background information document. Other control devices than those specified in the rule can be used to meet the performance standard in place of the reference control technology. However, the alternate control device will still be

6-11required to meet the percent reduction or concentration limits

for chlorinated HAP's specified in the rule.

6-127.0 PROCESS WASTEWATER AREA

7.1 DESIGN STEAM STRIPPER
Comment: Several commenters (20,000, 20,027, 20,059, 20,118, 20,147) contended that various aspects of the design specifications for the steam stripper required by the proposed rule were incorrect, and that some assumptions used in modeling the steam stripper control of process wastewater streams were incorrect. Two commenters (20,000, 20,147) reported that the specified steam stripper design would not achieve the desired results because the pressure was too high for the number of theoretical stages assumed. Two commenters (20,027, 20,118) criticized the use of a tray efficiency of 75 percent, stating that industry typically assumes a tray efficiency of 50 percent. The commenters (20,027, 20,118) also stated that the proposed inlet concentration for streams to be stripped was too high. Two commenters (20,027, 20,118) claimed that the analysis for the proposed steam stripper appeared to be based on stripping compounds (e.g., butadiene, toluene, naphthalene, and butanol) unrelated to the pulp and paper industry. One commenter (20,027) contended that these compounds do not possess the hydrophilic properties of methanol. The commenter (20,027) also criticized the use of Henry's law instead of empirical data to predict liquid-gas interface relationships. The commenter (20,027)

7-lconcluded that the result was that the stripper design was undersized. One commenter (20,147) strongly criticized the design steam stripper parameters and indicated that EPA should simply designate what streams require stripping and at what efficiency and leave the design of the system to the experts. Response: Based on comments received on the December 17, 1993 proposed rule and the March 8, 1996 supplemental notice, the requirements for a design steam stripper were removed from the final rule. Industry indicated that a design stripper would likely not be used. At proposal, industry commented that a mass removal target would be a more usable option. Prior to proposal, EPA lacked the data necessary to establish a mass removal target. However, additional data was submitted to EPA following the proposal and was used to determine the appropriate mass removal targe t (20,027A3). A discussion of this data was presented in the March 8, 1996 supplemental notice. Based on this data, EPA determined that the mass removal target is achievable (A-92-40, IV-B-l0). Additionally, information received from industry about specific design assumptions were considered in determining steam stripper costs (see section 7.6). 7.2 APPLICABILITY CUTOFFS
Comment: One commenter (20,027) advised that the proposed rule (with the 500 ppmw cutoff) would require stripping of streams with flow rates of 1,000 to 1,500 gallons per minute (GPM)

. The commenter (20,027) pointed out that no mill is known to operate a steam stripper capable of stripping streams with this high flow rate. The commenter (20,027) stated that the largest steam stripper used in the industry strips 500 GPM. The

7-2commenter (20,027) asserted that stripping at the levels proposed by EPA would require stand-alone steam strippers (A-92-40, II-B-20). One commenter (20,043) indicated that their steam stripper would be able to achieve about 90 percent removal of methanol if the applicability level were raised to 3,000 ppmw so that the large volume , dilute flows would not need to be stripped. However, one commenter (20,059) alleged that EPA relaxed the applicability cutoff in the final rule from 100 ppmw to 500 ppmw due to objections from industry and Office of Management and Budget (OMB). The commenter (20,059) argued that the cutoff limit for steam stripping wastewater (500 ppmw methanol) will virtually exempt all wastewater streams from steam stripping, and consequently , from control of atmospheric VOC emissions. Two commenters (20,027 , 20,118) asserted that steam stripping of streams that contain black liquor (even in dilute amounts) is not feasible due to foaming problems. As a solution, the commenters (20,027 , 20,118) proposed the restriction of the definition of process wastewater streams to include only certain defined streams that do not come in contact with black liquor. This would allow condensates contaminated with liquor (carryover or spilled liquor) to be discharged to the wastewater treatment system. Response: At the time of the proposal, EPA did not have sufficient data to identify the specific streams that are typically steam stripped. The applicability cutoffs were developed to distinguish between those streams that were steam stripped at the floor level of control and those that were not stripped. Following proposal , additional data was submitted to

7-3EPA (A-92-40 , IV-J-32) that identified the specific streams that

ar e stea m stripped and streams that are uncontrolled at the floor level of control. Control more stringent than the floor level is not warranted given the smal l concentrations of HAP's and the costs of controls. As discussed in the March 8, 1996 supplemental notice , EPA revised the format of the final rule for kraft and sulfite wastewater by replacing the applicability cutoffs with named pulping process condensate streams to be controlled. The EPA contends that the revised approach contained in the final rule more accurately reflects the floor level of control than the applicability cutoffs in the proposed rule. With regard to the commenter's concern of stripping streams that contain black liquor , EPA does not have sufficient data to assess the magnitude of this problem. However, EPA contends that periods when condensates are untreatable should be addressed with the downtime allowances for stand-alone and integrated steam strippers specified in the final rule. Further discussion of downtime issues is given in section 4.3.4.
7.3 HARDPIPING AND BIOLOGICAL TREATMENT
Comment: In regard to the EPA's request for comments and data at proposal , several commenters (20,027, 20,039, 20,054A2, 20,067, 20,074 , 20,111) supported biological treatment for the control of HAP's from wastewater. One commenter (20,054A2) stated that if other technologies, old or new, could achieve the same leve l of reduction , they should be allowed as alternatives. Two commenters (20,039 , 20,067) stated that by not allowing biological treatment as an alternative to steam stripping, money and efforts would be wasted for no environmental benefit. One commenter (20,111) reported that test results obtained from a

7-4kraft mill have shown non-detectable levels of methanol in both the sludge and the effluent to the river, indicating that a properly operated biological treatment system would be a better environmental alternative than steam stripping.
One commenter (20,011 ) asserted that methanol's high solubility, low volatility , and affinity for biological destruction were not considered when EPA chose steam stripping as the reference control technology over biological treatment. The commenter (20,011) questioned why reference control technology criteria for biological treatment systems have not been established despite data demonstrating their efficient destruction of HAP's. Two other commenters (20,027 , 20,115A2) also indicated that methanol is readily destroyed by biological treatment systems. One commenter (20,043) noted that the chemical characteristics of the HAP's found in pulp mill wastewater streams are correctly described as polar and these HAP's are not likely to volatilize readily. Response: In both the December 17, 1993 proposal and the March 8, 1996 supplemental notice, EPA stated that steam stripping of pulping process condensate streams constitutes the floor level of control for kraft pulping. The EPA asserts that the MACT standards address total HAP emissions, not just emissions of methanol. While EPA agrees with the commenters that methanol is readily degraded in well-operated biological treatment systems , information detailing the overall effectiveness for destroying total HAP compounds is not available. Based on the hydrophilic nature of methanol, EPA believes that a steam stripper removing 92 percent of methanol is

7-5achieving a substantially greater removal of total HAP (i.e., 92 percent removal of methanol in a steam stripper correlates to at least 92 percent removal of total HAP). This is not the case for biological treatment systems since methanol is preferentially degraded over other HAP compounds

(i.e., 92 percent removal of methanol in biological treatment does not necessarily correlate to 92 percent removal of total HAP). While EPA has limited data indicating that some welloperated biological treatment systems could meet the standard

(A-92-40, IV-Dl-75), EPA does not have sufficient data regarding total HAP removal to base the floor level of control on biological treatment. In the proposal and final rule, methanol was selected as the surrogate compound for measuring total HAP for most control devices since it is the predominant compound in process vent and

wastewater streams. However, the final rule specifies that compliance with the percent reduction standard must be demonstrated on a total HAP basis if a biological treatment system is used to comply with the pulping process condensate standard. Although EPA based the floor level of control on the performance of steam stripping technology, the final rule contains several compliance options. The options include discharging condensates to a biological treatment system achieving 92 percent destruction of HAP, recycling the pulping process condensate streams to a piece of process equipment that is controlled according to the pulping vent standard, achieving a specified percent mass reduction , and achieving minimum mass removal targets. Any HAP removed during handling and treatment,

7-6with the exception of biological treatment, must be controlled according to the pulping vent standard.

Comment: One commenter (20,027) questioned whether sufficient data were available to determine biological treatment's destruction efficiency of HAP's and cautioned that neither they nor EPA have sufficient information to predict what the target treatment efficiency o f "well operated treatment systems" are in general. The commenter (20,027) stated that the proposed effluent guidelines have the potential to reduce the BOD loadings to the biological treatment system and, consequently, to change the removal efficiency of the system. One commenter

(20,067) reported a HAP removal efficiency of 98 percent by biological treatment systems. Response: At proposal , EPA did not have sufficient data to characterize the total HAP removal efficiency of biological treatment systems. Following proposal , industry submitted data

(A-92-40, IV-Dl-75) that detailed the removal efficiency of methanol in biological treatment systems. Based on this data, EPA concluded that a well operated treatment system can achieve methanol removal of 98 percent. However , methanol is preferentially degraded in biological treatment systems over other HAP compounds. Therefore, the final rule requires owners and operators using a biological treatment system to comply with the pulping condensate standard to demonstrate initially and annually that the system is achieving at least a 92 percent reduction in total HAP, not just methanol. Regarding the commenter's (20,027) concern about the effect of reduced BOD loadings on biological treatment system removal efficiency, EPA maintains that using a biological treatment

7-7system to comply with the pulping process condensate standards is an appropriate option. If for any reason the biological treatment system cannot be operated to achieve a 92 percent HAP reduction on a continuous basis , then the biological treatment option could not be used. 7.4 WASTEWATER COLLECTION AND TRANSPORT SYSTEMS
Comment: Several commenters (20,027, 20,056, 20,059, 20,074, 20,115A2) discussed the enclosure of wastewater collection and biological treatment units. One commenter

(20,027) stated that the requirement for enclosing and combusting the wastewater collection and transport system components was expensive, impractical, completely unreflective of current practice and of minimal environmental benefit. One commenter

(20,056) supported the statement in the preamble to the proposed regulation that the release of HAP's from quiescent wastewater units are less significant than those from turbulent systems. The commenter (20,056) stated that control of quiescent tanks and impoundments would not be justified since the dominant HAP is methanol, which is extremely soluble in water and does not readily volatilize. Another commenter (20,115A2) stated that it would not be feasible to incinerate the large volume of air associated with an enclosed biological treatment system. One commenter (20,074) stated that enclosing the collection system until biological treatment is not needed to provide equivalence to steam stripping. The commenter (20,074) noted that steam strippers and incinerators are far more susceptible than wastewater plants to periods of excess emissions during startups, shutdowns, and malfunctions.

7-8One commenter (20,059) stated that EPA should evaluate emissions from quiescent basins and biological treatment systems and require them to be covered and vented to a control device. The commenter (20,059) indicated that volatile toxics evaporate from uncovered segments of wastewater treatment and biological treatment lagoons. The commenter (20,059) further asserted that biological treatment of wastewaters is ineffective at controlling VOC emissions to the atmosphere. Response: The EPA asserts that it was not the intent of the biological treatment compliance option specified in the proposed rule to enclose or cover and incinerate the biological treatment system emissions. The final rule was revised to make the requirements for the biological treatment system compliance option more clear. The EPA agrees with the commenter that enclosing treatment units and incinerating the emissions would be very costly for industry and would achieve minimal emissions reductions. This determination is based on an evaluation of the emissions from biological treatment units (A-92-40, IV-A-6) and the fact that biological treatment systems are typically not located near existing combustion devices (i.e., there would be costly gas collection/conveyance systems). In addition, no existing mills currently cover and vent their biological treatment systems to control devices. The EPA adopted a similar approach in the recently promulgated rules controlling air emissions from hazardous waste surface impoundments that treat volatile hazardous wastes. As presented in the December 6 , 1994 Federal Register notice

(59 FR 62917) and 40 CFR part 265.1086(a), uncovered biological treatment systems may be utilized to comply with the rule's

7-9requirements provided that the treatment system achieves the specified mass removal efficiency. The proposed requirements for enclosing the wastewater collection system were intended to prevent the volatilization of HAP compounds from the wastewater streams before the streams arrived at the treatment device (e.g., steam stripper or biological treatment system). The proposed rule contained requirements for tanks, containers, surface impoundments, and individual drain systems. Based on industry comments, the requirements for containers have been removed from the final rule since they are not used in the pulp and paper industry. Additionally the requirements for surface impoundments have been removed from the final rule since EPA concurs that collecting and incinerating emissions from these treatment units is not reasonable. The final rule retains the requirements for tanks that are used to store or treat the pulping process condensates. The specific individual drain system requirements contained in the proposed rule have been removed in favor of referencing the individual drain system requirements specified in 40 CFR subpart RR §§ 63.960, 63.961, 63.962, and 63.964. The EPA compared the collection system requirements contained in the proposed rule with the requirements of subpart RR. Since the requirements are consistent with the intent of the proposed standards, EPA concluded that the requirements of subpart RR, when combined with a treatment option, constitute MACT for the pulp and paper industry.

7-107.5 SECONDARY IMPACTS OF WASTEWATER CONTROLS
Comment: Several commenters (20,000, 20,011, 20,018, 20,027, 20,057A2, 20,067, 20,111, 20,115A2) indicated that the collateral emissions and the waste heat load associated with steam stripping were not adequately characterized by EPA. Two commenters (20,027 , 20,057A2) asserted that EPA did not consider that the waste heat from steam strippers would cause water pollution, and may impact NPDES permits. Several commenters

(20,027, 20,057A2, 20,111) noted that there would be an increase in NO x , SO2, CO, and PM less than 10 microns mean aerodynamic diameter (PMIO) due to the extra energy needs from the proposed steam stripping option. Two commenters (20,000, 20,067) also stated that the increased need for steam, normally generated by burning fossil fuel , could lead to increased carbon dioxide (CO2) emissions. Two commenters (20,011 , 20,018) stated that the secondary impacts associated with routing stripper overheads to a combustion device have not been adequately characterized. One

commenter (20,115A2) argued that incinerating the steam stripper overheads and discharging clean , hot water was counterproductive from an energy standpoint while achieving little more reduction of methanol emissions than biological treatment. Response: For the proposed and final rules, secondary impacts (e.g., NO x , SO2, CO, PM, etc.) were estimated for the following areas associated with steam stripping: (1) overhead gas combustion, (2) steam generation , and (3) electricity use. These secondary impacts are included in the impacts analysis. A discussion of the analysis for estimating secondary impacts is presented in chapter 20 of this document. The commenters' concerns regarding secondary impacts increases were referring to

7-11the impacts generated by the proposed steam stripper. At proposal, the flow rate of condensate streams sent to the steam stripper was estimated to be approximately 1 GP M per ADTP production per day (GPM/tpd). Based on data received following proposal, the flow rate was revised to approximately 0.2 GPM per ADTP per day. Consequently, the energy demand required by the steam stripper and the secondary impacts were proportionately reduced. Regarding overall energy concerns , the final rule specifies that mills can rectify the steam stripper overheads to produce a concentrated stream to be used as supplemental fuel in mill combustion devices. This action will substantially reduce the operating costs associated with steam stripping. Additionally, the treated condensate from the steam stripper could be used by mills in pulping process areas to reduce the overall demand for fresh or mill water. If a mill elects to discharge the treated stream to the biological treatment system, the contribution of this stream to the total mill effluent flow rate would be negligible (i.e. , hundreds of gallons compared to millions of gallons per day). 7.6 COSTS
Comment: Several commenters (20,011, 20,014, 20,018, 20,027, 20,043, 20,057A3, 20,114 , 20,118) claimed that EPA underestimated the cost of steam stripper installation because of inadequate design and that EPA also overlooked equipment requirements. Several commenters (20,014, 20,027, 20,057A2, 20,118) maintained that cooling towers will be needed to handle the increased heat load sent to wastewater treatment systems. Several commenters (20,011, 20,014, 20,018, 20,027, 20,057A2,

7-1220,114, 20,118) were concerned that existing steam capacity will not be adequate for stripping the required streams. The commenters indicated that the construction of package power boilers would be required to generate the additional steam necessary to strip the high volumes of wastewater. One commenter

(20,057A2) argued that the construction of new power boilers or modifications to existing ones would trigger PSD/NSPS review and permitting. The commenter (20,057A2) stated that EPA did not consider the capital costs associated with this need. One commenter (20,027) noted that the true cost of steam stripping depends on the water and heat balances at a given mill. The commenters indicated that these factors were not considered properly by EPA in developing costs. One commenter (20,014) reported that the additional steam needed to strip an estimated 1,700 GPM of condensates would cost approximately $3,500,000 per
year. One commenter (20,027) warned that the conclusion was incorrect that two-thirds of the industry strippers would be integrated with evaporators. The commenter (20,027) asserted that the proportion of integrated versus non-integrated steam strippers is not the 66/34 percent split (integrated vs. nonintegrated) used by EPA , but closer to a 6/94 percent split (30 of 32 mills are non-integrated). The commenter (20,027) disagreed that integrated steam strippers are a viable option

(A-92-40, II-B-28). One commenter (20,043) indicated that because pulp mills generate larger and more dilute wastewater streams than the chemical industry , it would be cost prohibitive to transfer chemical manufacturers ' wastewater technologies (i.e., steam

7-13strippers) to the pulp industry. One commenter (20,114) urged that the high cost of a stand-alone incinerator be considered since wastewater treatment systems are typically located in remote areas of the mill. One commenter (20,027) indicated that the ASPEN model EPA used to develop steam stripper design, cost, and model plant parameters is used for simulating packed tower distillation columns, not steam strippers. Therefore, the commenter asserted that the model inputs and assumptions used at proposal were not correct for the pulp and paper industry. The commenter (20,027) favored projections of cost and performance made on actual industry data rather than on a predictive model for chemical industry equipment. Response: The comments received regarding steam stripper costs were made in reference to the proposed steam stripper design. Although the cost estimation of steam stripping systems is not critical since stripping is a floor-level technology, EPA revised the design and performance parameters used to estimate the capital and annual costs associated with steam stripping

(A-92-40, IV-B-17) based on comments and data received following proposal. At proposal , the flow rate of condensate streams sent to the steam stripper was approximately 1 GPM per ADTP per day. Based on data received following proposal (20,027A3), the flow rate was revised to approximately 0.2 GPM per ADTP per day. Consequently, the capital and annual costs associated with steam stripping were proportionately reduced. The EPA contends that the ASPEN model provides steam stripper cost estimates that are comparable to the estimates

7-14provided by industry. While some mills may encounter higher or lower capital and annual costs, EPA maintains that the cost estimates derived from the ASPEN model are appropriate for estimating the national impacts ass0ciate.d with steam stripping. The costs associated with package boilers for additional steam capacity were not included in the steam stripper costs. The EPA maintains that the steam demand for the stripper system is not expected to be a significant portion of the overall mill steam generation capacity and that the affected mills will be able to meet the increased steam demand with existing systems. Additionally, the steam required for stripping may be generated from other sources besides fresh steam from power boilers or recovery furnaces (e.g. , flash or waste heat sources). The costs associated with cooling towers were not included in the steam stripper costs for the final rule. The EPA reviewed the data submitted by industry (A-92-40 , IV-Dl-46) detailing the number of cooling towers existing in the pulp and paper industry. The data indicated that 13 cooling towers were being used. While some mills may need cooling towers to handle the waste heat load from the pulping and bleaching processes, EPA's judgement was that it was not appropriate to assign the costs for installing and operating cooling towers to all mills that would use steam stripping. This decision was based on the fact that the stripped pulping condensates are typically sent to the mill's hot water tank for distribution to other process areas and the contribution of the stripped condensate is not expected to be significant when compared to the total volume of mill wastewater sent to the biological treatment system.

7-157.7 OTHER
Comment: On e commenter (20,115A2) stated that recycling pulping process condensates could potentially increase HAP emissions due to increased carryover to uncontrolled process equipment such as deckers and screens. Response: The final rule contains a compliance option for kraft pulping system wastewaters that allows mills to recycle the specified pulping process wastewater streams to controlled pieces of equipment without treatment. Since the piece of equipment receiving the untreated condensate is controlled according to the capture and control requirements of the pulping vent standards, EPA contends that HAP emissions would not be increased.

7-168.0 MONITORING

8.1 GENERAL
Comment: One commenter (20,059) stated that the monitoring parameters in the December 17, 199 3 proposal were insufficient. The commenter (20,059) stated that in order to show that an emission standard is enforceable, EPA must show that the monitoring standard is sensitive enough to (1) detect exceedances, (2) indicate the amount of time the source was out of compliance, (3) show the amount of emissions in excess of the standard, and (4) identify the pollutants emitted. The commenter

(20,059) stated that monthly measurements would not be sufficient to track wastewater treatment performance. One commenter

(20,150) requested monitoring equipment capable of detecting any discharge of organochlorine. The commenter (20,150) also wanted to disallow hourly averaging. One commenter (20,151) requested that the rule require monitoring and recordkeeping for the potential venting of HAP's from all potential discharge locations. Response: This rule , as NSPS and NESHAP programs have traditionally done , requires a combination of performance testing and continuous monitoring of control device operating parameters instead of monitoring the actual emission levels. Continuous

8-lparameter monitoring is consistent with section 504(b) of the

Act, which states that "continuous emission monitoring need not be required if alternative methods are available. . .for determining compliance." The "alternative method" presented in the rule is to monitor the control device parameters. The EPA has concluded in previous standards (e.g., the HON) that there is sufficient evidence to prove that pollution control equipment, if operating properly, can achieve high levels of HAP destruction. Data received from industry indicate that operational parameters provide an accurate indication of HAP destruction and emission levels. Operation parameter levels that ensure compliance are established during the initial performance testing effort, and continuous monitoring of operating parameters ensures continued compliance. Continuous emissions monitors for individual HAP species would add significant costs and burden to the industry without producing any environmental gain since the standard is based on total HAP. The parameter monitoring program contained in the final rule provides clear criteria for what is considered to be a violation. With the exception of biological treatment systems, a period of excess emissions (considered a violation of the standards) occurs when operating parameters that indicated compliance during the initial performance tests are exceeded. The monitoring approach for biological treatment systems is discussed later in this section. The final monitoring provisions are sufficient to detect exceedances and to determine the duration and extent of non-compliance. Providing a legal basis for effectively

8-2enforcing these emission limits does not require quantification of specific pollutants and emission levels.

Comment: Three commenters (20,027, 20,036A1, 20,056) claimed that the monitoring requirements are too burdensome on the industry. One commenter (20,036Al) stated that once the required process technology is installed and properly operated in order to produce the desired pulp quality, the operator has little or no effect on pollutant discharge. One commenter (20,056) contended that unless EPA can demonstrate the need for the proposed inspection schedule , one inspection every 6 months is appropriate. The commenter (20,056) stated that EPA must allow a facility the flexibility to determine the appropriate inspection schedule considering site-specific shutdown schedules, length of duct work , and history of repairs. One commenter (20,027) outlined several recommendations for changes to the proposed monitoring requirements which included not requiring chlorine monitoring from bleaching systems (since the effluent guidelines require Cl02 substitution), exempting process monitors from the monitoring plan specified in § 63.8(b), specifying a monitoring plan consistent with manufacturer's recommendation for calibration and maintenance, and allowing a ten percent deviation range around the initial performance test operating parameters that determine compliance. Response: The EPA has made every effort to reduce the monitoring burden and to require only those procedures that are necessary to determine continuous compliance. The continuous monitoring of control device parameters, as required by the NESHAP, is necessary to provide information that will satisfy the requirements of section 114(a)(3) of the Act for enhanced

8-3monitoring , certification of compliance status, and determination of continuous or intermittent compliance. The EPA considers the level of monitoring specified in the rule appropriate and necessary for compliance and disagrees with the commenters' assertion that the level is unwarranted. Most pollution control technologies specified in this rule (i.e., thermal oxidizers, caustic scrubbers, steam strippers, and closed vent systems) are not related to pulp quality. These systems are operated separately from the pulping and bleaching systems and must be operated such that the limits defined in this rule are met , regardless of what pulping and bleaching process adjustments need to be made to produce the desired pulp quality. For process equipment that is used to reduce emissions, appropriate monitoring parameters are required to be determined during the performance test. The initial performance test should be conducted during normal operation of the mill so that the monitoring parameters determined are indicative of continuous compliance. Process technologies that are outlined in the rule as pollution prevention measures (e.g., total chlorine free bleaching) satisfy the requirements of the rule when properly operated and no further measures would be needed for compliance. The EPA contends that the inspection schedule in the final rule (i.e. , monthly) is appropriate for ensuring continuous compliance and does not place an undue burden on the industry. A more frequent inspection schedule is not needed since EPA does not expect the closed-vent systems or closed collection systems to encounter significant breakdowns or defects that would be associated with problems that developed over a short period of time (e.g., one week). However, a less frequent inspection

8-4schedule is not appropriate since defects or potential problems would not be identified in a timely manner. The monitoring requirements specified in § 63.8(b) will not be waived for this rule. A 10 percent allowance above the established operating parameter compliance level is not allowed in the final rule. With the exception of biological treatment systems, the operational parameter levels that are determined during the performance test represent compliance and any exceedance will be judged as non-compliance. However, in setting the specified operating parameter level for determining compliance , a mill will determine this level based on parameter data monitored during the performance test, supplemented by engineering assessments and manufacturers' recommendations. The rationale and supporting information for the selected operating parameter must be submitted to the Administrator for approval.

Comment: Several commenters (20,011, 20,027, 20,054A2, IV-D2-15) requested that EPA allow some excursions and exemptions from monitoring to add flexibility to the parameter monitoring provisions. One commenter (20,054A2) supported excluding violations during startups, shutdowns, malfunctions, and during the first 48 hours in a reporting period. One commenter (20,011) stated that emergency venting should be an excusable excursion from otherwise applicable continuous monitoring requirements. One commenter (20,027) argued that because of process variability and lack of experience regarding continuous parameter monitoring systems, EPA must provide some provision for a certain number of excused excursions per reporting period. The commenter (20,027) offered to cooperate with EPA on such a project.

8-5Response: With the exception of biological treatment systems , monitoring excursions or exemptions during normal operation are not allowed in the rule (other than the allowed downtime allowances). The monitoring parameters identified during the initial performance test should be determined in a manner to account for process variability. If a facility believes that the initial monitoring parameters do not accurately demonstrate continuous compliance , the facility may retest, before any violation of the standard , and revise the monitoring parameters (i.e, revise their operating permit). For biological treatment systems, the rule identifies parameters to be monitored on a daily basis. Daily inlet and outlet samples must also be collected and archived for 5 days. The archived samples are used to demonstrate that the biological treatment system is achieving 92 percent reduction of total HAP if a specified monitoring parameter is outside the range established during the initial performance test. Quarterly performance monitoring for total HAP removal is also required in the final rule. To reduce the burden of sampling for total HAP during all four quarters , a mill may (during the first quarter test) establish a methanol percent removal that corresponds to at least 92 percent HAP removal , and only test for methanol percent reduction during the remaining quarterly tests. The general provisions allow for monitoring parameter excursions during periods of startup, shutdown, and malfunctions. The general provisions are being revised and will address the issue of venting episodes that occur due to safety-related

concerns. It is important for the source to include all known malfunctions in the startup, shutdown , and malfunction plan since

8-6a venting episode or monitoring parameter excursion that is not included in the plan counts as a violation.

Comment: One commenter (IV-D2-15) recommended that the final rule include more than one model for determining whether a biological system is adequate , because models are updated and improved frequently. The commenter requested that EPA's recommended test method protocol also allow use of the NCASI Organic Compound Elimination Pathway Model (NOCEPM). Response: The EPA recognizes the NCASI NOCEPM model as a credible biological degradation model; however, the WATER8 model, or updated versions , will be used to determine compliance because EPA has used WATER8 for demonstrating compliance with other rules and the NOCEPM model has several limitations (A-92-40, IV-B-23). However, industry has indicated that an updated version of NOCEPM is expected after promulgation. The EPA may amend the rule with a supplemental Federal Register notice to allow the use of the updated version of NOCEPM pending evaluation of the model.

Comment: One commenter (IV-D2-10) expressed concern over using emission factors to prove compliance with emission standards, noting that actual emissions data from the sources should be used whenever possible. Response: Emission factors are not used for demonstrating compliance with the rule. Compliance with the pulping and bleaching standards is determined based on emissions test data with the following exceptions. An initial performance test is not required for a thermal oxidizer meeting the temperature and residence time specified in the rule, nor for power boilers, lime kilns, and recovery furnaces that are used for controlling

8-7pulping process emissions. An initial performance test is also not required for bleaching systems that use TCF technologies. The initial and quarterly performance test for biological treatment systems used to comply with the pulping process wastewater standards requires that the destruction efficiency of the system be determined using a site-specific biodegradation rate factor calculated using EPA's WATER8 model (a systemspecific emissions model). Inputs to the model are obtained from the biological treatment system's monitoring and operating parameters. For determining compliance with the clean condensate alternative, emissions test data must be collected to determine the baseline HAP emissions and emission reductions that would have been achieved by implementing the MACT standards. The test data would also be used to substantiate the HAP emission reductions that are achieved using the alternative strategy.
8.2 CONTINUOUS EMISSIONS MONITORING
Comment: One commenter (20,049A2, 20,059) objected to EPA requiring parameter monitoring rather than continuous emissions monitoring systems (CEMS)

. The commenter (20,059) contended that EPA had not demonstrated that parameter monitoring is adequate for purposes of enforcement or protection of public health. The commenter (20,059) stated that EPA should require stringent monitoring of control devices so that operators have the incentive to properly maintain them and replace them before they deteriorate. One commenter (IV-D2-12) supported EPA's view that vents and streams subject to the regulation should be specifically identified and that parameter monitoring is a better approach

8-8than CEMS. Another commenter, (IV-D2-16) agreed that the proposal for initial performance testing is reasonable because no continuous monitoring system for methanol is available. Response: The use of CEMS is not necessary to demonstrate or assure compliance for certain pollutant and control strategy combinations. As demonstrated by the history of NSPS and NESHAP development , certain control devices are capable of achieving continuous levels of emission control, when they are welldesigned, operated, and maintained. The EPA maintains that no additional environmental benefit would be gained by requiring CEMS in this rule. Continuous parameter monitoring is consistent with section 504(b) of the Act, which states that "continuous emission monitoring need not be required if alternative methods are available..

. for determining compliance." The final rule requires that HAP emissions be controlled to a specified percent reduction, to a mass or concentration emission limit, or by applying specific equipment. A compliance demonstration is required for each emission point that demonstrates compliance by meeting a control device equipment specification or a percent reduction, mass , or concentration limit. Parameter monitoring provides the information needed to know whether control systems and other equipment are properly operated and maintained on a continuous basis.
Comment: Two commenters (20,049A2, 20,059, 20,085) contended that monitoring of specific pollutants should be required. One commenter (20,059) argued that speciated CEM data is needed in order to make sure that short-term averages are being achieved for all pollutants of concern. The commenter

8-9(20,059) expressed concern that the emissions reductions promised by this proposal will be unenforceable because of the lack of monitoring requirements for measuring actual emissions of specifi c HAP's. One commenter (20,085) asserted that if the risks from air toxics are to be properly evaluated and controlled, a monitoring component for specific pollutants should be included in the rule. Otherwise, the commenter (20,085) contended that it is unclear how the effectiveness of the MACT rule will be evaluated or how determinations of residual risk will be made in any meaningful way. One commenter (20,049A2) claimed that parameter monitoring would result in an inadequate amount of data to set "health protection" standards required by the Act. The commenter (20,059) stated that if parameter monitoring is used , EPA should not allow sources to select their own measures of compliance , but EPA must identify the appropriate range for each monitored parameter.
One commenter (20,049A2 and 20,059) considered the rule inadequate because it allows monitoring of total HAP's rather than specific air pollutants. The commenter (20,049A2) stated that this would result in larger amounts of less toxic pollutants reduced while not reducing more toxic pollutants. The commenter

(20,059) recommended that EPA investigate the applicability of
NCASI's test methods and other EPA test methods for periodic monitoring of speciated emissions at pulp mills, and explore the applicability of monitoring methods used by industrial hygienists. The commenter (20,059) also asserted that speciation would also be needed to protect the public's right to know and to assess the seriousness of a violation.

8-10Response: MACT standards are technology-based standards and are promulgated to achieve the maximum degree of reduction in HAP emissions considering the costs of achieving such emission reductions , any non-air quality health and environmental impacts, and energy impacts. While the Agency agrees that it would be advantageous to build a data base of specific HAP emissions for future consideration of section 112(f) for residual risk, the purpose of the monitoring requirements set forth in this rule is to ensure compliance with the MACT standards. The pulp and paper NESHAP reduces total HAP. Methanol is an appropriate indicator of total HAP since it is the dominant HAP present in pulping vents and condensates and since the control technologies identified in the rule do not remove HAP's preferentially. For bleaching vents , chlorine was designated as the surrogate for chlorinated HAP's (other than chloroform) because the MACT floor control technology, caustic scrubber , was installed primarily for chlorine control. For most systems, parameter monitoring adequately ensures continuous compliance with the MACT standards. To require continuous or periodic emissions monitoring of specific HAP's is unnecessary and will not provide additional pollution reductions. Monitoring health risks , is outside the scope of this rule. For biological treatment systems , continuous compliance is demonstrated using parameter monitoring combined with emissions modeling. The monitoring parameters specified for biological treatment systems are appropriate indicators that the system is being operated properly. If one of the monitoring parameters is outside the range established during the initial performance test, then compliance with the standard is demonstrated using the

8-11WATER8 emission model. This monitoring approach was developed since biological treatment systems and site-specific designs and may be achieving the HAP removal efficiency required by the standard even though one of the monitoring parameters is outside of the established range. With regard to the commenter's suggestion to use the NCASI test methods for periodic monitoring, the samples collected using the NCASI test methods must be analyzed before an indication of emissions can be determined. Consequently, the use of NCASI test methods for periodic monitoring does not provide an instantaneous indicator of continuous compliance unlike parameter monitoring. During the initial performance test, each facility must demonstrate compliance with applicable emission limits. At this time, the appropriate monitoring parameter values (i.e., those values recorded during the performance test when the source was achieving the MACT Standard) will be determined and specified in the source's permit. For the sulfite pulping and condensate segregatio n monitoring standards , EPA did not have sufficient informatio n to specify the parameters that should be monitored to demonstrat e continuous compliance. For those instances, or if an alternativ e parameter is chosen to be monitored instead of the parameter specified in the standard, then sufficient rationale must be submitted to the Administrator to justify the facility's assertion that the parameter chosen indicates that the control device or system is in compliance with the standard.

Comment: Two commenters (20,007, 20,059) disagreed with

EPA's decision not to require CEMS to measure total HAP's. One commenter (20,059) contended that CEMS should be required whenever technically feasible and for all pollutants that can be

8-12measured. The commenter (20,059) specifically stated that CEMS should be required for combustion sources at paper mills. One commenter (20,007) contended that they had demonstrated to EPA that an automated gas chromatographic system could be used to measure and speciate pertinent volatile HAP's. The commenter

(20,007) supplied a chromatogram illustrating the separation of 14 HAP's in less than 5 minutes in the 10 ppmv range. The commenter (20,007) also claimed that such devices would increase the accuracy of compliance demonstrations and contended that
EPA'S language in the rule regarding the technical impossibility of CEMS would limit technical advancement in the pollution monitoring field. The commenter (20,007) provided language to be included in the final rule that would allow CEMS. One commenter (20,059) contended that EPA mentioned that flame ionization analyzer (FIA) technology offered promise as a monitoring technique but rejected this option because it did not measure speciated emissions. The commenter (20,059) stated that the standards did not regulate individual pollutants and therefore EPA may have disqualified this control option prematurely. Response: The EPA has concluded that the use of CEMS is not technically feasible , does not provide any additional environmental benefit , and could significantly increase the cost and burden of demonstrating continuous compliance. The automated gas chromatographic system described by the commenter is used to comply with numerical limits for specific compounds identified in the facility's air permit. The proposed rule addresses total HAP emissions and does not establish numerical limits for individual HAP compounds. Therefore, an automated system for measuring

8-13specific HAP compounds would not be applicable. Additionally, establishing emission limits for individual HAP compounds for demonstrating compliance would require extensive emissions testing which would significantly increase the costs associated with compliance without providing any environmental benefit over parameter monitoring. As stated in the December 17, 1993 proposal, EPA believes that FIA technology would not increase the accuracy of compliance demonstrations and would place an undue burden on the affected industry. The EPA's position regarding FIA technology has not changed since proposal. 8.3 PARAMETER MONITORING
Comment: Two commenters (20,027, 20,054A2, IV-D2-15) recommended that EPA specify that § 63.8 of the general provisions is not applicable to process monitors for these standards, and that the monitoring and quality assurance plan for the control devices must be consistent with manufacturers' recommendations for calibration and maintenance. One commenter (20,043) stated that maintenance and calibration of monitoring devices was not adequately addressed in the proposed rule. Therefore, the commenter (20,043) asserted that requirements in the general provisions could not be met in practice. For example , the commenter (20,043) stated that zero and span checks on magnetic flow devices only reflect the operation of the electronics and not the magnetic field itself. The commenter (20,043) stated that one type of flow monitoring device, a delta pressure cell , contains a critical orifice which must be visually monitored to determine if its size is changing

8-14and stated that a zero and span check would not indicate this change.
One commenter (IV-D2-15 ) asserted that unlike continuous monitors , the instruments used to measure pH, steam flow, and feed flow for steam strippers and scrubbers, cannot be checked by a standard and cannot be evaluated using daily zero and span checks. The commenter (IV-D2-15 ) recommended that monitoring requirements recognize these differences and that EPA also specify that § 63.8 of the general provisions is not applicable to these process monitors. Response: The EPA disagrees with the commenters and believes that the specific sections in § 63.8 of the general provisions that apply to this rule are applicable to the required process monitors. However, if an owner or operator feels that the monitoring requirements in § 63.8 are not appropriate, the owner or operator may apply to the Administrator for an alternative monitoring method as outlined in § 63.8(f) of the general provisions to part 63.

Comment: One commenter (IV-D2-4) maintained that periodic performance testing is necessary to account for degradation of the process and control equipment , to determine if the operating and monitoring conditions initially set are still appropriate, and to adjust the surrogate parameters when necessary. Response: The calibration checks specified in § 63.8 of the general provisions are intended to identify and account for drift of monitoring devices. If the compliance status of a facility is in question, sectio n 11 4 of the Act authorizes the Administrator to conduct performance tests at any other time. If a facility believes that the parameter values selected during the initial

8-15performance test are no longer appropriate, the facility can

modify their operating permit to revise the initial parameter values based on additional performance test data. If process operating conditions change, or operation of the control device changes from those existing during the initial performance tests, then additional performance tests must be conducted such that

new, appropriate compliance parameters can be established.

Comment: One commenter (IV-D2-15) supported EPA's decision to use parameter monitoring and not to establish continuously enforceable sulfite limits. However, the commenter IV-D2-15) expressed concern that seasonal temperature changes and various pulp grade changes could require a lengthy period of time to establish which parameters need to be monitored in order to establish long-term compliance. The commenter suggested granting sulfite mills a compliance extension of 2 years to allow establishment of the monitoring parameters. The commenter (IV-D2-15) expressed concern that other enforcement initiatives will subject sulfite mills to penalties and enforcement actions that are not intended by this rule. The commenter urged EPA to establish clearly that: (1) monitoring parameters are used only as an indication that a process change has occurred, (2) if a source operates outside a parameter, then no violation is presumed, and (3) if a facility operates outside a parameter, then the facility's only obligation, after reporting, is to reestablish compliance at the new conditions. The commenter requested that if EPA could not establish these allowances, it should develop an equipment work practice standard for sulfite mills.

8-16One commenter (IV-D2-16 ) cautioned that existing sulfite recovery systems are designed to control sulfur dioxide, not methanol, and that there may be no practical parameter monitoring scheme to correlate methanol emissions. The commente r (IV-D2-16) suggested a joint industry study of methanol emission rates versus potential operating parameters, with the caveat in the rule that if the mill demonstrates during the test program that its emissions are consistently below the proposed emission rate or percent reduction requirement regardless of operating conditions, then no further routine testing or parameter monitoring will be required. Response: Th e EP A recognizes that there may be some difficulty in establishing appropriate monitoring parameters for sulfite pulping processes. The compliance schedule for sulfite processes specified in the rule is 3 years after the effective date. Th e EP A maintains that this time frame is sufficient for conducting the initial performance test to determine appropriate monitoring of parameter values. However, if additional time is needed to establish appropriate parameters, the mill may petition the Administrator to extend the compliance schedule for one additional year. The initial performance test should be executed during periods of normal operation. If a mill's processes are variable from an emissions standpoint , then the initial performance test should be conducted such that the parameters monitored are appropriate to indicate continuous compliance under all operating conditions that are likely to occur. If the facility later believes that compliance of the standard can be achieved at a different monitoring parameter value, the facility may conduct a

8-17performance test to demonstrate compliance and reestablish appropriate monitoring parameters (i.e., revise their operating permit) before any exceedance occurs.

Comment: Three commenters (20,011, 20,027, 20,054A2) disagreed with EPA's assertion that the monitoring of certain parameters was already being performed by industry and would not impose any additional costs on the industry. One commenter (20,054A2) explained that process monitors currently in use are not necessarily used for compliance monitoring, but for process information. Two commenters (20,027 , 20,054A2) contended that the inline process parameter monitors required by these standards are not similar to CEMS and continuous parameter monitoring would not be feasible. Two commenters (20,011 , 20,027) indicated that continuous parameter monitoring would impose an additional cost to the industry due to the accuracy and importance of required information. One commenter (20,151) requested that EPA specify, or provide guidance on what would be appropriate parameters to monitor for biological treatment systems. Response: Parameter values to be monitored by the continuous recording systems are chosen by the mill and submitted for approval by the Administrator after the initial performance

tests. Feasibility of using continuous monitoring of parameters is based on: (1) the need to demonstrate continuous compliance, (2) technical feasibility of the continuous parameter monitor and (3) cost or burden imposed by such a requirement. The EPA maintains that existing equipment can be used in most cases to provide continuous parameter monitoring since most of the monitoring parameters specified in the rule (e.g., thermal

8-18oxidizer temperature , steam stripper feed and steam application rates) are currently being tracked to provide an indication of proper operation. In other cases , new devices will need to be installed.

Comment: One commenter (20,059) contended that EPA needs to define combustion operating parameters to: (1) enable the establishment of a greater than 98 percent control efficiency requirement as MACT , and (2) ensure that the control device functions at the required levels. The commenter argued that the monitoring requirements were not sufficient to guarantee 98 percent HAP reduction. Response: The EPA has concluded, based on previous Agency studies, that temperature and residence time sufficiently define the combustion operation with respect to HAP destruction

(A-79-32, II-B-31). For boilers and lime kilns, combustion temperatures and residence times are more than sufficient to ensure at least 98 percent reduction of HAP's. For thermal oxidizers, EPA has outlined three compliance options; 98 percent HAP reduction , 20 ppmv (at 10 percent oxygen) outlet HAP concentration limit , or an operating level of 1,600 OF and 0.75 seconds residence time.
Comment: Three commenters (20,027, 20,054A2, IV-D2-15) disagreed with EPA's assumption that it is common practice to monitor scrubber inlet gas flow. The commenters (20,027, 20,054A2, IV-D2-15) stated that the industry practice is to monito r pH and/or scrubber liquid flow to ensure good performance for chlorine and Cl02 control, and some mills use oxidation/reduction potential as an alternate to pH.

8-19One commenter (20,043) approved of using a pH threshold for monitoring compliance because each scrubber has a specific pH threshold above which acceptable efficiency is maintained. The commenter (20,043) recommended that the rule should allow each scrubber to establish its own pH threshold. The commenter (20,043) also asserted that maintenance on scrubber monitoring devices can only be performed by breaking the line. For all bleach plant scrubber monitors , the commenter (20,043) recommended placing the pH electrodes in a high flow region of the system (i.e. , just downstream of the recirculating pump) to increase the reliability and decrease downtime. The commenter (20,043) recommended that the final rule allow the use of sample pots spliced off the main line to act as measurement points so that calibration and preventative maintenance can be performed with a minimum of lost material. One commenter (20,043) contended that EPA should allow the use of the last stack test for a measure of air flow as permanently installed pitot tubes would be impossible to accurately maintain. The commenter (20,043) claimed that periodic scrubber media flow measurements only indicate non-compliance when the flow approaches zero and a drop in the flow rate is not expected to result in non-compliance. Therefore, the commenter (20,043) concluded that monitoring of the flow rate is useful as part of a preventative maintenanceprogram but a drop in flow is not expected to indicate noncompliance. Response: The EPA contends that monitoring of inlet gas flow rate is necessary to prevent circumvention of the standard. During the initial performance test , a range of flow rates should

8-20be determined that reflect normal operations so that periodic fluctuations in the flow rate would not trigger a violation of the standard. Previous stack data measurements of flow rate are not allowed in the final rule. The rule specifies that the pH or oxidation/reduction potential of the scrubber effluent must be monitored. However, the facility has the flexibility to determine site-specific values.
Comment: One commenter (IV-D2-15) stated that mills that wish to demonstrate compliance with the percent reduction limit only be required to conduct a one-time performance test coupled with monitoring of scrubber parameters. Response: The final rule specifies that during the initial performance test , appropriate parameter values are determined. For compliance purposes , only the parameter values need to be monitored and recorded.

Comment: One commenter (20,027) argued that EPA should revise the monitoring requirements for steam strippers. Two commenters (20,027 , 20,054A2) stated that monitoring of the mass feed rate is not practiced in the industry, but the industry does monitor flow rates. Three commenters (20,027, 20,054A2, IV-D2-15) recommended monitoring the steam-to-flow ratio which has been demonstrated to have a direct relationship to stripper removal efficiency , rather than monitoring the mass feed rate. One commenter (20,043) indicated that the steam stripper monitoring devices are inline and are not readily accessible to routine maintenance and calibration. Response: The EPA revised the steam stripper monitoring requirements to include feed flow rate, steam flow rate, and feed

8-21temperature. The EPA has concluded that monitoring these parameters will provide an acceptable indication of steam stripper performance and HAP reduction efficiency since the steam-to-feed ratio has the greatest influence in HAP removal.

Comment: One commenter (20,027) recommended monthly inlet and outlet methanol concentration tests for the compliance demonstration for mills using biological treatment. The commenter (20,027) acknowledged that daily or weekly soluble BOD5 measurements could be used as an indicator of normal biological treatment system operation since methanol has an extremely high solubility. However, the commenter (20,027) recommended that soluble BOD not be used as a means of determining compliance with a MACT standard. One commenter (20,151) requested that EPA specify, or provide guidance on , what would be appropriate parameters to monitor for biological treatment systems. In response to the March 8 , 1996 supplemental notice, one

commente r (IV-D2-15), disagreed with the use of soluble BOD5 as a compliance measure for determining whether a biological treatment system is adequate. The commenter (IV-D2-15) supported measuring the inlet and outlet methanol concentrations to determine compliance. The commenter (IV-D2-15) claimed that, based on results of NCASI testing in 1995 , the following monitoring scheme for biological treatment systems should be followed:
1. Monitoring of soluble BOD (in ppmw) into and out of the system on the same frequency as BOD is required to be monitored in the mill's NPDES permit.

2. Daily monitoring of methanol (in ppmw) into and out of the system commencing within 24 hours of determining that soluble BOD removal has dropped below 80 percent and continuing until greater than 90 percent methanol

8-22removal or methanol outlet concentrations below 5 ppmw are measured for 3 consecutive days.

3. Non-compliance would be determined by measured methanol removal efficiencies below 90 percent with outlet concentrations in excess of 5 ppmw. Another commenter (IV-D2-5) suggested that inhibited soluble
BOD5 be used instead of soluble BOD as a surrogate parameter for methanol removal efficiency because the suggested parameter

(soluble BOD5) ignores the effects of ammonia and looks only at hydrocarbons such as methanol. One commenter (20,076 and 20,045), however , suggested that measurement of soluble BOD5 would be a good indicator of methanol removal efficiency and as a means of demonstrating compliance with the MACT rule. One commenter (20,059) stated that EPA should require more frequent monitoring of the HAP content of the incoming and treated wastewater by sampling liquid streams and speciating their constituents. Response: In the December 17, 1993 proposed rule, the monitoring parameters specified for biological treatment systems were inlet and outlet methanol concentrations determined every 30 days and appropriate parameters as specified in the operating permit and demonstrated to the satisfaction of the Administrator. The proposed monitoring requirements for biological treatment systems have been revised in the final rule to more accurately reflect the operation of these systems, based on comments and discussions with industry (A-92-40, IV-E-83, 84, 87). The final rule specifies the following monitoring parameters:

(1) composite daily sample of outlet soluble BOD5 concentration to compare to maximum daily and monthly averages, (2) inlet liquid flow, (3) mixed liquor volatile suspended solids,

8-23(4) liquid temperature , and (5) average horsepower of aerator units. Also , daily inlet and outlet samples must be collected and archived. If the soluble BOD , mixed liquor volatile suspended solids, or the horsepower of the aeration units is outside of the range established during the initial performance test, then the archived samples must be used to demonstrate that the biological treatment system is achieving 92 percent reduction of total HAP. The EPA asserts that no additional environmental benefit would be obtained by requiring monitoring of speciated HAP's entering the biological treatment system since the standard is based on total HAP.
Comment: On e commenter (20,110) requested that EPA amend the rule to incorporate telemetering, alarm indications, and other administrative controls on non-incinerated venting of pulping component gas collection systems from dedicated bypass vents, rupture disks , and other potential discharge locations. Response: The EPA maintains that mills already have indicators of venting and bypass anomalies to provide for worker safety. The EPA has concluded that a requirement of telemetering and alarms add unnecessary burden and do not provide an environmental benefit. The rule requires mills to report the date and duration of any venting anomalies.
8.4 LEAK DETECTION AND INSPECTION
Comment: The December 17 , 1993 proposed rule required closed-vent systems to be visually inspected every 30 days and measured initially and annually to demonstrate no detectable leaks. Several commenters (20,011, 20,027, 20,054A2, 20,056, 20,118, 20,146, IV-D2-15) asserted that requirements for leak checks and visual inspections of closed-vent systems are costly

8-24and unnecessary and recommended that EPA provide an exemption from monitoring for enclosures and closed-vent systems operating
under a vacuum. One commenter (IV-D2-15) stated that closed-vent systems are designed to operate under negative pressure, and visual inspection of negative pressure systems would not provide any additional benefits beyond current industry inspection methods. The commenter (IV-D2-15) suggested that visual inspections be required only for positive pressure systems. The commenter (IV-D2-15) also stated that when visual inspections are appropriate , an annual inspection would be sufficient. One commenter (20,027) asserted that there should be annual and startup leak detection and initial and bi-annual visual inspection for positive pressure vent systems. Two commenters (20,027 , 20,054A2) recommended a workpractice standard that would only require visual inspections of positive-pressure closed vent systems. Two commenters (20,027, 20,054A2) explained that inspections should be conducted upon startup and upon at least two additional occasions annually. One commenter (20,059) contended that EPA should require a hydrocarbon analyzer be used instead of visual monitoring for detecting leaks in ductwork.
One commenter (20,036Al) contended that the monitoring requirements in the proposed rule , such as monitoring of negative

pressures, leak detection with a portable hydrocarbon detector for leaks greater than 500 ppmv , and bypass line monitoring are unnecessary and illogical for sulfite mills where any loss of sulfur dioxide over one pound is a major upset and must be reported to the National Response Center. The commenter

(20,036~) claimed that the lower odor threshold of sulfite

8-25mills, between 0.3 and 1 ppmv , makes the hydrocarbon analyzer requirement of 500 ppmv unnecessary. Response: The final rule makes distinctions between positive and negative pressure portions of closed-vent systems. For positive pressure portions of the closed-vent system, the rule requires monthly visual inspections and initial and annual leak detection measurements. For negative pressure portions of the closed vent systems , the rule requires monthly visual inspections and annual demonstrations that each enclosure opening is maintained at a negative pressure. The EPA concluded that leak measurements for negative pressure systems would not be necessary if a mill could annually document that its system was operating at a negative pressure. This decision to remove the leak test requirement from negative pressure systems was made because industry burden will be reduced without sacrificing environmental benefits since any leaks in a negative pressure closed-vent system would not cause a release of pollution but would draw air into the system.

Comment: Two commenters (20,102 , 20,129) recommended a leak detection standard of 50 ppmv instead of 500 ppmv in the rule. The commenters (20,102 , 20,129) contended that this requirement was reasonable because it is already used in New York and California for detecting fugitives from local exhaust ventilation systems from dry cleaning operations. The commenters (20,102, 20,129) proposed an alternative requirement of a local exhaust velocity of 50 ft/min or sufficient inward air flow as indicated by visible smoke tube tests to indicate proper inward air flow and negative pressures to properly capture HAP emissions from pulping equipment. The commenters (20,102, 20,129) claimed that

8-26these provisions are standard industrial hygiene ventilation provisions that are easily used. Response: The EPA has concluded that the 500 ppmv leak detection standard provides an adequate level of leak prevention since this detection standard is consistent with other leak detection standards that EPA has promulgated. The 500 ppmv limit is associated with the accuracy limit of the detection device used in Method 21 (for more details see EPA Method 21). State implementation plans have the authority to lower the leak detection standard below 500 ppmv.
8.5 BYPASS VENTS
Comment: In the December 17, 1993 proposal, bypass line valves were required either to (1) have a flow indicator installed, calibrated, and maintained to indicate flow, or (2) to be closed with a car-seal or lock-and-key type configuration and to be visually inspected every 30 days. One commenter (20,027) considered the sealing of bypass vents to be an emission control requirement that must be evaluated as part of the floor. For safety reasons , several commenters (20,011, 20,027, 20,054A2, 20,146) stressed that bypass lines should not be sealed and enclosure openings should not be locked. The commenters (20,027, 20,054A2) recommended allowing other means of monitoring venting, such as manual log entries for manually operated by-pass valves, valve position , and flow indicators (where applicable). Response: The purpose of establishing requirements for bypass vents is to minimize the events in which vent streams are released to the atmosphere. Monitoring requirements such as bypass line seals are an aspect of compliance and are not based on MACT floor determinations. Based on an evaluation of the

8-27industry's comments , EPA has revised the bypass line requirements to include log entries recording pertinent information such as valve position, flow rate, and flow direction. The requirements for a lock-and-key type seal have been revised to specify easily broken seals (i.e. , car-seals) for bypass line valves due to safety concerns.
Comment: One commenter (20,054A2) contended that monitoring flow through bypass lines would not be of any benefit since the flow indicator cannot distinguish between inward and outward
flow. Another commenter (20,056) stated that industry should be given the flexibility to utilize other devices such as temperature sensors and chemical sensors, and other methods such as manufacturers' recommendations , sound engineering practices, and professional judgement instead of specifying a flow measuring device be installed on bypass and vent lines. The commenter

(20,056) stated that EPA may suggest compliance parameters that may be monitored but should allow for States to allow other parameters for source monitoring. Response: The rule contains two sets of requirements for monitoring bypass lines. The first set of requirements is the installation of a flow indicator in the bypass line which provides a record of the presence of gas stream flow in the bypass line at least once every 15 minutes. The second set of requirements is the installation and maintenance of a bypass line valve, monthly log entries of valve inspections, and a seal on the valve mechanism that ensures that the valve or closure mechanism cannot be opened without breaking the seal. The EPA believes that flow into a closed-vent system from the bypass line is unlikely and that any flow in a bypass line would be outward.

8-28If a mill does not wish to use the monitoring procedures specified in the rule , the mill may request that the Administrator allow an alternate monitoring method through the procedure outlined in § 63.8(f) of the general provisions to part 63.

8-299.0 TEST METHODS AND PROCEDURES

9. 1 FIVE-MILL SAMPLING PROGRAM
Comment: Three commenters (20,011, 20,027, 20,056) contended that the data gathered from the five-mill sampling study should not have been used to develop the December 17, 1993 proposal because the test methods and data were suspect. One commenter (20,027) stated that EPA's main contractor had major concerns about the use of certain methods employed in the

program, including draft Method 0011 for aldehydes and ketones and Method 26A for hydrogen chloride (HCl) in sources with chlorine and Cl02 present. One commenter (20,056) stated that the laboratory performing Method 0011 analysis of aldehydes and ketones conceded that there was difficulty with contamination problems for process liquid samples. The commenter (20,056) asserted that the aldehyde and ketone data were suspect. The commenter (20,056) also stated that EPA's characterizations of chlorine and HCl emissions are questionable since the test method used (Method 26A) could produce positive bias when used in the presence of ClO2. One commenter (20,027) expressed concerns about the validity of the sampling results described in the BID (A-92-40 , II-A-35), since there were conflicting results for the same compound when measured by different sampling procedures.

9-lResponse: At the time of proposal, the test methods used for the five-mill study were considered appropriate because they were the best available test methods for measuring the pollutants of interest at the time. The data from the five-mill study have since been supplemented by industry-supplied test data. The Agency recognizes the difficulties associated with the methods used in the five-mill study , and was cautious when incorporating the five-mill study results into the development of revised emission factors. As discussed in chapter 2 , the proposal data base relied on model process units derived from emission points. The emission points were characterized by the five-mill study. Based on comments and data received following proposal, the approach used to develop the emission factors has been revised from an emission point to a mill-system approach. In the revised approach, data from the five-mill study were only used where complete mill systems were tested (e.g. , all emission points in a pulp washing system). This helped EPA to examine all the data on an equivalent basis. The five-mill test data generally fell within the range of the industry-supplied test data when evaluated on the mill-system basis. The analyses of these data are detailed in the revised emission factor document (A-92-40, IV-A-8).

Comment: One commenter (20,056) stated that the NCASI methanol impinger method utilized by EPA was believed to be susceptible to false high bias: entrained moisture (containing a higher concentration of methanol) is trapped due to the method's high sampling flow rate. The commenter (20,056) stated that the new industry testing program does not contain this bias since the

9-2heated SUMMA canister method was conducted concurrently with the NCASI impinger method for quality assurance. Response: At four of the five sites tested, the NCASI methanol impinger method was not operated at a sampling rate high enough that would likely entrain liquid droplets. The methanol data collected at the fifth site may have been susceptible to the high bias. However, as stated earlier in this section, the data collected in the EPA five-mill study was supplemented with data collected by industry. The available data (both EPA and industry data) were evaluated using a mill-system approach and the data collected in the five-mill study was retained in the analysis since EPA data generally fell within the range of the industrysupplied data. 9.2 REQUIRED TEST METHODS
Comment: One commenter (20,011) claimed that Method 21 was inappropriate for methanol, TRS , and other volatile compounds. Response: The EPA maintains that Method 21 is appropriate for methanol and VOC leak measurement because it is the accepted measurement method. Additionally , the leak measurements specified in the rule, based on Method 21, do not require the measurement of TRS compounds.
Comment: Two commenters (20,027 , 20,056) indicated that Cl02 has been shown to interfere with the accuracy of test Method 26A; thus , this method may not be appropriate for measuring emissions from bleach plant sources. One commenter

(20,027) recommended modifying Method 26A by replacing the alkaline impinger with a potassium iodide impinger so that chlorine and Cl02 can be measured accurately in bleach plant

gases.

9-3One commenter (IV-D2-15) asserted that Cl02 is listed as a potential interferant to Method 26A, which was required at proposal to measure chlorine emissions. The commenter (IV-D2-15) concluded that it would not be appropriate to use Method 26A for measuring bleach plant emissions. The commenter (IV-D2-15) recommended an NCASI method which uses potassium iodide as an absorbing solution followed by dual pH titration. The commenter

(IV-D2-15) stated that this method has been submitted to EPA for approval as a validated method for bleach plant sources. Response: The EPA agrees with the commenters regarding the potential interference from C102. Chlorine dioxide is a listed interferant in Method 26A. The final rule contains specific modifications to Method 26A to make the method appropriate for determining chlorine concentration in the presence of C102.

Comment: Two commenters (20,027 , 20,011) asserted that the proposed test method for sampling methanol, proposed Method 308, has not been evaluated using Method 301 validation criteria. The commenter (20,027) submitted several minor changes to the proposed Method 308 that should be made to allow additional flexibility in the method. Another commenter (20,087) specifically noted problems with sections 2.1.6, 2.1.9, 3.2.3, 3.2.4, 3.2.5, 4.1.2, 4.1.3, 4.2.1, 4.3.2.3, and 6.1 of proposed Method 308. The commenter (20,087) suggested language that would solve the problems. Response: The proposed Method 308 has been validated using Method 301 validation criteria. The validation was conducted by the Atmospheric Research and Environmental Analysis Laboratory in
EPA's ORD. The results of the validation were reported in the January 1995 issue of the Journal of the Air and Waste Management

9-4Association. Method 308 was promulgated in this rulemaking and has been revised to incorporate the technical comments provided by the commenter.
Comment: One commenter (20,027) declared that EPA should recognize the applicability of the NCASI NOCEPM model and allow its use as an alternative to the WATER7 model since its applicability to the treatment of pulp and paper wastewaters is well accepted. The commenter (20,027) noted that the biological degradation kinetics in the WATER7 model are based on the twoparameter Monod kinetics; however , Method 304 (the required Method) provides a single rate parameter (first order) which cannot be used directly as an input to the WATER7 model. Rather, WATER7 must be "forced" to assume a first-order relationship in order to use the results obtained from Method 304. Response: [Note: The WATER8 model is an update to the WATER7 model]. The EPA recognizes the NCASI NOCEPM model as a credible biological degradation model. However, the WATER8 model will be used to determine compliance because EPA has used WATER8 for demonstrating compliance with other rules and the NCASI NOCEPM model has the following limitations: inability to support Monod kinetics ; inability to simulate plug-flow or sequential reaction; and inability to model recycle flow, clarifiers, collection system elements, screens , and trenches (A-92-40, IV-B-23). However, industry has indicated that an updated version of NOCEPM is expected after promulgation. The EPA may amend the rule with a supplemental Federal Register notice to allow the use of the updated version of NOCEPM pending evaluation of the model.

9-5The WATER8 model still incorporates the two-parameter Monod kinetics ; therefore, the WATER8 model will need to be set up properly if single rate parameters from Method 304 are used for WATER8 inputs. The EPA maintains that the WATER8 model provides acceptable results with the modified setup needed to incorporate Method 304 results.
Comment: One commenter (20,011) asserted that the Method 305 procedure for determining the HAP content of a waste stream is unnecessarily complex for methanol, and differs from the version proposed in the HON. The commenter (20,011) claimed that the method has not been validated or published for comment. Response: Method 305 in the proposed rule is the same as the method specified for compliance testing under the HON. The method was published for comment with the proposed HON and was promulgated with the final HON. The method has been validated by Method 301 and was extensively evaluated in the laboratory before proposal with the HON. In March 1997, industry informed EPA that it had not used Method 305 to obtain the methanol steam stripper performance data

(which was used as the basis for the proposed pulping process condensate standards). Instead, a direct aqueous injection gas chromatography/flame ionization detection (GC/FID) method was used (NCASI Technical Bulletin No. 684, Appendix I). Consequently , the industry contends that Method 305 should not be specified in the final rule for determining compliance with the pulping process condensate standards. However, the NCASI test method has not been validated using EPA Method 301 procedures. If the Agency approves the Method 301 validation procedures for
NCASI's GC/FID test method , this method may be referenced as

9-6either an alternative or a replacement for Method 305 (for determining methanol concentration only) with a supplemental Federal Register notice since it is unlikely that the test method validation would be completed before promulgation of the MACT standard.
Comment: One commenter (20,144) indicated that target compounds must be specified for Method 305, because the analytical methods are compound specific. The commenter (20,144) asked if the compounds specified in the preamble in section X.A.3 would constitute such a list. Response: The final rule specifies that Method 305 must be used to determine the methanol or total HAP concentration in process liquid streams. In determining the total HAP concentration for use in the mass flow rate, mass per megagram of pulp produced , or the mass percent reduction requirements demonstrations, the final rule contains the criteria for excluding compounds. Compounds with concentrations at the point of determination that are below 1 ppmw or compounds with concentrations at the point of determination that are below the lower detection limit where the lower detection limit is greater than 1 ppmw are not required to be included in the total HAP concentration determination.

Comment: One commenter (20,011) stated that Method 25D for determining compliance with the wastewater requirements in the proposed rule was not employed during the testing program, and may be inappropriate for use on pulp mill sources. The commenter

(20,011) requested that EPA clarify which test methods must be used to verify compliance when biological treatment systems are used.

9-7Response: The rule does not specify the use of Method 25D. The rule requires the use of Method 305 for determining the methanol (surrogate for total HAP) concentration in wastewater

streams. For determining compliance with the biological treatment system, the fraction of methanol degraded in the system is determined by using the procedures specified in appendix C of part 63 (except that the inlet/outlet test can not be used for systems that are not well-mixed). The proposed rule incorrectly indicated that Method 304 was contained in appendix A of part 63. Method 304 is contained in appendix C of part 63. This change has been made in the final rule.

Comment: Two commenters (20,102 , 20,129) requested that the test methods and procedures in § 63.451 include equations for combustion efficiency used in RCRA 40 CFR 264 to ensure adequate calculation and specification of combustion efficiency using CO and CO 2 emission values. Response: The final rule specifies the equation for calculating the percent destruction on a mass basis. With regard to the commenters ' suggestion to monitor CO and CO 2 to indicate combustion efficiency , EPA asserts that these monitoring requirements would place additional burden on the affected facilities without providing a substantive improvement in monitoring combustion device efficiency. For thermal oxidizers, the rule requires the facility to monitor the combustion device temperature. Since this parameter is determined during the initial performance test , EPA contends that this parameter is sufficient for monitoring thermal oxidizer efficiency. The rule also allows using power boilers, recovery furnaces, and lime

9-8kilns for controlling pulping process emissions. No monitoring requirements or initial performance tests are required for these devices since the HAP destruction efficiency should exceed the 98 percent required in the rule when the devices are properly operated.
Comment: One commenter (20,056) recommended allowing the mass of pulp produced during a sampling event (for determining the mass emission rate) to be determined over a longer period of time than proposed sampling period to allow for periods when the pulping process may be curtailed or even shut down while other processes may continue to run. Response: The EPA disagrees with the commenter's suggestion. While some processes in the mill may have some degree of independence due to in-process storage, EPA asserts that periods of shutdown of all or part of the mill to which the commenter alludes , do not constitute normal operation with regard to any emissions testing program. The EPA recommends that any emissions testing be conducted when the pulp production process is in normal operation.

Comment: One commenter (20,070Al) stated that sampling procedures required to demonstrate compliance with percent destruction option for the combustion standards could expose personnel to safety hazards when sampling inlet gas streams. Response: The EPA recognizes the safety concerns expressed by the commenter. In the final rule, several control options are provided for complying with the pulping process standards. The EPA's intent in providing compliance options was to allow mills flexibility in demonstrating compliance. If a mill does not feel comfortable with sampling inlet gas streams to demonstrate

9-9compliance with percent destruction requirements due to safety

concerns, the mill may choose one of the other control options

(e.g., outlet concentration).

Comment: One commenter (20,144) indicated that the rule does not allow for any vacillation around the monitored parameters (minimum or maximum) and, therefore, compliance with the rule would be impossible. The commenter (20,144) suggested that the rule specify an averaging time for each of the parameters specified in § 63.452. Response: The final rule does not specify averaging times for monitoring parameters. Rather, the final rule specifies that the owner or operator shall provide for the Administrator's approval, the rationale for the selected operating parameter to be monitored , the monitoring frequency, and the averaging time.

9-1010.0 RECORDKEEPING AND REPORTING

Comment: The reporting and recordkeeping requirements of the general provisions apply to all sources subject to the NESHAP unless a relevant standard specifically exempts or modifies those requirements. The December 17 , 1993 proposal was issued prior to the final development of the general provisions. The proposal specifically required the recordkeeping requirements located in
§ 63.10(a), (b), and (c) for monitoring parameters. The proposal also required the reporting requirements found in the general provisions in the following reports:

. Initial Notification [§§ 63.9(a) through (d); 63.10(f)];

. Notification of Performance Tests [§§ 63.7; 63.9(g)];

. Notification of Compliance Status [§ 63.9(h)];

. Exceedance Reports [§ 63.10(e) (3) (i) through (v) and (viii)]; and

. Summary Reports (quarterly) [§ 63.10(e)(3)]. Several commenters (20,011, 20,027, 20,083, 20,102, 20,103) opposed the reporting time of 45 days for Initial Notification as being completely unrealistic in light of the realities of compliance planning. Several commenters (20,027, 20,056, 20,083) contended that the recordkeeping and reporting requirements were excessive and may be contrary to the Paperwork Reduction Act.

10-lTwo commenters (20,056 , 20,102) indicated that the recordkeeping and reporting required may take as long as 1 year to develop and implement. One commenter (20,056) estimated that the industrywide cost for implementing a digital-based reporting system to be between $500 million and $1 billion. Another commenter (20,083) stated that EPA's estimate that the recordkeeping and reporting burden of the proposed rule would require 923 to 1,797 man-hours or approximately between one half and one person-year per source to implement was considerable , but asserted that EPA's estimates of recordkeeping and reporting are only a small fraction of the
true burden. One commenter (20,018) agreed with industry recommendations to reduce the recordkeeping and reporting burden, and provided some additional recommendations including: eliminate the requirement to retain monitoring values if the values show routine compliance , retain only outlying monitoring values, eliminate the requirement to retain all records, retain only those records specifically identified by name, and eliminate the reporting of data that is already required under other EPA, State, or local rules. One commenter (20,102) also stated that if EPA provides guidance to State and local agencies as to what is acceptable for notification of performance tests , then 75 calendar days for notification is sufficient. One commenter (20,027) concluded that EPA must amend the monitoring , recordkeeping , and reporting requirements of the proposal to conform to the less stringent requirements adopted in the HON.

10-2On e commenter (IV-D2-15) contended that proposed reporting, recordkeeping , and monitoring requirements go well beyond what is reasonable or necessary. Response: The recordkeeping and reporting requirements in the December 17 , 1993 proposal were based on the requirements in the proposed general provisions. The final general provisions, which now have been promulgated , reduce some of the compliance burden relative to the proposed version. In addition, the final pulp and paper rule provides exemptions and modifications from some of the general provisions. The pulp and paper rule incorporates by reference specific sections of the general provisions for clarity. In the final rule , EPA revised the recordkeeping and reporting requirements to reflect revisions to the general provisions and to respond to concerns expressed by commenters. Specific revisions include the following:

. Due date for Initial Notification was changed from 45 days to 1 year.

. Information required in Initial Notification report was greatly reduced.

. Changes were made regarding the need for, and frequency of, quarterly excess emission reports.

. Performance Test deadline was extended from 120 to 180 days , along with a change in the notification of test date from 75 to 60 days.

. Changes were in requirements for site specific test plans.

. Clarification of the difference between "performance test" and "performance evaluation."

10-3. "Step-by-step" procedures in startup, shutdown, and malfunction plans were deleted.

. A non-binding control strategy report was added to be submitted with the Initial Notification and every 2 years, beginning 1 year following promulgation. This requirement is for owners or operators of sources selecting the extended compliance plan specified in § 63.440(d ) (1 ) of the rule.

. An option was added for Regional EPA offices to waive duplicate submittal of notifications and reports.

. A requirement for owners or operators to maintain a record of their determination of their area source status was added to show that a relevant standard does not apply to them (assume this will not affect any of NESHAP pulp and paper mills). In addition to these specific recordkeeping and reporting revisions, the final rule specifically names the process streams that ar e subject t o control by the rule. This approac h als o will reduce the recordkeeping and reporting requirements, because characteristics of individual process streams will not have to be reported.
Comment: One commenter (20,056) objected to retaining records for 5 years but recommended keeping them for 2 years. Response: The EPA disagrees with the commenter and does not believe that retaining records for 2 years is sufficient because it does not provide adequate detail on the history of the mill. The EPA believes that retaining records for 5 years (first
2 years on site , remaining 3 years off site) as specified in the general provisions is appropriate. The EPA maintains that 5 years of records are needed to provide adequate compliance history for each mill.

10-4Comment: One commenter (20,110) suggested that the rule incorporate recordkeeping requirements and other administrative controls on the venting of non-incinerated vent streams

(i.e., by-pass and emergency vents) from pulping component gas collection systems , from dedicated bypass vents, from rupture disks, and from other potential discharge locations. Response: The EPA agrees with the commenter; however the rule already requires owners or operators to report venting of uncontrolled streams (i.e. , by-pass and emergency vents) as specified in § 63.10.
Comment: One commenter (20,092) contended that the rule should require quarterly reporting until 2 years pass without an exceedance of any State or federal emission limitations applicable to the source. The commenter (20,092) stated that once this occurs , semi-annual reporting is acceptable, provided that any exceedance triggers a renewal of quarterly reporting. Response: The EPA disagrees with the commenter's recommendation of requiring quarterly reports for the first 2 years. The EPA maintains that semi-annual requirements, as specified in the general provisions, is consistent with other rules and provides sufficient reporting frequency. An owner or operator is required to submit quarterly reports if any excess emissions occur during the reporting period. The commenter's recommendation would place undue reporting burden on the affected industry without achieving any significant environmental benefit.

10-511.0 COST/ECONOMIC IMPACTS

11.1 COST IMPACTS
Comment: Several commenters (20,014, 20,018, 20,027, 20,028, 20,039, 20,046, 20,067, 20,07OAl, 20,071) stated that EPA severely underestimated the compliance costs of the proposed MACT standards. One commenter (20,039) stated that the final costs of compliance with the proposed rules may approach $20 billion as opposed to the $4 billion projected by EPA. One commenter

(20,070Al) stated that the capital costs to comply with the cluster regulations could be at least $300 million, and may be twice this amount depending on the degree to which the final rule differs from the proposed rule. One commenter (20,046) stated that EPA's compliance cost estimate used for their mill was less than half the cost of the estimate determined by the commenter and industry experts. Another commenter (20,067) stated that an estimated $350 million will be spent on compliance modifications for 11 out of 12 mills and an additional $100 million may be spent depending on interpretation of several vague definitions, terms, and phrases in the proposed NESHAP. One commenter (20,014) indicated that EPA did not take into account the cost of lost production during construction or modification. One commenter (20,074)

11-lurged EPA to adopt the proposal made by the American Pulp and Paper Industry which met the stated goals of EPA for this rulemaking. The commenter (20,074) added that the cost of the industry proposal was $1 million compared to EPA's proposed rule at $2 million. Another commenter (20,148) contended that EPA lacks sufficient data for development of this standard. The commenter

(20,148) suggested that the true costs and benefits cannot be determined until sufficient data are obtained. Response: After review of the comments on the proposed rule and additional data supplied by the commenters and pulp and paper industry representatives , EPA has made significant changes for the final pulp and paper NESHAP. Among the significant changes

are: subcategorization of the industry , requiring only specific named vent and wastewater streams to be controlled, and providing several options for control. By subcategorizing the industry, EPA has evaluated the level of control at existing kraft, soda, semi-chemical, and sulfite mills individually. As a result , the control requirements for soda and semi-chemical mills are significantly reduced from the requirements for kraft mills , and the control requirements for sulfite mills are specific to sulfite mills and not transferred from kraft mills. The final rule requires only specific named vent and wastewater streams to be controlled in each of the subcategories. Therefore, the number of emission points that are required to be controlled , and the cost of compliance, have been significantly reduced from proposal. The EPA believes these changes will reduce much of the commenter's concern about confusion in the rule.

11-2The final rule also provides several options for controlling

vents and wastewater that will allow the owner or operator the flexibility of choosing the best option for their mill. For example, kraft mills complying with the wastewater requirements can choose either to use a steam stripper or to hard-pipe wastewater to a well-operated biotreatment unit. Sulfite mills have the flexibility of complying with emission limits or percent reduction requirements with any technology that can meet the requirements. The EPA believes that these changes, as well as other changes to the final rule, will significantly reduce the compliance cost of the rule. Additionally, EPA has revised the national cost impacts to incorporate new data supplied by commenters and representatives of the pulp and paper industry. The new data include: information to characterize vent streams (temperature, flow rate, and moisture content); description of equipment in vent gas treatment systems; updates to the data base characterizing the equipment and processes at pulp and paper mills, and cost information for condensate segregation and other controls. The commenters are referred to chapter 20 of this document and EPA's memorandum discussing the costing changes (A-92-40, IV-B-13). Changes made to the costs for the effluent guidelines are discussed in the preamble for the promulgated air and water rules. The EPA contends that the costs in the final impacts analysis represent an appropriate estimate of the cost of compliance with the final rule.

11-311.2 ECONOMIC IMPACTS
Comment: Two commenters (20,115A2, 20,117) argued that EPA did not properly evaluate the effect of the proposed rule on the nation's economy. Response: Total impacts on employment and output, both direct and indirect, are estimated with final-demand nationallevel input-output multipliers from the U.S. Department of Commerce's Regional Input-Output Modeling System (RIMS II: Pigler 1993) which provides estimates of losses in employment, shipments, and Gross Domestic Product. These impacts are reported in the Economic Analysis for the National Emission Standards for Hazardous Air Pollutants for Source Category: Pulp and Paper Production; Effluent Limitations Guidelines,
Pretreatment Standards , and New Source Performance Standards: Pulp, Paper, and Paperboard Category- Phase 1 (A-92-40, I-A-2)

(hereafter referred to as EA). These estimated effects on employment, output , and shipments relate to both direct and indirect economic impacts of the combined air and water pulp and paper rule.
Comment: On e commenter (20,025) provided a number of comments concerning the market model used to estimate market impacts of the regulation at proposal. The comments included specific criticism of the supply and demand parameter assumptions of the model , the methods used to determine market equilibrium, and other alleged model deficiencies. Response: The EPA used a market model and a financial model to estimate market impacts for proposal of the regulations. However for promulgation of the final rules, the EPA chose to use only the financial model with some modifications to estimate

11-4market impacts and to predict mill closures. The EPA concluded significant market changes have occurred since proposal that would necessitate an update of data used in the market model. These data updates could only be accomplished through an additional updated survey of all mills in the pulp and paper industry. Since such a survey would be burdensome to the industry and would require significant time and resources, the

EP A elected to utilize the financial model with modifications for promulgation. Thus comments relating specifically to assumptions underlying the market model are moot for the economic analysis conducted for the final rules.

Comment: Several commenters (20,009, 20,057, 20,103, 20,104, 20,115A2, 20,117) indicated that the economic burden of the proposed rules will force some facilities to close. One

commente r (20,115A2) stated that the proposed rule will close between 13 and 33 mills with little or no benefit to the environment or human health. The commenter (20,115A2) stated that EPA should determine the percentage of the total nationwide production capacity that will be lost due because of mill closings. The commenter (20,115A2) stated that if the demand for paper products approaches or exceeds the remaining production capacity of the mills then there would be a strong tendency for a run-up in prices. One commenter (20,057) indicated that the proposed regulation will close 33 mills and eliminate 21,800 jobs , based on an industry estimate. The commenter

(20,057) stated that EPA's economic analysis would have concluded the same results if EPA had properly estimated the capital requirements of the proposed rule. One commenter (20,067) argued that EPA ignored the fact that compliance with the proposed

11-5regulations depends significantly on the ability of the affected facility owner to raise the capital necessary to conduct compliance modifications

. One commenter (20,018) argued that the technological and financial impact of the proposed MACT rules was greatly underestimated by EPA and the proposed rules will have a negative impact on the ability of American pulp and paper companies to compete in the world market. One commenter (20,046) argued that an economic model that used true capital costs and inherently higher operating costs would clearly show that the proposed cluster rules are not affordable. Response: The costs , economic impacts, and health and environmental benefits of the proposed air (MACT I) and water rules were evaluated and fully discussed in the Regulatory Impact Assessment of Proposed Effluent Guidelines and NESHAP for the Pulp, Paper, and Paperboard Industry (EPA-821-R-93-020). This assessment was updated for the final rule in the EA. In addition to assessing the impact of the MACT I final rule on the pulp and paper industry , the impact of the final MACT III, proposed

MACT II , and the final water rules were evaluated individually and jointly. (Note that MACT III impacts are not reported in the EA because the MACT III rule is not expected to result in control costs or emission reductions for the pulp and paper industry.) The EA estimates the costs and economic impacts of the regulation, evaluates the health and environmental benefits of the regulation , and compares the costs of the regulation to the benefits of the regulation. The EPA agrees with the commenter that based on the EA , there is the potential for facility closures to result from the regulations. Although no mill closures are predicted to result from the final MACT I

11-6regulation , it is anticipated that as many as three mills may close due to the combined final MACT I, proposed MACT II, and final water regulations. Comments that mill closures will exceed
th e EPA's estimate are based on the pulp and paper industry's estimate of the cost of emission controls. The EPA evaluated the industry estimate of the cost of emission controls and adjusted the cost analysis where appropriate. Based on the revised cost estimates resulting from commenters' input, as well as other elements of the impact analysis, the EPA reassessed the economic impacts for the final rule in the EA. Job losses, decreases in pulp and paper shipments, and decreases in exports associated with predicted mill closures are reported in the EA. In addition, the price increases anticipated for pulp and paper products are estimated and reported in the EA. The air and water rules are not expected to significantly impact the ability of the domestic pulp and paper industry to compete in the world market. The economic analysis also considers the cost of financing emission control equipment and equipment necessary to meet the effluent guidelines. For most of the analyses conducted, a real cost of capital or financing (discount rate) of 7 percent is assumed. However, a sensitivity analysis of the cost of capital using company-specific cost of capital estimates is performed and these results are discussed in the EA. The impact of increased capital and operating costs because of environmental controls on the financial viability of mills affected by the regulations is fully evaluated and reported in the EA. With regard to the assertion that capital costs and associated operating costs are understated , EPA has revised cost estimates based on comments and data provided after proposal. Significant changes were also made

11-7to the requirements , such as requiring named systems to be controlled, which reduce the costs. The costs estimated for the promulgated rule incorporated all these changes and data. The EPA believes that the final rule costs appropriately characterize the costs for the industry.

Comment: One commenter (20,009) stated that EPA should try to distinguish between those mills that might close due to meeting new environmental control technologies and those that would close anyway due to market and/or production constraints and urged EPA not to dismiss technological options with large environmental benefits just because the costs "seem" high. One commenter (20,103) stated that EPA did not perform an adequate evaluation of the cost of compliance with this standard and the benefits to society and the environment. In particular, the commenter (20,103) asserted that the overall cost of shutdown of some facilities does not seem to have been addressed by EPA. Another commenter (20,104) contended that the proposed rules will force chlorine and caustic soda manufacturing facilities to close, including three chlorine and caustic soda manufacturing facilities in the Pacific Northwest. Response: In the EA , the number of mills that are anticipated to close assuming baseline conditions (no additional environmental controls) are distinguished from the number of mill closures expected to close as a result of the environmental regulations. Economic impacts reported in the EA relate specifically to mill closures resulting from the environmental regulations. Estimates of the number of job losses anticipated to occur and potential price increases resulting from the regulations are reported in the EA. Job losses, decreases in

11-8shipments, and decreases in exports are not expected to be significant due to the level of mill closures expected. The cost of mill closures that may result from the regulations are measured in terms of lost production and potential job losses with the financial closure model. Lost production and potential job losses are measure s of important costs of a mill shutdown. Estimates of the direct and indirect economic impacts of the regulations on the national economy are also reported. A comparison of the costs and benefits of the regulations is conducted in the EA. Many of the health and environmental benefits of the regulations are discussed qualitatively, and thus the monetized benefits are compared to annualized costs with recognition that the monetized benefits are likely understated. The air rules are anticipated to have negligible impacts on the consumption of chlorine at pulp and paper mills. However, the effluent guidelines are anticipated to cause a decline in consumption of chlorine by the pulp and paper industry. In an article published in the November 1994 issue of Chemical and Engineering News, "Chlorine Industry Running Flat Out Despite Persistent Health Fears" , the pulp and paper industry is reported to have consumed approximately nine percent of the total domestic production of chlorine in 1994. The level of chlorine consumption by the pulp and paper industry is anticipated to decline to approximately six percent of the total domestic chlorine production by the year 2000. Despite the anticipated decline in consumption of chlorine by the pulp and paper industry, the overall growth in domestic production for the industry is anticipated to occur at a rate of 0.8 to 1.5 percent per year suggesting that growth in chlorine consumption is

11-9anticipated to occur in industries other than the pulp and paper industry

. (Chemical Week. Web page. 1996. <http://www.chemweek.com/marketplace/product_focus/1996 chlorine.html>)

. Since moderate growth is anticipated in domestic chlorine production for the future, it does not seem likely that environmental regulations for the pulp and paper industry will result in chlorine manufacturing facility closures. Using the estimated annualized cost of this NESHAP, an evaluation of the economic impacts and distributional effects to the pulp and paper industry is performed. The final rule when evaluated independently of other regulatory requirements for air and water pollution , is not expected to have a substantial impact on the industry. Estimated price increases are less than 0.5 percent for bleached paper-grade kraft and sulfite, dissolving-grade kraft and sulfite, and semi-chemical pulp and paper products , while unbleached kraft pulp is estimated to have a price increase of almost 5 percent. The costs imposed on affected facilities do not result in any mill or firm closures, thus, the rule assessed individually is not expected to alter employment, shipments , or exports for the industry by appreciable

amounts. Implementation of the final rule is expected to reduce emissions of HAP, VOC, and TRS, but increase emissions of PM, q? I CO, and NO x . The benefits that accrue as a result of the standard result from changes in human health effects associated with inhalation of the above pollutants, as well as changes in welfare effects such as visibility, crop yields, materials soiling, and corrosion. The EPA is not able to place a monetary value on all of the benefits achieved by the rule. Values are

11-10obtained for changes in VOC, SO2, and PM emissions only. Total benefits for these pollutants range in value from $727 million to $1,493 million.
Comment: One commenter (20,061) contended that the compliance costs of the future MACT standards for combustion sources would make the cost to benefit ratio even less appealing to industry and society. One commenter (20,027) stated that EPA was obliged to have considered the costs and other impacts of the future combustion MACT standards when considering beyond-thefloor technologies. Response: At proposal of the MACT standard for noncombustion sources , the Agency was preparing the combustion
source MACT standard. The combustion source MACT standard was proposed concurrently with promulgation of the chemical pulping MACT standard. The economics and benefits analyses incorporated the impacts of both MACT standards, as well as the impacts of the effluent guidelines portion of the final rule.
Comment: One commenter (20,018) stated that EPA's costbenefit analysis for emission controls should consider the technological differences between kraft, sulfite, and neutral sulfite pulp mills. One commenter (20,072) stated that the gap of non-competitiveness between soda and kraft mills will be further widened if the soda mills are required to comply with the same compliance regulations as kraft mills. Response: In the final rule , EPA has subcategorized the pulp and paper industry by pulping type (kraft, soda, semichemical, and sulfite). As a result , the control requirements for soda and semi-chemical mills are significantly reduced from kraft mills. The control requirements for sulfite mills are

11-11specific to sulfite mills. Therefore, the cost of complying with the standard is different for kraft, soda, semi-chemical, and sulfite mills. These differences are incorporated in EPA's cost and economics analyses.

11-1212.0 BENEFITS

Comment: Several commenters (20,027, 20,053A1, 20,088, 20,101, 20,129) argued that the generation of collateral emissions associated with combusting vent gases are more of a concern than methanol , the predominant HAP compound. One commenter (20,027) claimed that to generate the steam required for stripping will lead to significant collateral increases of
NO,, SO21 PM, CO, and CO2. The commenter (20,027) declared that it is a bad trade for the environment to pay this price for a control effort that can largely be described as methanol removal.

One commenter (20,053Al) stated that the proposed requirements for the collection and control of high volume systems with low concentrations of HAP emissions suggest EPA has not fully considered the potential environmental trade-off between the minimal HAP reductions and the increased emissions of other pollutants. One commenter (20,101) said a drawback of the proposed rules is the increase in CO, nitrogen oxide, sulfur dioxide, and PM due to combustion controls. Another commenter

(20,129) stated that the emissions from combustion sources may increase due to the need for increased boiler capacity for extended cooking times, Cl02 generation, etc. However, the commenter (20,129) stated a demonstrative environmental gain will

12-lresult in the reduction of chlorinated compound emissions from the bleach plant. Response: MACT standards are required to be based on control of HAP emissions. Although methanol is the largest emitted HAP , there are a number of other HAP's emitted from pulp and paper mills that are substantially reduced due to the control requirements in the final rule, such as chloroform, o-cresol,

etc. The final rule achieves a significant reduction in the emissions of total HAP, VOC, and TRS compounds. The Agency recognizes that some criteria pollutants (such as SO2, PM, and
NO x ) will be increased due to the control requirements (from combustion of vent gases and fuel for energy), and the Agency has accounted for these increases in the impacts analysis. However, these increases are much smaller in absolute value than the decreases in HAP , VOC, and TRS emissions. A detailed discussion of the benefits of the rule are presented in the preamble to the promulgated rule and in the Economic Analysis report (A-92-40, V-A-2). Additionally, the Agency believes that in some cases, the impacts have over-estimated the emissions because some mills may be able to use existing controls to reduce emissions. However, EPA does not have sufficient information on the number and effectiveness of these controls , so no reductions were estimated.
Also , mills may use fuels that emit lower amounts of criteria pollutants when combusted , or may use other control options, such as the clean condensate alternative or lower emitting equipment, that may not increase secondary emissions.

12-2Comment: Two commenters (20,025 , 20,114) stated that EPA used incorrect assumptions about ozone formation contending that the relationship between VOC reductions and ozone reductions is not linear. On e commenter (20,025) continues by stating that given the relationship between VOCs and ozone in rural areas, and other uncertainties [relating to background ozone concentrations] there is no basis for monetizing the agricultural benefits relative to VOC reduction. Response: The photochemical production of ozone is the result of atmospheric physical processes and complex chemical processes involving two classes of precursor pollutants: VOCs

an d N O x . The analysis for the proposal of the pulp and paper rule used the most readily available data at the time to quantify and monetize VOC emission reductions. Since that time, a mor e recent analysis (the Regulatory Impact Analyses for the Particulate Matter and Ozone National Ambient Air Quality Standard s [NAAQS] and Proposed Regional Haze Rule) provides data that can be used to monetize VOC emission reductions. The ozone NAAQS analysis acknowledges the complex relationship between emission reductions and ambient ozone concentrations by using a variety of prognostic and empirical models to examine this issue. The complex relationship is also incorporated into the benefits analysis for this pulp and paper rule since the VOC benefit value is derived from the ozone NAAQS data. One of the methods used to value VOC emission reductions estimated for the pulp and paper rule limits the valuation (both health and welfare categories) of the emission reductions only to areas with ambient ozone concentrations high enough to potentially violate either the current ozone standard or the

12-3revised ozone standard. These areas (rural or urban) are not only above the background concentration level, but also above the current ozone standard or the newly promulgated ozone NAAQS. The Ozone Staff Paper estimates the national average background ozone concentration to be approximately 0.04 parts per million, which is incorporated into the benefit analysis of reduced ozone concentrations. Given this estimated background ozone concentration, the method of valuing VOC emission reductions as described above addresses the background ozone concern in both urban and rural areas.
Comment: Several commenters (20,025, 20,027, 20,101, 20,114 , 20,116) stated that the benefits assessment of the proposed rules contains calculation errors. Two commenters

(20,025, 20,027) stated that their review of the Regulatory Impact Assessment (RIA) indicates that EPA's analysis does not employ sound science , is skewed by a large arithmetic error, uses unrepresentative data , and is based on unwarranted assumptions.

On e commenter (20,025) stated that incorrect assumptions about ozone formation led to unjustified agricultural benefits. Three commenters (20,025, 20,101 , 20,114) stated that EPA made a mathematical error in the use of the Office of Technology Assessment's economic benefits analysis which resulted in a per-metric ton benefit for VOC control that is $468 million too high. Response: The benefits assessment in the RIA at proposal contained a printing error. In addition , the benefits assessment has been updated to reflect more recent valuation estimates for VOC, PM, and SO2 emission reductions. Revisions to the analysis also include an added explanation of the underlying assumptions

12-4and a revision of the benefit calculations due to a reevaluation of the emission reductions and the related monetized health and welfare benefits valuation.

Comment: One commenter (20,083) argued that EPA should not refer to methylene chloride as a VOC in the final rule and preamble since methylene chloride is specifically excluded from

EPA's definition of VOC. Therefore, the commenter (20,083) stated that corrections should be made to the benefits or tropospheric ozone reductions calculations due to the control of methylene chloride. One commenter (20,083) argued that it is inappropriate for EPA to use VOC reductions as a "benefit" for supporting the stringent HAP emission standards. Response : Methylene chloride is not referred to as a VOC in the final rule and is not included as a VOC in the benefits analysis. However, methylene chloride is classified as a HAP and benefits were attributed to reductions in human health effects from reductions in emissions.
Comment: Two commenters (20,025 , 20,116) stated that EPA used an obsolete potency factor for the inhalation route of exposure in the chloroform risk assessment. One commenter

(20,025) stated that EPA should update the potency factor. Two commenters (20,025 , 20,114) stated that the cancer risk reductions for formaldehyde and chloroform were overstated due to the use of incorrect potency and scaling factors. Response: The Agency is aware that several organizations have reassessed the carcinogenic potency of formaldehyde and chloroform. The reassessments have incorporated more biologically based dose-response information. The cancer potency factors used in the risk assessment at proposal were taken from

12-5the Integrated Risk Information System (IRIS). A recent search of IRIS shows the same cancer potencies as were used in this risk

assessment. This program office has tended to base risk assessments on the values contained in IRIS. The Agency did not reassess the risk from the pollutants for the final rule, did not place a monetary value on them , and did not base the decisions in the final regulatory alternative on this information.

Comment: Several commenters (20,016, 20,005, 20,027, 20,101, 20,117) said the costs outweigh the economic benefits. One commenter (20,117) suggested that EPA seriously consider the economic impacts of the proposal and compare those impacts to the environmental benefits. The commenter (20,117) contended that the environmental benefits achieved by the regulation will be small while the economic impact will be severe. Two commenters (20,011, 20,088) stated that the costs are likely understated while the benefits are probably overstated due to the improper characterization of secondary pollutant impacts. One commenter

(20,016) stated that the pulp and paper industry does not oppose environmental capital investments but asks that any environmental requirements be based on demonstrated benefits commensurate with the costs of the requirements. One commenter (20,101) contended that EPA should reconsider whether the benefits resulting from reduced air emissions outweigh the costs of achieving those benefits. One commenter

(20,027) submitted that the realistic costs of the proposed "cluster" standards exceed the realistic benefits by a factor of thirty. (Case law cited: Portland Cement Assoc., National Lime Assoc., Sierra Club.) The commenter (20,027) indicated that the enormous costs are unwarranted considering the minimal benefits

12-6achieved with the standard. The commenter (20,027) warned that EPA grossly overestimated the environmental benefits of the proposed MACT standards. One commenter (20,025) added that EPA had not cited any reliable studies to support health benefits of reducing TRS emissions. Another commenter (20,066A4) argued that the proposed rules were only marginally cost-effective as underscored by EPA's benefit-cost comparison. The commenter

(20,066A4) added that in every case of these studies, the annualized compliance cost for the mills exceeds the annualized benefit of the rule by many millions of dollars. Response: The EPA is limited in its ability to place a monetary value on all of the benefit categories. Because several health and welfare endpoints , as well as entire pollutant categories are not monetized, the estimate of benefits is underestimated. For instance , one category that achieves significant reductions is TRS , which is responsible for the malodorous smell associated with pulp and paper mills and can result in toxic effects, as well, irrespective of odor. The value of these reductions could be significant given the odor's negative affect on individuals comfort and well-being, and the toxic effects that adversely impact human health (e.g., headaches , nasal irritation , and respiratory and cardiovascular impacts). Overall, all of the information outside of the monetized costs and benefits presentation must be considered before a determination that costs outweigh benefits can be made. Given the uncertainties described in the analyses, EPA cannot make a statement in either direction

. The analysis of the final rule presents a range of benefits. The lower bound estimate results in a net cost (i.e. , costs exceed benefits) while the

12-7upper bound estimate produces net benefits (i.e., benefits exceed costs).
Comment: One commenter (20,114) contended that EPA should perform a cost-to-benefit evaluation to justify the RIA. One commenter (20,129) indicated that EPA should perform risk assessments when developing control applicability cut-off values. Response: The EPA did present a cost-to-benefit comparison and presented the results in a RIA for the proposed rule. For the final rule , the EPA presented results in the EA report

(A-92-40, V-A-2). The analysis of HAP benefits relies on risk assessments, however , this is completed independent of the development of cut-off values.
Comment: One commenter (20,011) indicated that EPA did not provide sufficient information to allow the industry to check the accuracy of the cost-benefit analysis calculations. Response: The benefits analysis , in the proposed rules RIA and in the promulgated rules EA report (A-92-40, V-A-2), outlines the assumptions that were used. All sources of information used are available in the public docket.

Comment: Two commenters (20,005 , 20,059) contended that EPA will have to establish a second round of standards in 8 years to address the residual cancer risk associated with the pulp and paper industry because the current proposed MACT standards were not sufficiently aggressive. One commenter (20,059) stated that EPA should establish final MACT standards that would reduce emissions of carcinogenic and acutely toxic compounds to levels that will protect public health with an adequate margin of safety. One commenter (20,005) stated that EPA should establish

12-8air toxic regulations based on risk so that emissions are reduced by the most cost-effective methods available. Response: The Act requires that MACT standards require

". . . the maximum degree of reduction in emissions of the hazardous air pollutants that the Administrator . . . determines is achievable . .

. through application of measures, processes, methods, systems, or techniques . . . .'I In other words, the MACT standards are technology-based standards, rather than riskor health-based standards ; MACT standards control total HAP emissions, rather than each individual HAP. Therefore, EPA cannot consider the toxicity of different compounds when developing the standards. The EPA maintains that the final rule requires stringent control of all HAP's. Additional control of a few HAP's through other technologies is not warranted considering the cost and other impacts of those technologies. As the commenter noted , the residual cancer risk after the standard has been promulgated will be analyzed 8 years after promulgation. At such time , EPA will review the toxicity of specific compounds.

Comment: One commenter (20,072A8) stressed that requiring the soda mills to collect, transport , and incinerate vent gases that are not an odor problem discourages the use of the soda process without consideration of the welfare benefits (odor reduction) associated with soda mill operation. Response: The EPA agrees with the commenter that soda mills do not have TRS emissions or the odor problems associated with

TRS. However, test information and information submitted by the industry indicates that soda mills have HAP emissions comparable to kraft mills. The EPA has determined that significant HAP

12-9reductions can be achieved for minimal cost of controlling selected equipment at soda mills. Therefore, EPA maintains that substantial benefit is obtained from controlling emission vents at soda mills.

Comment: One commenter (20,059) argued that EPA did not provide sufficient information to indicate the extent of emissions that will go uncontrolled as a result of the exemptions. Response: The EPA disagrees with the commenter. In memoranda placed in the docket at proposal and promulgation, in the background information document (volume 1), and in chapter 20 of this document , EPA has provided the baseline emissions and emissions reductions for each control option. The emissions that will go uncontrolled can be calculated from this information.

Comment: Commenter (IV-D2-15) opposed language in the March 8, 1996 , Federal Register notice that stated that all the HAP's to be regulated at pulp and paper mills "can cause toxic health effects following exposure, including nausea, headaches, respiratory distress , and possible reproductive problems" because it does not reference amount of dosage or exposure levels. The commenter contended that EPA had not shown that the effects described are associated with exposure levels resulting from pulp and paper HAP emissions. Response: The Federal Register statement was a qualitative description of possible effects of the HAP's emitted by pulp and paper mills. The EPA did not state that these effects were quantified. The benefit analysis contained in the RIA at proposal evaluates and quantifies changes in cancer incidences

12-10resulting from the proposed rule , but qualitatively discusses all other health effect end-points.
Commenter: One commenter (20,025) contended that the EPA had no basis for assigning benefits to acrolein emission reductions because there are no emissions at baseline. The commenter (20,025) also stated that the TRS emissions calculated by EPA were erroneously high , which led to a gross exaggeration of potential human benefits. Response: The EPA disagrees with the commenter. Based on information contained in emission test reports for pulp and paper mills, emission factors were developed for acrolein. The commenter is referred to the chemical pulping emission factor document (A-92-40 , IV-A-81 for emissions information on acrolein obtained by the EPA. Baseline emissions of acrolein were calculated to be 257 mg/yr. Regarding TRS emissions, the EPA revised its estimates of emissions based on additional information and test reports obtained since proposal. See chapter 20 for TRS emission estimates and the chemical pulping emission factor document (A-92-40 , IV-A-8) for development of TRS emission factors.

12-1113.0 EMISSIONS AVERAGING

Comment: The December 17, 1993 proposal requested comment on whether to include emissions averaging in the final rule. Three commenters (20,011, 20,027, 20,056) supported including emissions averaging to provide flexibility to the industry. Other commenters (20,059, 20,102, 20,103, 20,129) opposed averaging because they asserted that averaging would increase emissions and not be enforceable. One commenter (20,027) noted that in keeping with EPA's approach of not distinguishing among the regulated pollutants (HAP's) from this source category, EPA should establish an emissions trading system. The commenter (20,027) also favored EPA making a generic finding that emissions averaging in the pulp and paper industry does not increase hazards. Other commenters (20,011, 20,146) supported an emissions trading system and claimed that an emissions trading policy is consistent with the Act, EPA policy, the current administration's views, and general congressional intent. Several commenters (20,059, 20,102, 20,103, 20,129) strongly objected to emissions averaging and supported point-by-point compliance requirements. Two commenters (20,102, 20,103) expressed concern that averaging between types of emissions could minimize the public health benefits of the regulation,

13-1particularly substitution of ultra-hazardous pollutants for less toxic ones. One commenter (20,059) indicated that the omission of detailed discussion of interpollutant trading in section 112(g) of the Act reflects an intention of Congress not to authorize this practice for MACT standards. One commenter

(20,103) contended that emissions averaging would be too difficult to enforce. One commenter (20,129) considered HAP emissions to be highly variable and a function of chemical pulping process conditions and air pollution control technology. The commenter (20,129) warned that averaging HAP emissions that are highly variable and not well known is problematic.

One commenter (IV-D2-4), while maintaining opposition to the use of emissions averaging , conceded that in this instance, limited emissions averaging may be useful to minimize the overall cost of compliance while still achieving the desired emissions reduction. The commenter (IV-D2-4) supported requiring a "static" vs. a "dynamic" emissions averaging scheme, restricting emissions averaging to streams of similar pollutants, and allowing permitting agencies to restrict the use of emissions averaging. Response: Based on comments received following proposal, EPA concluded that incorporating emissions averaging in the rule would add flexibility and could reduce the costs of compliance. However, EPA has decided that a traditional emissions averaging approach (as taken in the HON) is not appropriate for this industry. The EPA and industry held several meetings after proposal to discuss mill-wide emissions limits and emissions averaging concepts, based on the use of emission factors

(A-92-40, IV-Dl-49, 51, and 61). The EPA concluded that

13-2currently available emission factors were sufficient for estimating national emissions reductions and impacts; however, they were inadequate for demonstrating compliance in a traditional emissions averaging program. The variability between mill operations would require a case-by-case evaluation of the feasibility of emissions averaging. Since a significant amount of emissions source testing would be necessary to support a viable emissions averaging program , demonstrating compliance would be too burdensome on industry and very difficult to enforce. Some commenters suggested an alternative to traditional emissions averaging that would be more appropriate for the pulp and paper industry. This condensate pretreatment alternative is currently referred to in the final rule as the CCA. A brief discussion of this alternative was presented in the March 8, 1996 Federal Register supplemental notice. A description of the industry's assumptions used to assess the condensate pretreatment alternative was also submitted to the Agency (A-92-40, IV-Dl-59). The CCA is based on information provided by the industry after the December 17, 1993 proposal (A-92-40, IV-Dl-29, 29a, 33, and 38). The CCA focuses on reducing the HAP concentration in process water (such as from the digestion and liquor evaporation areas) that is introduced into process equipment throughout the mill. By reducing the amount of HAP in the process water, reductions in HAP emissions will also be achieved since less HAP will be available to volatilize off the process to the atmosphere. To demonstrate compliance, the mass emission reduction of HAP's achieved by the alternative technology must equal or exceed that which would have been achieved by

13-3implementing the kraft pulping vent controls. Eligibility for

this compliance alternative is determined on a case-by-case basis during the permitting process. For purposes of developing a compliance strategy, sources may use either emission test data or engineering assessment to determine the baseline HAP emission reductions that would be achieved by complying with the kraft pulping vent standard. To demonstrate that the alternative technology complies with the emission reduction requirements of the standards, emission test
data must be used. Two conditions must be met for a CCA compliance demonstration: (1) owners and operators that choose this alternative must first comply with pulping process condensate standards before implementing the alternative technology, and (2) the HAP emission reductions cannot include reductions associated with any control equipment required by local, State, or Federal agencies or statutes or with emission reductions attributed to equipment installed prior to December 17, 1993 (i.e., the date of publication of the proposed rule). For purposes of the CCA, the rule provides an alternative definition of the affected source. The alternative definition allows for CCA to apply to process systems outside of the kraft pulping system. The expanded source includes the causticizing system and the paper making system. The mill must specify the process equipment within the expanded source with which to generate the required HAP emissions reductions using the CCA. The mass emission reduction of HAP's must equal or exceed the reduction that would have been achieved through application of the kraft pulping vent standards. The final determination of

13-4equivalency shall be made by the permitting authority based on an evaluation of the HAP emission reductions.

Comment: Several commenters (IV-D2-2, IV-D2-7, IV-D2-15, IV-D2-19) to the March 8 , 1996 Federal Register supplemental notice supported the concept of the CCA compliance approach as outlined by the industry. The commenters also suggested that the final MACT rule allow individual mills to make a case-by-case demonstration that installing and operating a condensate treatment system and reusing the cleaned condensates in various process areas will achieve equivalent or greater mill-wide total HAP emissions reductions as compared to the MACT requirements. One commenter (IV-D2-15) recommended that in order to make a case-by-case determination of equivalent emissions reduction, a mill would: (1) determine total HAP emissions reductions for any pulping component systems that would be subject to a 98 percent total HAP reduction requirement under the final rule;

(2) determine the emissions reductions from implementing the CCA for all process units where the recycled cleaned condensates would be used (or would affect the emissions of total HAP), by using estimates of relevant process liquid concentrations; (3) verify the step 2 reductions are equal to or exceed those from step 1 ; and (4) periodically monitor the methanol concentration or other appropriate parameters on a case-by-case basis to ensure reductions continue. One commenter (IV-D2-15) stated that NCASI documented the relationship between process stream methanol concentration and air emissions for vacuum drum brownstock washer systems, oxygen systems, smelt dissolving tanks , and paper making systems. The commenter (IV-D2-15) also contended that a relationship has been

13-5developed for estimating total bleaching system methanol emissions based on the amount of methanol entering the bleaching system and the total vent gas flow rate. These relationships could be used by mills to demonstrate the emissions reductions achieved by the reduction of HAP concentration in reused condensate streams , in lieu of testing. Response: The EPA included provisions for the CCA in the final rule. To be considered equivalent to point-by-point control, the CCA must achieve at least the same total HAP reductions as would be achieved if the MACT controls were implemented on a point-by-point basis. The responsible permitting authority will determine the adequacy of the plan. The EPA rejected the use of the HAP emissions/process water concentration relationship data developed by NCASI (A-92-40, IV-Dl-29, 33, and 38) as a means of demonstrating compliance with the CCA. While a relationship may exist between the HAP emissions from a piece of process equipment and the HAP concentration in the process water reused or recycled to the equipment, the information compiled thus far by NCASI is insufficient for demonstrating compliance due to inherent process variability between mills. These emission factors may be helpful for screening or preliminary evaluations of the viability of the

CCA. To demonstrate compliance with the CCA, however, the rule requires that a mill (1) perform emissions testing to establish the baseline , uncontrolled emissions level for the pulping system after the pulping process condensate requirements of § 63.446 are

met; (2) apply the 98 percent HAP emissions reduction required by
§ 63.443(c) to obtain a compliance HAP emissions level; and (3) after the alternative technology has been implemented, retest

13-6the pulping system to determine the HAP emissions level. To

demonstrate compliance with the Act, the HAP emissions levels measured after the CCA technologies have been implemented must be equal to, or lower than, the compliance level of HAP emissions calculated from the baseline testing.

13-714.0 DEFINITIONS

14-1Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Acid plant None The process equipment Definition not needed. No definition for acid used at sulfite mills to plant was incorporated produce cooking acid from into the proposal. sulfurous acid, sulfur While the industry's dioxide, bisulfite salts, definition appears to and acids and various be technically correct, base cations. the term acid plant is not used in the rule. (A-92-40, IV-Dl-104) Therefore, this definition was not needed. Affected None For the purpose of this Definition not needed. The affected source is source subpart, a facility which presented in the is a major source that applicability section produces pulp from wood of the rule. or other fiber sources, a facility which is a major source that manufactures paper and paperboard, or a facility which is a major source that has integrated production of pulp and manufacture of paper and paperboard.
(A-92-40, IV-Dl-104)Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Air-dried A pulp sample with a A pulp sample at 10 Definition not needed. The units used in the pulp moisture content of percent by weight rule are based o n ovenless than or equal to moisture content. Pulp dried pulp. 10 percent by weight. samples for applicability Pulp samples for the or compliance pulping component shall determinations for both be unbleached pulp and the pulping and bleaching for the bleached component shall be component shall be unbleached pulp. bleached pulp. (A-92-40, IV-Dl-104) [from December 17, 1993 proposal] Black liquor Pulping liquor from the Pulping liquor from the Spent cooking liquor that Th e commenter's digester to the point pulping process to the has been separated form definition changes the of its incineration in point of its incineration the pulp produced by the word "digester" to the recovery furnace of in the recovery furnace kraft, soda, or semi- "pulping process". a sulfate (kraft) (k of a sulfat e (kraft) chemical pulping process. However, the rule recovery process. It recovery process. It definition has been contains dissolved contains dissolved simplified to improve organic wood substances organic wood substances clarity. and residual active and residual active alkali compounds from alkali compounds from pulping process. pulping process.

[from December 17, 1993 [commenter 20,056] proposal, preamble] Bleaching Brightening and Brightening of pulp by The industry definition Industry definition delignification of pulp the addition of oxidizing was used in the rule. addresses the use of by the addition of chemicals or reducing reducing chemicals. oxidizing chemicals. chemicals. Therefore, the industry's definition [from December 17, 1993 (A-92-40, IV-Dl-104) was used in the rule. proposal1Term Bleaching component Proposal/ supplemental notice definition All process equipment beginning with the first application of chlorine o r chlorinecontaining compound up to and including the final bleaching stage. Treatment with ozone, oxygen, peroxide may occur before or after the addition of chlorine. If treatment occurs before this chlorine addition, then these stages are included in the pulping component; if treatment occurs after the addition of chlorine, then these bleaching stages are included in the bleaching component. [from December 17, 1993 proposal) Industry recommendation All process equipment after high density pulp storage prior to the first application of oxidizing, purification, or reducing chemicals following the pulping component up to and including the final bleaching stage.
(A-92-40, IV-Dl-104) Definition not needed; included in the definition of "bleaching Rationale for final definition Industry definition addresses the use of oxidizing or reducing chemicals and provides an equipment reference for the start of the bleaching component. This is necessary to accommodate the TCF process. The rule definition is a combination of the proposal and industry definitions.Term Bleaching stage

Bleaching system

Boiler Proposal/ supplemental notice Rationale for final definition Industry recommendation Final definition definition None All process equipment All process equipment The proposal did not associated with a associated with a contain a definition of discrete step in the discrete step of chemical a bleaching stage. The bleaching process, application and removal industry definition including chemical and in the bleaching process appears to be accurate steam mixers, bleaching including chemical and and the EPA agrees with towers , washers , and seal steam mixers, bleaching the commenter. For the (filtrate) tanks. towers , washers, seal rule, the industry (filtrate) tanks, and definition was slightly (A-92-40, IV-Dl-104) vacuum pumps, and any modified to address other equipment serving "chemical application the same functions as and removal" and to those previously listed. includ e "but not limite d to" language. None None All process equipment "Bleaching system" after high-density pulp better describes the storage prior to the definition than first application of "bleaching component." oxidizing chemicals or reducing chemicals following the pulping system , up to and including the final bleaching stage. Any enclosed combustion Any enclosed combustion Any enclosed combustion The EPA does not device that extracts device whose primary device that extracts believe that the useful energy in the purpose is the extraction useful energy in the form industry's definition form o f steam. Boilers of useful energy in the of steam. A boiler is adds any clarity to the are not considered form o f steam

. Boilers not considered a thermal rule. Therefore, the incinerators. are not considered oxidizer. proposal definition was incinerators. used in the rule. [from December 17, 1993 (A-92-40, IV-Dl-104) However, the term proposal1 "incinerator" was replaced by "thermal oxidizer" to add clarity.Term Proposal/ supplemental notice definition Industry recommendation Final definition Brownstock washer system Includes rotary vacuum drum washers, pressure washers, diffusion washers, horizontal belt washers, all filtrate tanks, and intermediate stock chests. The washing system does not include deckers, screens, stock chests or pulp storage tanks following the last stage of brownstock washing. 

## I [from March 8, 1996

Federal Register supplemental notice1 The equipment used to wash pulp and separate spent cooking chemicals following the digester system and prior to the bleaching component, oxygen delignification system or paper machine

syste m (at unbleached mills), such as vacuum drum washers, diffusion washers, rotary pressure washers, horizontal belt filters, intermediate stock chests, and their associated vacuum pumps, filtrate tanks and foam breakers or tanks. The washing system does not include deckers, screens, stock chests, or pulp storage tanks, following the last stage of brownstock washing.
(A-92-40, IV-Dl-104) All equipment used to wash pulp and separate spent cooking chemicals following the digester system and prior to the bleaching system, oxygen delignification system, or paper machine system (at unbleached mills). The pulp washing system equipment includes vacuum drum washers, diffusion washers, rotary pressure washers, horizontal belt filters, intermediate stock chests, and their associated vacuum pumps, filtrate tanks and foam breakers or tanks, and any other equipment serving the same function as those previously listed. The pulp washing system does not include deckers, screens, knotters, stock chests, or pulp storage tanks, following the last stage of pulp washing. Rationale for final definition The industry definition appears to be technically correct. The definition (pulp washing system) used in the rule was modified to address all pulp washing systems (i.e., separate definitions for brown and red stock would not be needed) by removing the term l'brownlt and replacing with word "stock" with the wor d "pulp"Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Causticizing None All lime mud washers and All equipment associated No definition was system storage tanks, white and with converting sodium included at proposal. mud liquor clarifiers and carbonate into active The industry definition storage tanks, slakers, sodium hydroxide. The appears to be slaker grit washers, lime equipment includes smelt technically correct. kilns, green liquor dissolving tanks, lime For the rule, the clarifiers and storage mud washers and storage industry definition was tanks, and dreg washers tanks, white and mud slightly modified to ending with the white liquor clarifiers and present function first, liquor storage tanks storage tanks, slakers, followed by typical prior to the digester slaker grit washers, lim e equipment. system. kilns, green liquor clarifiers and storage (A-92-40, IV-Dl-104) tanks, and dreg washers ending with the white liquor storage tanks prior to the digester system, and any other equipment serving the sam e function as those previously listed. Chemical The process by which The process by which Definition not needed. The term "chemical recovery pulping chemicals in pulping chemicals in the recovery" is not used the spent cooking spent cooking liquor are in the rule. liquor are extracted or extracted or recovered recovered after the after the multiple effect multiple effect evaporator system, evaporator system. consisting of a recovery furnace , black liquor [from December 17, 1993 oxidation (if any), black proposal] liquor storage tanks, and ending with th e smelt dissolving tank, and associated equipment.
(A-92-40, IV-Dl-104)Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Chip steamer None A separate vessel for the A vessel used for the No definition was purpose of preheating purpose of preheating or included at proposal. wood chips prior to the pretreating wood chips The industry definition digester , using flash prior to the digester, appears to be steam from the digester using flash steam from technically correct, or live steam. the digester or live however the rule steam. definition was slightly (A-92-40, IV-Dl-104) modified to remove the term "separate" to acknowledge that chip steamer vessels may be integrated into the digester system. Closed-vent A system that is not A system that does not The proposal definition The industry definition system open to the atmosphere discharge to the was used in the rule. includes language and is composed of atmosphere during normal referring to normal piping, ductwork, operation and is composed operation to address connections, and, if of piping, ductwork, concerns regarding necessary , flow- connections, and if malfunctions and inducing devices that necessary, flow inducing safety-related venting. transport gas or vapor devices that transport This language does not from an emission point gas or vapor from an add any clarity to the to a control device. emission point to a definition and is control device. unnecessary. Also, EPA [from December 17, 1993 does not intend for the proposal] (A-92-40, IV-Dl-104) definition to depend on operating mode. Therefore, the proposal definition was used in the rule.Term Combustion device Proposal/ supplemental notice definition An individual unit of equipment, including but not limited to, an incinerator , lim e kiln, recovery furnace, process heater, or boiler, used for the thermal oxidation of organic hazardous air pollutant vapors. [from December 17, 1993 Industry recommendation Final definition An individual unit of An individual unit of equipment, including but equipment, including but not limited to, a thermal not limited to, a thermal oxidizer, lime kiln, oxidizer , lim e kiln, recovery furnace, process recovery furnace, process heater, or boiler, used heater , or boiler, used for the thermal oxidation for the thermal oxidation of organic hazardous air of organic hazardous air pollutant vapors. pollutant vapors. (A-92-40, IV-Dl-104) Rationale for final definition The industry definition includes the terms "incinerator" and "thermal oxidizer." The EPA believes that an incinerator is addressed by th e "term" thermal oxidizer. Therefore, only theTerm Condensate Segregation Proposal/ supplemental notice definition The practice of generating, producing, or isolating a high-HAP concentration/low flow rate condensate stream Erom process vent vapors or gases in order to maximize the HAP mass and minimize the condensate volume sent to subsequent treatment [from March 8, 1996 Federal Register supplemental notice] Industry recommendation The practice of generating, producing, or isolating a high-HAP concentration/low flow rate condensate stream from process vent vapors or gases in order to maximize the HAP mass and minimize the condensate volume sent to subsequent treatment.

For the cases where condensate segregation is practiced, the segregation process must be operated such that either: (a) The combined high methanol fraction streams from one or more sources contain 50 percent of the total methanol in the foul condensate streams from the same sources; or
(b) All foul condensate streams when combined contain a minimum of 10 lb methanol/ADTP for bleached mills or 6.4 lb nethanol/ADTP for unbleached mills.
(A-92-40, IV-Dl-107) Final definition Definition not needed. Rationale for final definition The concept of condensate segregation is incorporated into the language of the rule.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Container Container means any Delete entire definition. Definition not needed. Based on industry portable unit in which comments, containers wastewater or HAP (A-92-40, IV-Dl-104) are not used in the removed from wastewater pulp and paper is stored , transported, industry. Therefore, treated , or otherwise the rule does not have handled. Examples of container requirements. containers are drums, barrels, tank trucks, barges, dumpsters, tank cars, dump trucks, and ships. [from December 17, 1993 proposal] Decker system A piece of equipment The equipment, including Equipment used to thicken The industry definition used to thicken or filtrate tanks, primarily the pulp slurry or reduce includes references to reduce the water used to thicken the pulp its liquid content after process equipment content of the pulp slurry or reduce its the pulp washing system location and appears to slurry after the pulp liquid content after the and prior to high-density be technically correct. washing system. brownstock washer system pulp storage. The decker However, the terms and prior to high density system includes decker "primarily" and [from December 17, 1993 storage. vents, filtrate tanks, "brown " were deleted proposal] and associated vacuum and a list of typical (A-92-40, IV-Dl-104) pumps, and any other equipment was were equipment serving the added to the rule same function as those definition to broaden previously listed. the definition. The wording was modified to present function first, followed by typical equipment.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Digester Each continuous Each continuous digester Each continuous digester The industry's system digester or each set of or each batch digester or each batch digester recommended definition batch digesters used used for the chemical used for the chemical includes pulping of for the chemical treatment of wood o r non- treatment of wood or non- non-wood fibers and treatment of wood, wood fibers, including wood fibers. The includes specific including associated associated flash tank(s), digester system equipment equipment. The EPA flash tank(s), blow blow tank(s), chip includes associated flash agrees with the tank(s), chip steamer(s), blow heat tank(s) , blow tank(s), commenter's revisions. steamer(s), accumulator(s), chip steamer(s) not using However, the words condenser(s), and pre- condenser(s), and pre- fresh steam, blow heat "brownstock washer" hydrolysis unit(s). hydrolysis unit(s) accumulator(s), relief were replaced with preceding brownstock gas condenser(s), pre- "pulp washing system" [from December 17, 1993 washers. hydrolysis unit(s) and "but is not limited proposal] preceding the pulp to" was included. (A-92-40, IV-Dl-104) washing system, and any Additionally, the other equipment serving language was modified the same function as to present function those previously listed. first, followed by The digester system typical equipment. includes any of the liquid streams or condensates associated with batch or continuous digester relief, blow, or flash steam processes.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Existing None For the purposes of this The most current general The industry definition
source subpart , a source covered provisions definition was is slightly different by this subpart that is used in the rule. from that in the not a new source. general provisions, however, the rule is (A-92-40, IV-Dl-104) not the appropriate mechanism for changing the general provisions definitions. Any revisions to the general provisions should be accomplished in the ongoing litigation. The most current general provisions definition is used. Flow A device which Any device that indicates The industry definition The industry definition indicator indicates whether gas gas or liquid flow in an was used in the rule. includes liquid flow. flow is present in a enclosed system. The EPA agrees with the closed vent system. commenter's revision. [Commente r 20,027] [from December 17, 1993 proposal]Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Green liquor Liquor made by The solution made by Definition not needed in The industry definition dissolving the sodium dissolving smelt the rule. is more technically containing smelt from (primarily sodium sulfide correct (i.e., solution the kraft recovery and sodium carbonate) versus liquor). process in water, prior from the kraft recovery However, the definition to causticizing. process in water, prior was not needed in rule. to causticizing. [from December 17, 1993 proposal, preamble] [Commente r 20,027] Hardwood Pulpwood from broad- Any species of broad- Definition not needed. The term "hardwood" is leaved dicotyledonous leaved angiosperms not used in the rule. deciduous trees. possessing true vessels. [from December 17, 1993 (A-92-40, IV-Dl-104) proposal, preamble] High volume, None None The gas collection and This term was included low transport system used to in the rule to concentration convey gases from the distinguish between the
or

HVLC HVLC system to a control HVLC collection system collection device. and the HVLC system system vents.Term

Incinerator Proposal/

supplemental notice definition An enclosed combustion device that is used for destroying organic compounds. Auxiliary fuel may be used to heat waste gas to combustion temperatures. Any energy recovery section present is not physically formed into one manufactured or assembled unit with the combustion section; rather, the energy recovery section is a separate section following the combustion section and the two are joined by ducts or connections carrying flue gas.
[from December 17, 1993 proposal] Industry recommendation Industry recommended replacing this definition with the definition for thermal oxidizer.
(A-92-40, IV-Dl-104) Final definition The definition for thermal oxidizer was used in the rule. Rationale for final definition The definition for thermal oxidizer replaces the incinerator definition because it was a broader definition.Term Proposal/ supplemental notice definition 

# I Industry recommendation Final definition Individual The system used to drain system convey process wastewater streams from pulping or bleaching process equipment or tanks or process wastewater collection and treatment system unit to a receiving process wastewater collection and treatment system unit. The term includes all process drains and junction boxes, together with their associated sewer lines and other junction boxes , manholes, sumps, and lift stations, down to the receiving process wastewater treatment system. The individual drain system shall be designed to segregate the vapors within the system from the other drain systems. A segregated storm water sewer system, which is a drain and collection system designed and operated for the sole purpose of collecting rainfall-runoff at a facility, and which is segregated from all other individual drain The system used to convey process wastewater streams from the pulping component to a receiving process wastewater collection and treatment system unit. The term includes all process drains and junction boxes, together with their associated sewer lines and other junction boxes , manholes, sumps, and lift stations, to the receiving process wastewater treatment system. (A-92-40, IV-Dl-104) Definition not needed. Rationale for final definition This definition was not included in the final rule because the original definition was too burdensome and did not adequately reflect the streams included in this rule. Systems used to convey wastewater streams from pulping and bleaching systems are referred to as hardpiping.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Junction box A manhole access point Any structure designed Definition not needed in Although EPA agrees to a wastewater sewer for the conjunction of rule. that the industry system line or a lift two or more sewer lines. revision addresses the station. A junction box may allow fact that not all access to the sewer junction boxes will [from December 17, 1993 lines. have manholes or allow proposal] access, this definition [Commente r 20,027] was deleted from the rule since the control options for wastewater have been simplified. Knotter A piece of equipment All equipment where Equipment where knots, The industry definition system where knots or pieces knots , oversized oversized material, or adds the term of uncooked wood are material, or pieces of pieces of uncooked wood "oversized material". removed from the pulp uncooked wood are removed are removed from the pulp The EPA agrees with the slurry after the from the pulp slurry slurry after the digester commenter's revision. digester system and after the digester system system and prior to the For the rule, the prior to the pulp and prior to the pulp washing system. The proposal definition has washing system. brownstock washer system. knotter system equipment added more specific Equipment used to Pieces of equipment used includes the knotter, equipment associated remove oversized to remove oversized knot drainer tanks and with knotter systems to particles from pulp particles from pulp ancillary tanks, and any provide greater clarity following the pulp following the brownstock other equipment serving and brownstock has been washer are considered washer are considered the same function as replaced with pulp to screens. screens. those previously listed. broaden the definition. Additionally, the [from December 17, 1993 (A-92-40, IV-Dl-104) language was modified proposal] to present function first, followed by typical equipment.Term Low volume, high concentration or LVHC collection system Proposal/ supplemental notice definition Includes batch digester blow vents; batch digester relief steam condenser vents; continuous digester relief steam vents; turpentine condenser(s) vents; continuous digester blow tank vent ; evaporator vacuum system vents; liquor concentrator vacuum system vents; preevaporator vacuum system vents; steam stripper feed tank vents; and steam stripper off gas vents.

[from March 8, 1996 Federal Register supplemental notice] Industry recommendation Includes batch digester blow tank and/or blow heat recovery vents; batch digester relief condenser vents; continuous digester blow tank and/or blow heat recovery vents; continuous digester relief condenser vents; black liquor preevaporator; evaporator; and concentrator vacuum systems vents; foul condensate off gas vents; and foul condensate storage tank vents.
(A-92-40, IV-Dl-104) Final definition The gas collection and transport system used to convey gases from the LVHC to a control device. Rationale for final definition The proposal definition was modified to distinguish between the LVHC collection system and the LVHC system vents.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Malfunction None Any sudden and not The most current general The industry definition reasonably preventable provisions definition was adds language for failure of air pollution used. safety venting to the control equipment, a general provisions process , or process definition. However, equipment to operate in a the rule is not the normal or usual manner, appropriate mechanism or the venting of for changing the equipment for safety general provisions reasons. Failures that definitions. Any are caused by poor revisions to the maintenance or careless general provisions operation and not should be accomplished malfunctions. in the ongoing litigation. The most (A-92-40, IV-Dl-104) current general provisions definition was used. Mechanical None None A pulping process that Definition needed for pulping only uses mechanical and final rule. This thermo-mechanical process was not processes to reduce wood addressed in the to a fibrous mass. The proposed rule. mechanical pulping processes include, but are not limited to, stone groundwood, pressurized groundwood, refiner mechanical, thermal refiner mechanical, thermo-mechanical, and tandem thermo-mechanical.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Multiple- A series of evaporators Delete definition. This definition was The industry recommends effect operated at different replaced with the deleting this evaporator pressures such that the (A-92-40, IV-Dl-104) evaporator system definition from the system vapor from one definition. rule since evaporator evaporator body becomes system will be defined. the steam supply for The EPA agrees with the the next evaporator, commenter. and associated condenser(s) and hotwell(s) used to concentrate the spent cooking liquid that is separated from the pulp.

New kraft recovery furnace [from December 17, 1993 proposal] None A kraft recovery furnace Definition not needed. The rule does not located at an existing define new or existing source covered by this equipment but subpart, on which references the results construction or from the general reconstruction is provisions litigation. commenced after (proposal date for MACT II) or a kraft recovery furnace located at a new source.
(A-92-40, IV-Dl-104)Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition New source None For purposes of this The most current general The industry definition subpart, an affected provisions definition was is different from that source on which used in the rule. in the general construction or provisions. However, reconstruction is the rule is not the commenced after December appropriate mechanism 17, 1993. A unit process for changing the or component added to or General Provision modified at an existing definition. Any facility is not a new revisions to the source, unless such general provisions addition or should be accomplished reconstruction is so in the ongoing large as to make the litigation. The most entire facility a new current general source by virtue of the provisions definition definition of was used. "reconstruction" in this subpart.
(A-92-40, IV-Dl-104) Non- None None Definition not needed. This definition was condensible replaced with gas system definitions for LVHC and HVLC collection systems

. Non-wood None Includes pulping of flax The production of pulp The industry definition pulping straw, cereal straw, from fiber sources other appears to be bagasse, hemp, cotton, than trees. The non-wood technically correct. jute , kenaf, grasses, sources include, but are The EPA agrees with the leaf fibers , or secondary not limited to, bagasse, commenter. Language fiber repulping. cereal straw, cotton, was added to the flax straw, hemp, jute, beginning of the [Commente r IV-D2-141 kenaf, and leaf fibers. definition for clarity.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Nuisance None A device which circulates Definition not needed. The industry definition scrubber a liquid solution to appears to be remove pollutants from a technically correct. gaseous vent stream. The However, this effluent from a nuisance definition was not scrubber i s sewered and needed since the rule not recovered for cooking does not specify or acid production. identify control technologies for (A-92-40, IV-Dl-104) sulfit e mills. Operating A minimum or maximum A minimum or maximum Definition not needed. "Operating parameter parameter value established for a value established for a value" was incorporated value control device or control device or process into the rule; process parameter if parameter which, if therefore, the achieved by itself, or achieved by itself, or in definition was not in combination with one combination with one or needed. or more other operating mor e other operating parameter values; parameter values; is an determines that an indication that an owner owner or operator has or operator has complied complied with an with an applicable applicable emission emission limitation or limitation or standard. standard. [from December 17, 1993 (A-92-40, IV-Dl-104) proposa l]Term Oven-dried pulp Proposal/ supplemental notice definition None Industry recommendation Final definition A pulp sample at zero percent moisture content by weight. Pulp samples for applicability or compliance determinations for both the pulping and bleaching systems shall be unbleached pulp. For purposes of complying wit h mas s emission limits in this subpart, megagram of ODP shall be measured to represent the amount of pulp entering and processed by the equipment system under the specified emission limit. For equipment that does not process pulp, megagram of ODP shall be measured to represent the amount of pulp that was processed to produce the gas and liqui d stream s that the subject equipment is processing. Rationale for final definition This term was needed to define the units in the rule.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Oxygen Includes the blow tank, The equipment that uses The equipment that uses The industry definition deligni- the post oxygen oxygen to remove lignin oxygen to remove lignin appears technically fication washers, filtrate from pulp after from pulp after high- correct and adds tanks, and any brownstock high density density stock storage and specific equipment for interstage pulp storage storage and prior to the prior to the bleaching reference. The EPA tanks. bleaching component. The system. The oxygen agrees with the oxygen delignification delignification system commenter. The [from March 8, 1996 system includes the blow equipment includes the industry definition was Federal Register tank, the post oxygen blow tank, washers, slightly modified to supplemental notice1 washers, filtrate tanks, filtrate tanks, and any remove "brownstock" and and any interstage pulp interstage pulp storage add "but is not limited storage tanks. tanks, and any other to" to broaden the equipment serving the definition in the final (A-92-40, IV-Dl-104) same function as those rule. previously listed. Papermaking None All of the equipment used Definition not needed; it This definition was component to convert pulp into was included in the included in the paper, paperboard, or definition of "papermaking system" market pulp, including "papermaking system." definition. the stock storage and "Papermaking system" preparation systems (such better describes the as pulp mixing and definition than dispersion, beating and "papermaking refining, and addition of component." additives), the paper or paperboard machin e "wet end" systems (including sheet formation, pressing and vacuum systems), paper machine white water systems, broke recovery systems, an d "dry end" systems (including drying, calendering , onmachine coating, winding, slitting, and cutting).
(A-92-40, IV-Dl-104)Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Papermaking None None All equipment used to "Papermakin g component" system convert pulp into paper, was replaced by paperboard, or market "papermaking system" pulp, including the stock because "papermaking storage and preparation system" better systems, the paper or describes the paperboard machines, the definition. The EPA paper machine white water maintains that system, broke recovery industry's proposed systems , and the systems definition of involved in calendering, "papermaking component" drying , on-machine was too specific and coating, slitting, was modified to be more winding, and cutting. broad and also renamed "papermakin g system

. ” Part 70 None A permit issued by a The mos t current general The industry definition permit state permitting provisions definition was is different from that authority pursuant to a used. in the general program approved by EPA provisions. However, under part 70 of this the rule is not the chapter. appropriate mechanism for changing the (A-92-40, IV-Dl-104) general provisions definition. Any revisions to the general provisions should be accomplished in the ongoing litigation. Th e most current general provisions definition was used.Term

Process emission point Proposal/

supplemental notice definition A gas stream that contains hazardous air pollutants discharged during operation of process equipment including, but not limited to digesters, evaporators, pulp washing systems, bleaching towers, bleaching stage washers, and associated filtrate tanks. [from December 17, 1993 proposal] Industry recommendation The location where a gas stream that contains hazardous air pollutants is discharged from the process equipment in the pulping component, bleaching component, process wastewater component, chemical recovery component/system, papermaking component, or causticizing system as defined in this section. Process emission points include gas streams that are discharged directly to the atmosphere, discharge to the atmosphere via vents or open process equipment, or after diversion through a product recovery device.
(A-92-40. IV-Dl-104) Final definition Definition not needed. Rationale for final definition The EPA agrees with the industry revisions, however, this definition was not needed since the format of the rule has been revised to name specific vents to be controlled.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Process A piece of equipment, A grouping of equipment, Definition not needed. This definition was not wastewater structure, or transport structures, or transport needed since the collection mechanism used in mechanisms used in pulping wastewater system conveying or storing a conveying or storing a control options have process wastewater process wastewater been simplified. stream. Examples of a stream. Examples of process wastewater process wastewater collection system collection system equipment include equipment include foul individual drain condensate drain systems, systems , wastewater wastewater tanks, or tanks, surface surface impoundments. impoundments, or containers. (A-92-40, IV-Dl-104) [from December 17, 1993 proposal] Process Air emissions from all Delete definition. Definition not needed. This definition was not wastewater process wastewater needed since the format component streams produced from (A-92-40, IV-Dl-104) of the rule has been the pulping and revised to name bleaching processes. specific vents to be controlled. [from December 17, 1993 proposal]Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Process Any HAP-containing Any HAP-containing liquid Definition not needed. This definition was not wastewater liquid that results that results from contact needed since the format stream from either direct or of water with organic of the rule has been indirect contact of compounds. revised to name water with organic specific vents to be compounds. Examples of (A-92-40, IV-Dl-104) controlled. a process wastewater stream include, but are not limited to, digester condensates, evaporator condensates, and NC G system condensates. [from December 17, 1993 proposal 1 Process None A collection of equipment Definition not needed; The definition for wastewater or structures, a process, replaced by "process process wastewater treatment or specific technique wastewater treatment treatment system component that conveys or removes system." replaces "process or destroys any HAP in a wastewater treatment process wastewater component." stream. Examples include, but are not limite d to, a steam stripping unit, or a biological treatment unit.
(A-92-40, IV-Dl-104)Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Process A process or specific None A collection of "Process wastewater oastewater technique that removes equipment, a process, or treatment component" treatment or destroys the specific technique that was changed to "process system organics or any HAP in removes or destroys the wastewater treatment a process wastewater HAP's in a process system" because stream. Examples wastewater stream. "process wastewater include, but are not Examples include, but are treatment system" limited to, a steam not limited to, a steam better describes the stripping unit, stripping unit, definition. wastewater incinerator, wastewater thermal or biological treatment oxidizer, or biological unit. treatment unit. [from December 17, 1993 proposal]Term Pulp washing system Proposal/ supplemental notice definition Pulp or brownstock washers and associated vacuum pumps, filtrate tanks, and foam breakers or tanks used to wash the pulp to separate spent cooking chemicals following the digestion system and prior to the bleaching component. [from December proposal) 17, 1993 Industry recommendation None Final definition All equipment used to wash pulp and separate spent cooking chemicals following the digester system and prior to the bleaching system, oxygen delignification system, or paper machine system (at unbleached mills). The pulp washing system equipment includes vacuum drum washers, diffusion washers, rotary pressure washers, horizontal belt filters, intermediate stock chests, and their associated vacuum pumps, filtrate tanks, and foam breakers or tanks, and any other equipment serving the same function as those previously listed. The pulp washing system does not include deckers, screens, knotters, stock chests, or pulp storage tanks, following the last stage of pulp washing. Rationale for final definition The definition used in the rule was modified to address all pulp washing systems (i.e., separate definitions for brown an d redstock would not be needed) by removing the term "brown" and replacing with wor d "stock" with the word "pulp".Proposal/ supplemental notice definition All process equipment, beginning with the digester system, and up to and including the last piece of pulp conditioning equipment prior to the bleaching component, including treatment with ozone, oxygen, or peroxide before the first application of chlorine or chlorine-containing compounds. [from December 17, 1993 proposal] Industry recommendation The wood storage and preparation area (including debarking and chipping), the digester system, knotter systems, brownstock washer system, pulp storage, turpentine recovery system, multiple effect evaporator system, causticizing systems, weak and strong black liquor storage tanks, tall oil recovery system, oxygen delignification system, deckers and screens. The pulping component ends with the last stage of brownstock washing, deckers and/or screens, or the last stage of post-oxygen washing. Rationale for final Final definition definition Definition not needed; Industry indicated that included in definition of they want to include "pulping system." wood storage and preparation. The EPA disagrees because the rule does not address emissions from wood storage and preparation areas. This definition was incorporated into the "pulping system" definition.

(A-92-40, IV-Dl-104)Term Pulping process condensates Proposal/ supplemental notice Rationale for final definition Industry recommendation Final definition definition None None Any HAP-containing liquid that results from contact of water with organic compounds in the pulping process. Examples of a process condensates stream include digester system condensates, evaporator system condensates, LVHC, and HVLC system condensates, and any other condensates from equipment serving the same function as those previously listed. Liquid streams that are intended for by-product recovery are not considered process condensate streams. "Process wastewater stream " was replaced by "pulping process condensates" because "pulping process condensates" better describes the definition.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Pulping None None All process equipment, "Pulping component " was syste m beginning with the changed t o "pulping" digester system, and up system" because to and including the last "pulping system" better piece of pulp describes the conditioning equipment definition. prior to the bleaching system, including treatment with ozone, oxygen, or peroxide before the first application of a chemical bleaching agent intended to brighten pulp. The pulping system includes pulping process condensates and can include multiple pulping lines. Purchased Virgin pulp purchased Pulp purchased from an Definition not needed. The term is not used in pulp from an off-site off-site facility or the rule. facility or obtained obtained from an interfrom an inter-company company transfer from transfer from another another site. site. [Commente r 20,027] [from December 17, 1993 proposal, preamble]Term

Reconstruction Proposal/

supplemental notice definition None Industry recommendation The replacement of components at a source subject to this subpart to such an extent that: (1) The fixed capital cost of the new components exceeds 50% of the fixed capital cost that would be required to construct a comparable new source; and (2) It is technologically and economically feasible for the reconstructed source to meet the relevant standard(s) established in this subpart. Any reconstructed source is subject to relevant standards for new sources, including compliance dates, irrespective of any change in emissions or hazardous air pollutant from that source.
(A-92-40, IV-Dl-104) Final definition The most current general provisions definition was used in the rule. Rationale for final definition The industry definition adds language for safety venting. However, the rule is not the appropriate mechanism for revising the general provisions definitions. Any revisions to the general provisions should be accomplished in the ongoing litigation. The most current general provisions definition was used.Term Recovery device Proposal/ supplemental notice Rationale for final definition Industry recommendation Final definition definition An individual unit of Delete definition Definition not needed. This term is not used equipment, such as an entirely. in the rule. absorber or a condenser, capable of (A-92-40, IV-Dl-104) and used for the purpose of recovering chemicals for use, reuse, or sale.

[from December 17, 1993 proposal] Recovery furnace An enclosed combustion Delete definition. The proposal definition The EPA believes this device where was used in the rule. definition was concentrated spent (A-92-40, IV-Dl-104) necessary since liquor is burned to recovery furnaces are recover sodium and referenced in the sulfur, produce steam, pulping control and dispose of unwanted options. "Recovery dissolved wood furnace" replaces components in the "kraft recovery liquor. furnace" because "recovery furnace" is a [from December 17, 1993 broader definition. proposal] Redstock None The equipment used to Definition not needed. The brownstock and washer system wash sulfite pulp and to "Red stock washer system " redstock washer system separate spent sulfite was included in the "pulp definitions have been liquor (which is returned washing system" incorporated into the for recovery) following definition. "pulp washing system" the digester system. definition.
(A-92-40, IV-Dl-104)Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Relief valve A valve used only to None Delete the definition. This term is not used release an unplanned, in the rule. nonroutine discharge. A relief valve discharge can result from an operator error, a malfunction such as a power failure or equipment failure, or other unexpected cause that requires immediate venting of gas from process equipment to avoid safety hazards or equipment damage. [from December 17, 1993 proposal] Screen system A piece of process A piece of process All equipment in which The EPA agrees that the equipment where pieces equipment in which oversized particles are industry definition of oversized particles oversized particles are removed from the pulp adds clarity to the are removed from the removed from the pulp slurry prior to the rule. The proposal pulp slurry after the slurry after the bleaching or papermaking definition was slightly pulp washing system and brownstock washer system system washed stock modified (e.g., prior to the and decker system and storage. "brownstock " to "pulp") papermaking equipment. prior to the bleaching or to broaden the Equipment used to paper machine component definition. remove uncooked wood washed stock storage. prior to the pulp Pieces of equipment used washing system are to remove knots, considered knotters. oversized materials, or pieces of uncooked wood [from December 17, 1993 prior to the brownstock proposal] washer system are considered knotters.
(A-92-40, IV-Dl-104)Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Secondary None None A pulping process that Definition needed for Fiber pulping converts a fibrous final rule. This material, that has source was not in the previously undergone a proposed rule. manufacturing process, into pulp stock through the addition of water and mechanical energy. The mill then uses that pulp as the raw material in another manufactured product. These mills may also utilize chemical, heat, and mechanical processes to remove ink particles from the fiber stock. Segregated Any condensate stream No definition was Definition not needed. This term is condensate that contains at least provided by industry. incorporated into the stream (high- 65 percent by weight of However, they indicated rule language. HAP fraction) the total HAP mass in the July 9, 1996 (measured as methanol) letter that the percent that is present in the split between high and vapor stream prior to low fractions should be condensation or 50/50 (not 65/35). isolation. [from March 8, 1996 Federal Register supplemental notice]Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Spent liquor Cooking liquor from a Process liquid generated Process liquid generated The industry definition digestion or pulp- from the separation of from the separation of appears technically washer process, black liquor from pulp by cooking liquor from pulp correct. The final containing dissolved the pulp washing process, by the pulp washing definition was a organic wood materials containing dissolved system containing modified version of and residual cooking organic wood materials dissolved organic wood industry's definition compounds. and residual cooking materials and residual wit h "pulp washing compounds. cooking compounds. system " replacin g "pulp [from December 17, 1993 washing process." proposal] (A-92-40, IV-Dl-104) Steam A column, and A column , and associated A column (including The EPA believes that stripper associated condensers stripper feed tank, associated stripper feed industry comments system or heat exchangers, condensers or heat tank, condensers, or heat improve the definition used to strip compounds exchangers, used to exchangers), used to and have been from wastewater, using remove compounds from remove compounds from incorporated into the air or steam. foul condensate, using wastewater or condensates definition. air or steam. using steam. The steam Additionally, the [from December 17, 1993 stripper system also definition was revised proposal] (A-92-40, IV-Dl-104) contains all equipment to address methanol associated with a rectification. methanol rectification process including rectifiers, condensers, decanters, and storage tanks, and any other equipment serving the same function as those previously listed. Sulfite A chemical pulping None The proposal definition The proposed term pulping process that uses a was used in the rule. appropriately defines mixture of sulfurous the sulfite pulping acid and bisulfite ion process. as the cooking liquor. [from December 17, 1993 proposal]Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Surface A unit which is a Delete the definition. Definition not needed. This term is not used impoundment natural topographic in the rule. depression, manmade (A-92-40, IV-Dl-104) excavation, or diked area formed primarily of earthen materials (although it may be lined with manmade materials), which is used for the purpose of treating, storing, or disposing of wastewater and is not an injection well. Examples of surface impoundments are equalization, settling, and aeration pits, ponds, and lagoons. [from December 17, 1993 proposal] Temperature A piece of equipment A piece of equipment used A piece of equipment used The EPA agrees with the monitoring used to monitor to monitor temperature to monitor temperature industry definition. device temperature and having and having an accuracy of and having an accuracy of an accuracy o f +1 +1.0 percent of the +1.0 percent of the percent of the temperature being temperature being temperature being monitored expressed in monitored expressed in monitored expressed in degrees Celsius or +0. 5 degrees Celsius or +0.5 degrees Celsius or +0. 5 degrees Celsius (OC), degrees Celsius (OC), degrees Celsius (OC), whichever is greater. whichever is greater. whichever is greater. (A-92-40, IV-Dl-104) (A-92-40, IV-Dl-104)

[from December 17, 1993 proposal]Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Thermal None Thermal oxidizer means an Thermal oxidizer means an Industry indicated that oxidizer enclosed combustion enclosed combustion the term thermal device that is designed device that destroys oxidizer includes for thermally oxidizing organic compounds by incinerators. The EPA gaseous organic thermal oxidation. agrees with the compounds. commenter. Therefore the rule definition for (A-92-40, IV-Dl-104) "thermal oxidizer" includes incinerators. Also, the auxiliary fuel and energy recovery language in the incinerator definition was removed since it is not needed. Turpentine None The decanters and storage All equipment associated The industry definition recovery tanks used for recovering with recovering is specific to system turpentine from the turpentine from digester decanters and storage digester system. system gases including tanks. The EPA condensers, decanters, modified the definition (A-92-40, IV-Dl-104) and storage tanks, and to add more clarity, any other equipment specifically including serving the same function equipment used in as those previously turpentine recovery listed. The turpentine systems. recovery system includes any liquid streams associated with the turpentine recovery process such as turpentine decanter underflow. Liquid streams that are intended for byproduct recovery are not considered turpentine recovery system condensate streams.Proposal/ supplemental notice Rationale for final Term definition Industry recommendation Final definition definition Weak black None All storage tanks Definition not needed. The EPA agrees with the Liquor containing black liquor industry definition. storage tanks recovered from the For the rule, the brownstock washer system definition was slightly and prior to the multiple modified so that it is effect evaporator system. not specific to kraft (Brownstock or decker mills only. filtrate tanks are not Furthermore, weak black weak black liquor storage liquor storage tanks tanks.) were included in the definition for weak (A-92-40, IV-Dl-104) liquor storage tanks. Weak liquor None None Any storage tanks except This definition storage tanks washer filtrate tanks replaces weak black containing spent liquor storage tanks. recovered from the The definition was pulping process and prior expanded such that it to the evaporator system. was not specific to kraft mills. Working day None Any day on which the Definition not needed. Industry indicated that federal government this definition was offices are open for left out of the general normal business. provisions, however, Saturdays, Sundays, and the rule is not the official federal holidays mechanism for changing are not working days. general provisions definitions. Any (A-92-40, IV-Dl-104) revisions to the general provisions should be accomplished in the ongoing litigation. This definition is not needed in the rule.15.0 INTEGRATED RULE INTERACTION

15.1 GENERAL
Comment: Several commenters (20,019, 20,027, 20,039, 20,051, 20,057A2, 20,088, 20,089, 20,091, 20,115, 20,153) supported the concept of an integrated rule. However, several commenters (20,027, 20,039, 20,057A2, 20,059, 20,088, 20,115) criticized combining air and water regulations into one rule because they believed it failed to fully consider the cross-media impacts of each of the regulations. One commenter (20,091) stated that they were impressed with the coordinated effort by EPA to develop air and effluent guidelines but thought that pollution prevention should be carried further. One commenter (20,088) supported EPA's effort to combine air and water regulations, but stated that EPA should use a life cycle analysis , or holistic approach to evaluate the effectiveness of the combined rule. Several commenters

(20,049A3, 20,059, 20,082, 20,129, 20,132 , 20,133) indicated that EPA has authority under the Act to establish emission limits for

non-HAP's. One commenter (20,049A3) contended that EPA has the authority to set limits for other pollutants under the Act and should propose enforceable emissions limits for all air pollutants of concern including criteria and non-conventional pollutants. One commenter (20,059) cited section 111(d)(l) of the Act as authorization for EPA to establish "existing source"

15-1performance standards to control non-criteria pollutants, such as TRS, and to require State Implementation Plans (SIP) to incorporate these standards.

On e commenter (20,122) argued that a truly cross-media rulemaking would consider the impacts on workers, products, chemical accident potential , and hazardous waste generation. Response: The EPA disagrees with the commenters' suggestion that the cross-media impacts associated with the combined rule have not been addressed. All of the information submitted to the Agency following the December 17 , 1993 proposed rule and the March 8, 1996 supplemental notice has been considered in developing the final rule. For example, the effluent limitation guidelines and standards , established by EPA's Office of Water, have the potential to increase the solids loading sent to the

recovery process. This scenario was considered by OW in developing their cost and benefit analysis. In another case , the MACT standards and the effluent limitation guidelines and standards require 100 percent Cl02 substitution. This process modification would reduce the chlorine and chlorinated HAP's being sent to the bleach plant scrubber. Comments received following proposal indicated that the percent removal requirements for bleach plant scrubbers would be difficult to achieve if the mass of chlorine and chlorinated HAP's sent to the scrubber were reduced. In response to these comments, EPA included chlorine outlet concentration and outlet mass emission limit compliance options. Regarding pollution prevention efforts, the final rule will contain provisions for complying with the kraft pulping standards using a strategy that focuses on removing HAP's from in-process recycled or reused condensate streams before they are allowed to

15-2be volatilized into the atmosphere. Since the final rule does not identify the specific control technology to be used, this compliance alternative (the CCA) , provides industry with the opportunity to implement pollution prevention projects that can achieve the HAP reductions equivalent to the MACT standards. Additionally, the effluent guidelines contain voluntary performance-based incentive programs designed to compliment the baseline BAT to encourage individual mills to evaluate and install technologies that could achieve further pollutant reductions. Regarding the comprehensiveness of the regulations, NESHAP standards are limited to addressing the compounds contained in the HAP list in section 112(b) of the Act and emitted from the all significant sources at pulp and paper mills. Although there are some areas of the mill that are not specifically covered by the pulp and paper rule , EPA maintains that the rule addresses the pollutants , and pollutant sources deemed most critical at pulp and paper mills. The effects on workers and product markets caused by the MACT standards are evaluated in the EA (A-92-40, V-A-2). Chemical accident potentials are addressed under section 112(r) of the Act for applicable facilities. Residual risks of this rule will be addressed under section 112(f) of the

Act. Hazardous waste generation is addressed and regulated under

RCRA. The EPA maintains that all cross-media impacts will be considered, if not specifically under this rule, under other rules that are already in effect.

Comment: On e commenter (20,122) indicated that TCF and secondarily chlorine free (SCF recycled paper products that have not been secondarily bleached with chlorine and chlorine compounds) technologies should be evaluated from both air and

15-3water perspectives. The commenter (20,122) stated that it was

inappropriate for EPA not to consider the applicability of TCF/SCF technologies under the Act simply because they were eliminated from consideration under the CWA. The commenter (20,122) further asserted that EPA must develop a way to phase in TCF/SCF technologies within the rule and other authorities. Another commenter (20,102) encouraged incentives for producing paper using TCF and other environmentally friendly technologies. Response: The EPA has included incentives for facilities to use TCF processes in the final rule. For this NESHAP, all kraft mills have been given a total of 8 years to comply with the standard. This additional 5 years was given to allow facilities to install process equipment, such as oxygen delignification and TCF bleaching. The OW has also included several incentive packages in the effluent guidelines. These incentives would provide mills with additional compliance time, up to 16 years beyond the date of promulgation, to meet limitations more stringent than BAT. Qualifying technologies more stringent than BAT include oxygen delignification and TCF bleaching. Additionally, EPA considers that the TCF technologies would constitute compliance with the bleaching component of the MACT requirements. Therefore, in the air portion of the combined rule, EPA has indicated that application of TCF technologies for bleaching would comply with the bleaching standards.

Comment: One commenter (20,145) opposed the expansion of the combined rule to a multimedia permit concept. The commenter (20,145) indicated that a single multimedia permit at a facility would prevent new projects and delay major expansions. The commenter (20,145) opposed multimedia permits because they would limit the flexibility of industry to choose options for reducing

15-4pollutants and because changes that affect one permitted media would open the permit for review on all permitted media. Response: Compliance with the combined rule will not require a multimedia permit. The air and water regulations were developed jointly because of the multimedia nature of pollution control in this industry. The air and water regulations are being promulgated simultaneously to facilitate coordinated compliance planning. However, the regulations are being promulgated individually under the respective authorities of the
Act and the CWA. Accordingly , each regulation will be implemented under the authority of its respective Act. Permitting requirements, therefore, will be unchanged. This NESHAP will be implemented according the requirements of the part 63 general provisions and each mill's title V operating permit. New source review permits will be required for any new or modified sources. Water regulations will not be addressed in air permits , nor will air regulations be addressed in the permits required under the CWA. 15.2 EFFLUENT GUIDELINES
Comment: Two commenters (20,018 , 20,027) questioned whether EPA had effectively evaluated the integration of air and water standards for the bleaching component. One commenter (20,057A2) stated that EPA has not evaluated the impact of the proposed air standards on the effluent guidelines. One commenter (20,018) indicated that there appeared to be inconsistencies between the proposed MACT standards for the bleaching component and the technology requirements applied to pulp bleaching in the effluent guidelines due to lack of coordination between air and wastewater groups. The commenter

(20,018) stated that the proposed effluent guidelines require

15-5complete substitution of chlorine with Cl02 for kraft bleaching. The commenter (20,018) contended that MACT for the bleaching component should be complete Cl02 substitution since emissions of chlorine and chloroform from a Cl02 bleaching stage are significantly lower than a chlorine bleaching stage. One commenter (20,027) stressed that the impact of the effluent guidelines proposed process changes on elemental chlorine emissions should have been considered when determining the air control options for the bleach plant. The commenter

(20,027) stated that substitution of Cl02 for elemental chlorine plus oxygen delignification would greatly reduce the concentration of elemental chlorine at the inlet to bleach plant scrubbers. The commenter (20,027) pointed out that this would make it difficult to demonstrate the high removal efficiency required by MACT and significantly increase the probability of a calculated exceedance when, in reality, the actual emissions of chlorine were very small. Response: The EPA has conducted several impact analyses on the integration of the air and water standards and maintains that a sufficient evaluation of the integration of these two standards has been completed. The EPA has analyzed air emissions after implementation of the effluent limitation guidelines and standards options (referred to as OW Options A and B), and TCF. Results of these analyses are presented in chapter 20 of this document. The December 17 , 1993 proposed rule specified that HAP emissions from chlorine or chlorinated compound application stages must be reduced by 99 percent. The EPA agrees with the commenters that Cl02 substitution , required by OW and the MACT floor, will decrease the amount of chlorine in bleach plant

15-6scrubber inlets and that a 99 percent reduction of chlorinated HAP's from a Cl02 application stage may not be feasible. As discussed in the March 8 , 1996 supplemental notice, EPA incorporated a scrubber outlet chlorine concentration and considered a mass emission limit as options for the bleaching system requirement. The outlet concentration, mass emission limit, and the percent mass reduction options are considered by EPA to be equivalent (A-92-40, II-I-24, IV-B-29).
Comment: One commenter (20,027) stated that the waste heat that will accompany steam stripping will have adverse water pollution consequences. The commenter (20,027) noted that many mills (particularly in southern States) have heat-limited effluent treatment systems. The commenter (20,027) declared that requiring increased steam stripping at such mills would probably lead either to noncompliance with NPDES limits or to the need to construct cooling towers. Response: The EPA reviewed the data submitted by industry (A-92-40, IV-Dl-46) detailing the number of cooling towers existing in the pulp and paper industry. (The data indicated tha t I3 cooling towers were being used.) No additional data were submitted to EPA regarding potential conflicts with steam stripping and the NPDES permit program or the prevalence of cooling towers used in conjunction with steam stripping systems. While some mills may need cooling towers to handle the waste heat load from the pulping and bleaching processes, EPA's judgment is that it is not appropriate to assign the costs for installing and operating cooling towers to all mills for estimating national impacts.

15-715.3 COMBUSTION MACT
Comment: Several commenters (20,027, 20,018, 20,043, 20,054A2, 20,056, 20,057A2, 20,146) argued that all processes in the mill are interrelated and that EPA failed to consider this when it failed to propose combustion MACT standards with the MACT standards for other sources. Two commenters (20,027, 20,057A2) claimed that EPA proposed an integrated rule that requires changes in the technology and engineering of process-source emissions without considering the impact of those changes on the design, capacity, and engineering of the liquor recovery process. Several commenters (20,011, 20,014, 20,027, 20,043, 20,046) stated that the lack of integration between the process sources and combustion source rulemakings has several technical, engineering, emissions , and economic implications that were not considered by EPA. One commenter (20,014) stated that it is difficult to evaluate the combined regulations because the air emission regulations for other sources at the mill

(i.e., recovery furnaces, lime kilns, smelt dissolving tank vents, oxidizers, and power boilers) are not known. Another commenter (20,046 , 20,046A2) contended that the costs associated with the combustion sources must be considered as part of the ultimate cost/benefit analysis of the combined rule. Several commenters (20,027, 20,043, 20,056, 20,114) urged EPA to integrate the combustion and process MACT standards and re-propose the NESHAP. One commenter (20,059) indicated that the deferral of proposals for combustion and certain non-combustion sources frustrates the objective of a coordinated pollution prevention approach. Several commenters (20,011, 20,027, 20,043, 20,059, 20,066A3) indicated that EPA must consider the impacts the proposed non-combustion standards and combustion standards

15-8would have on each other because the two types of sources are so interrelated. Three commenters (20,027, 20,043, 20,066A3) cited examples of pulping emission units at sulfite mills that are currently controlled by combustion source control equipment and combustion emission sources (white liquor production) that are affected by water reuse patterns. One commenter (20,057) indicated that the combustion and non-combustion standards must be consistent with each other. Three commenters (20,046A2, 20,056 , 20,074) indicated that the costs of the pending combustion source MACT regulations are likely to be very high , and in order to assess the total costs of the regulations o n mills, EPA should wait until the combustion source requirements are clearly understood and then integrate them into the cost-effectiveness assessments. Response: In the preamble to the Decembe r 17, 1993 proposal, EPA indicated that the combustion source MACT standards were expected to be proposed in 1994 and be promulgated together with the standards for the non-combustion source emission points and effluent guidelines. After further evaluation and analyses, EPA proposed the combustion source standards as the noncombustion MACT standards and the effluent guidelines were promulgated. The EPA contends that the Agency has considered the interrelated nature of pulp and paper mill s and impacts of the combined rule (i.e., combustion sources, non-combustion sources, and effluent guidelines). The non-combustion source standards address HAP emissions associated with pulping and bleaching

processes. The only potential conflict between the combustion and non-combustion source standards is the use of recovery furnaces as emissions control devices. While combustion sources

15-9(e.g., chemical recovery operations) are not covered in the scope of the non-combustion source standards , the recovery furnace has been identified as a control device for pulping emissions used at a limited number of existing facilities. Comments received following proposal have stressed that industry groups strongly recommend that recovery furnaces not be used for controlling pulping emissions due to serious explosion risks. Although EPA agrees with the industry's concerns regarding explosion hazards, the final rule contains a control option for routing pulping emissions to a recovery furnace, power boiler, or lime kiln to provide individual mills flexibility in complying with the noncombustion source standards. The effluent limitation guidelines and standards contain requirements that have the potential to affect combustion

sources. Most notably , the effluent limitation guidelines and standards for handling black liquor spills which will likely result in increased solids loading to chemical recovery

processes. The EPA's OW has taken these interactions into account in their costs and impacts analyses. With regard to sulfite mills , EPA has established a separate subcategory for these pulping processes and re-evaluated the floor level of control. This analysis was discussed in the March 8, 1996 supplemental notice. Consequently, EPA determined that sulfite pulping emissions are typically controlled using the acid making/chemical recovery systems at these mills. The acid making/chemical recovery systems at sulfite mills should not be affected by the combustion source standards.
Comment: On e commenter (20,053Al) suggested that emission standards for black liquor oxidation (BLO,) systems should be included in the proposed pulping emission standards. The

15-10commente r (20,053Al) asserted that control of HAP emissions from

BLO , systems would be substantially more cost effective, and would result in significantly greater environmental benefits than treatment of insignificant HAP sources such as brownstock washer vents and oxygen delignification vents. Response: The EPA disagrees with the commenter regarding the insignificance of brownstock washer vents and oxygen delignification vents. As presented in the revised emission factor document (A-92-40, IV-A-8), HAP emissions from these sources are not insignificant. With regard to the appropriate placement in the rule for BLO, systems, EPA contends that these systems should be considered part of the chemical recovery process (i.e. , combustion sources). The purpose of BLO, systems is to convert sodium sulfide into thiosulfate. This conversion is done to prevent the stripping of hydrogen sulfide gas in the chemical recovery process and is therefore best considered under the combustion source MACT standards.

15-1116.0 INTERACTION WITH OTHER RULES

16.1 NEW SOURCE REVIEW/PREVENTION OF SIGNIFICANT DETERIORATION
Comment: Industry and some States have commented extensively on the potential problems that could result from the interaction between the December 17 , 1993 proposed rule and the NSR program. The NSR program includes the PSD and nonattainment NSR preconstruction permit programs. Regarding the December 17, 1993 proposed rule, many commenters (20,027, 20,057, 20,057A2, 20,071, 20,103, 20,111, 20,118) stated that: (1) the control equipment and process changes required to comply with the rule will increase emissions of SO 2 and NO x ; (2) these compounds are generated from the combustion of vent gases required by the rule; and (3) the increases in SO2 emissions could be of such magnitude to trigger the need for preconstruction permits under the PSD/NSR program. Several commenters (20,027, 20,043, 20,053A1, 20,054A2, 20,057, 20,057A2, 20,146) maintained that there are issues and impacts of PSD/NSR review that were overlooked by EPA. Commenters indicated that NSR review would: (1) cost the pulp and paper industry significantly more for permitting and implementation of NSR and PSD requirements than predicted by EPA (2) impose a large permitting review burden on State air quality offices; and (3) present difficulties for mills to meet the

16-lproposed NESHAP compliance schedule of 3 years due to the time required to obtain a preconstruction permit. One commenter (20,071) indicated that, for some sources, it would be difficult or impossible to obtain permits due to emission caps and difficulties obtaining offsets. The commenter

(20,071) indicated that sources would be required by one set of regulations to install emission controls and constrained from beginning construction on them by another set of regulations. One commenter (20,027) noted that the PSD/NSR review could preclude existing combustion devices from controlling vent gases

(i.e., stand-alone thermal oxidizers would have to be used). One commenter (20,043) also noted that a steam-limited facility near a Federal Class I PSD area (61 FR 38250, July 23, 1996) area may not be able to perform the required steam stripping because an increase in criteria air pollutant emissions, resulting from increased steam production, may be prohibited, or limited, by the PSD air quality restraints. Many commenters (20,010, 20,011, 20,027, 20,011, 20,057A2, 20,010, 20,111, 20,118) made recommendations on how EPA should handle the issue of PSD/NSR in the final rule. Several

commenter s (20,010, 20,011, 20,057A2, 20,111, 20,118) stated their views on whether or not the pollution controls required by MACT should be excluded from PSD/NSR review. Three commenters

(20,027, 20,011, 20,057A2) proposed that controls installed to comply with MACT standards be granted an explicit "pollution control " exclusion from PSD review and NSR. One commenter

(20,057A2) recommended that EPA include language in the PSD and NSPS regulations to exempt sources that install controls as a result of MACT standards , rather than in each MACT standard.

16-2One commenter (20,010) indicated that the PSD regulations should not be bypassed for situations where the installation of new incineration equipment results in increases in criteria pollutants. One commenter (20,111 ) indicated that the installation of MACT controls should trigger PSD or NSR requirements if there is an associated increase in pulp production or in the permitted emission levels of the existing boiler. Response: An industry-wide NSR exemption for pulp and paper mill s is not necessary because EP A already has an existing policy for excluding from NSR pollution control projects (PCP) at existing sources (July 1 , 1994 memorandum from John Seitz, "Pollution Control Projects and NSR" " and proposed revisions to 40 CFR parts 51 and 52 at 61 FR 38250). The PCP exclusion is granted on a case-by-case basis by the permitting authority. Under this policy, projects that are eligible include physical or operational changes whose primary function is the reduction of air pollutants subject to regulation under the Act (e.g., MACT standards). To obtain the exclusion, a mil l must submit a request for exclusion to the permitting authority through either a minor NSR permitting process , a State non-applicability

process, or other similar process. Modifications to existing combustion devices (e.g. , boilers) or the addition of a standalone thermal oxidizer to comply with a MACT standard are the types of technologies that would qualify for a PCP exclusion. To grant a PCP exclusion , the permitting authority must determine that the project i s "environmentally beneficial" and would cause no adverse air quality impacts. An adverse air quality impact is defined as causing or contributing to the violation of a national ambient air quality standard (NAAQS), a

16-3PSD increment , or an air quality related value (AQRV) in a Federal Class I PSD area (e.g., national parks). Th e AQRV's are specified by the responsible Federal Land Manager (FLM). In the March 8 , 1996 supplemental notice, EPA presented a strategy for streamlining the process of granting a PCP exemption. Based on an evaluation of pollutant reductions and environmental and energy impacts , the notice proposed a policy statement that projects implemented to comply with the MACT portion of the December 17 , 1993 proposed rule were to be considere d "environmentally beneficial" under the Agency's PCP policy. This determination would mitigate one of the two caseby-case determinations required by the permitting authorities. A case-by-case determination that PCP would pose no adverse air quality impacts would still be required in order for the exemption to be granted. The March 8, 1996 supplemental notice requested comment on the determination that these MACT control projects are environmentally beneficial and eligible for the PCP exemption. The EPA also solicited comments on providing a specific exclusion in the NSR rule for these types of controls installed to comply with MACT. Issues related to the time required to obtain a PSD/NSR review and the impact on the compliance schedule are addressed in the response to the following comment summary.
Comment: With regard to the March 8, 1996 supplemental notice, several commenters (IV-D2-2, IV-D2-3, IV-D2-7, IV-D2-10, IV-D2-11) stated that the guidance by EPA regarding the existing PCP exclusion was inadequate , and recommended including specific language in the pulp and paper MACT rule exempting MACT compliance projects from PSD/NSR review. On e commenter

16-4(IV-D2-15) supported EPA's determination that MACT compliance projects will be environmentally beneficial and should qualify for exemption under EPA's PCP exclusion guidance. However, the commenter (IV-D2-15) contended that EPA should recognize that when mills install the controls required for MACT, they will likely upgrade other parts of the operation at the same time, including increases in capacity. The commenter (IV-D2-15) requested that the exclusion be broad enough to include all the actions taken concurrently with the MACT installation. The commenter (IV-D2-15) requested a firm commitment from EPA that MACT compliance projects will be expressly excluded from coverage in the new NSR reform regulations. Two commenters (IV-D2-11, IV-D2-15) urged that EPA include language in the pulp and paper MACT rule that will expressly exclude any project installed for the purpose of complying with MACT from NSR or PSD review without any need for a site-by-site air quality benefit analysis. Another commenter (25,538) objected that both the PCP exemption and proposed NSR reform rule provide inadequate relief. Both policies still give the FLM an opportunity to conduct an AQRV review. The commenter (25,538) also objected that these policies apply only t o "modifie d " sources and not to new emission units (e.g. , new boilers) that may be constructed to comply with the rule. The commenter (25,538) indicated that, because the granting of NSR relief is voluntary by the State, it is doubtful that the States will confer the NSR relief that EPA has proposed. As a result , the commenter (25,538) asserts that additional controls on these collateral emissions will be required, and EPA has not taken into account the cost of these additional controls.

Two commenters (20,057A2, 20,118) on the December 17, 1993 proposed rule had noted that EPA failed to consider the

16-5additional burden that PSD/NSR review would have on State permitting agencies. One commenter (IV-D2-4) strongly opposed the specific exclusion of these types of projects in the NSR rules. The commenter (IV-D2-4) noted that these projects are not necessarily environmentally beneficial and should not be eligible for automatic exemption from major source NSR. The commenter

(IV-D2-4) also expressed concern that EPA's statement that MACT compliance projects ar e "environmentally beneficial" and would limit the States ' authority to apply the environmental safeguards available in the July 1, 1994 policy. These safeguards are required to ensure that progress made by permitting authorities to reduce air pollution is not compromised. One commenter

(20,103) questioned what the appropriate response would be where an increase in SO 2 results in potential violation of SO 2 NAAQS. Response: The PCP exemption offered by the current policy 

### ( July 1 

### , 1994 memorandum from John Seitz, "Pollution Control Projects and NSR" and proposed revisions to 40 CFR parts 51 and 52 at 61 FR 38250) and in the proposed NSR reform (61 FR 38250) provides adequate relief from any cost or schedule impacts of NSR that are unreasonable. In the December 17, 1993 proposed rule, EPA has concluded that projects implemented to comply with the rule ar e "environmentally beneficial," under the context of the NSR program, based on the overall environmental impacts associated with this rule. This conclusion, along with the proposed NSR reform rule , should reduce some of the uncertainty with the policy and help provide uniformity in its application. The Agency does not believe, however , that an automatic exemption from NSR is appropriate or necessary. Case-by-case review and approval by the permitting authority is a necessary and

16-6appropriate step to ensure that the environmental safeguards are met and that the approval is subject to public notice. The environmental safeguards are protection of the NAAQS, PSD increments, an d AQRV's in Federal Class I areas; and the securing of offsetting emission reductions if the project results in a significant increase of a nonattainment pollutant. Designation of MACT projects a s "environmentally beneficial" does not limit the States ' authority to apply these environmental safeguards, as provided in the July 1994 policy. The case-by-case nature of the PCP exemption should not impede the granting of exemptions. The objections to the proposed exclusion that were raised by the State and local air pollution control agencies pertained primarily to EPA's request for comment on the proposed option of granting in the rule an automatic exemption from major NSR. An exemption in the rule could allow significant emission increases even in cases with local air quality problems. Their position was that the environmental safeguards in the current policy should be retained. The EPA agrees that an automatic exemption from major NSR is not appropriate. In addition , the procedure of a PCP application and review by the permitting authority is necessary to ensure that the PCP exemption is not applied to projects performed concurrently with NESHAP compliance that would result in an increase in process utilization or emissions. The types of projects suggested by one commenter as being candidates for PCP exemption include such activities as concurrent process upgrades to increase production capacity. The EPA believes that these are the types of projects that the Act presumes should be subject to NSR preconstruction review. Review by the permitting authority

16-7through the minor NSR process, therefore, is a necessary safeguard to monitor appropriate application of the policy. Obtaining a minor NSR permit should not impose any significant delays that would adversely affect the ability of pulp and paper mills to comply with the NESHAP on time. Possible triggers for NSR/PSD review would be SO2 and NO x emission increases associated with the control of pulping systems. First, most of the mills that will experience significant SO2 and NO x emission increases will be kraft mills, and the final rule allows 8 years for compliance with the kraft pulping HVLC system requirements. In addition , a mill can request a compliance date extension of up to 1 year if needed for the installation of controls. Delays in the ability to install controls that are caused by the permitting process could qualify for this additional extension. In addition, the proposed NSR reforms contain measures to reduce the delays that sometimes are associated with permitting near Federal Class I PSD areas. The proposed NSR reforms better define the role of the FLM and the procedures to follow for an AQRV analysis. The proposed NSR reforms require that the FLM provide to the applicant, in advance, a current list of relevant AQRV, sensitive receptors , critical pollutant loadings for each AQRV and the methods available to analyze potential impacts. The rule also will define the role of the FLM and set a timetable for FLM involvement in the permitting process. These reforms should streamline the process by reducing much of the uncertainty inherent in the current process. The claim that the PCP exemption is a "voluntary" action by the permitting authority is somewhat misleading. The current policy and the proposed NSR rules contain specific criteria for

16-8issuing an exemption. Emissions cannot cause or contribute to a violation of a NAAQS, and PSD increment, or an AQRV. These criteria involve local air quality impacts that must be considered on a case-by-case basis. Also, review by the local authority is needed to ensure that the proposed project is a MACT compliance activity. Projects that meet these criteria qualify for an exemption from major NSR, and there is no reason to believe that the permitting authority will not issue the exemption if all the legal criteria are met. In conclusion , EPA maintains that for the majority of pulp and paper mills , compliance with the NESHAP will not trigger major NSR because most mills will qualify for, and obtain, a PCP exemption from NSR. Since NSR is not expected to occur in a widespread or frequent manner , it is not appropriate to account for additional costs of NSR in the national impacts of the rule. Likewise, a significant burden increase on State permitting agencies is not expected. The 8-year compliance period for designated HVLC system operations at kraft mills with potential NSR problems allows the time to explore alternative pollution prevention programs that have less secondary impacts, like those anticipated with the clean condensate alternative.

Comment: One commenter (20,057A2) suggested that EPA evaluate the impact of the proposed rule on the northeast Transport Region ozone non-attainment areas (NAA). The commenter

(20,057A2) requested that EPA provide guidance on meeting the NO x reasonably achievable control technology (RACT) standards and for new source compliance with LAER. Response: The EPA has concluded that this rule should not have an adverse impact on ozone attainment in the northeast Ozone Transport Region (OTR) because the decreases in VOC emissions are

16-9very large compared to the potential increases in NO x emissions (about 75 to 1). The rule will decrease VOC emissions by 409,00 0 Mg/yr and may increase NO x emissions by 5,230 Mg/yr, nationally. The EPA recognizes that some of those increases will occur in the northeast OTR. These increases in NO x are very small in comparison with current national and regional NO x emissions and with current NO x emissions from pulp and paper plants subject to the final rule. Increases in NO x emissions from compliance with the MACT standard are estimated at about 5,23 0 Mg/yr (5,75 3 tons/yr). National NO x emissions in 1994 were approximately 21.4 million Mg/yr (23.6 million tons/yr). Increases in N O x emissions resulting from compliance with the NESHAP are primarily due to increased steam demand for steam stripping the pulping process condensate streams. Combustion of pulping vent streams accounts for a minority of the estimated increases in NO x emissions. Facilities installing boilers or increasing boiler capacity to meet the increased steam demand may have to meet NO x , RACT standards or LAER. For these facilities, EPA has provided guidance on meeting NO x standards in a documented entitled Alternative Control Techniques Document -- NO x Emissions from Industrial/Commercial/Institutional (ICI) Boilers, EPA-453/R-94-022, published in March 1994. This document outlines several options for reducing NO x from industrial boilers. For combustion devices used to combust pulping vent streams, EPA does not believe that guidance on NO x RACT and LAER is

necessary. The EPA has concluded that approximately 70 percent of all facilities will comply with the pulping standard by routing vents to existing combustion devices and 30 percent will

16-10construct incinerators to control the vents (A-92-40, IV-E-93). Analysis of existing combustion sources shows that a 5 percent increase in fuel use is required to incorporate the vent streams and keep the combustion device at a consistent level of operation

(A-92-40, II-B-31). Such a small increase in fuel requirements should result in minimal NO x increases at these mills. The facilities using existing combustion devices should not trigger any additional N O x RACT requirements beyond those already in place for these devices. For the 30 percent of facilities EP A estimates will install new incinerators, NO x increases are not expected to trigger LAER, because the anticipated emissions increases are below the emission thresholds for nonattainment NSR. For incinerators, the rule requires 98 percent HAP reduction. The rule requires 98 percent reduction of HAP's or an operating temperature of 1600 OF at a residence time of 0.75 seconds. Sources are not expected to operate incinerators at temperatures significantly higher than 1600 OF due to added fuel costs. Analysis of NO x formation mechanisms show that below 1800 OF, negligible levels
of NO x are generated. Therefore, the standard tends to minimize the additional formation of NO x . In the event that a facility that does become subject to NO x RACT, available technologies include low-NO, burners , selective catalytic reduction (SCR), or selective non-catalytic reduction (SNCR) technologies.

Comment: On e commenter (20,027) maintained that the exclusion from NSR and PSD review for the installation of pollution control projects (including process modifications such

as Cl02 substitution) is legally required based on the definition

o f "modification " in NSPS regulations.

16-11Response: The comment is incorrect. A pollution control project modification is not legally required to be exempted from NSR and PSD review based on the NSPS definition of "modification" in 40 CFR part 60. For purposes of NSPS , the addition or use of any system or device whose primary function is the reduction of air pollutants is not considered to be a "modification. " This definition, however, has no application to the NSR/PSD rules. A separate and distinct definition of "modification" is specified for NSR/PSD implementation in 40 CFR parts 51 and 52. 16.2 RESOURCE CONSERVATION AND RECOVERY ACT/BOILERS AND
INDUSTRIAL FURNACES
Comment: Regarding the December 17, 1993 proposal, two commenters (20,011 , 20,027) agreed with the proposed requirement of combusting steam stripper overheads in the process wastewater

area. According to three commenters (20,027, 20,057, 20,057A2) the overhead stream should be condensed to enhance the fuel value by concentrating the methanol. Three commenters (20,027, 20,057, 20,146) pointed out that increasing the concentration of methanol would increase the cost-effectiveness of this control option; however, burning a waste-derived fuel would likely trigger the Resource Conservation and Recovery Act/Boilers and Industrial Furnaces (RCRA/BIF) rules. Several commenters (20,011, 20,027, 20,054A2, 20,057, 20,057A2, 20,071) indicated that EPA failed to address the potential RCRA/BIF implications of the combined rule. Three of these commenters (20,027, 20,057A2, 20,071) urged EPA to exempt the burning of methanol condensates (from steam-stripping devices installed to meet the HAP reduction requirements) from the RCRA/BIF rules under a "clean fuels exemption," as long as they are combusted on site and only exhibit the characteristic of ignitability.

16-12One commenter (20,078) indicated that the need for both a title V air permit and a RCRA permit (when methanol is concentrated and burned) was redundant and suggested issuing only air permits. The commenter (20,078) stated that a similar process is currently in place for water quality/RCRA issues using a NPDES permit. In the March 8 , 1996 supplemental notice, EPA proposed to exclude from RCRA/BIF requirements the combustion of steam stripper system condensates. Three commenters (IV-D2-7, IV-D2-15, IV-D2-19) supported EPA's decision that stripper vent gases that were condensed and combusted on site to meet MACT requirements should not be subject to the RCRA/BIF requirements. One commenter (IV-D2-15) expressed concern that EPA limited the scope of its decision to only those stripper overheads that have been concentrated before being combusted. The commenter

(IV-D2-15) stated that some mills may be able to meet the MACT requirements without rectifying their vent gases, but because those gas streams may condense naturally, they would fall under RCRA/BIF. The commenter (IV-D2-15) stated that although these mills may not be utilizing their methanol streams to their greatest energy potential , the environmental risk posed by burning the unconcentrated materials would be no greater than that for the rectified materials. The commenter (IV-D2-15) recommended that EPA modify its proposal in the final rule to allow mills that simply condense stripper vent gases and burn these condensates to be excluded from regulations under RCRA/BIF. One commenter (IV-D2-3) recommended that the methanol rectification system (steam stripper, rectifier, separate tanks, and delivery system) be exempted as a whole from RCRA/BIF. Such an explicit exclusion will ensure that a facility may efficiently

16-13re-use methanol fuel without component pieces of the handling system being re-regulated by BIF. One commenter (IV-D2-14) noted that the proposed standards for pulp mills may trigger RCRA/BIF regulations, and specifically stressed concern over RCRA/BIF applicability at the point of generation of the pulping process condensate waste stream. To resolve the conflict , the commenter (IV-D2-14) suggested that the collection and subsequent stripping or alternative treatment of pulping process condensate should be exempt from RCRA/BIF and should only be regulated by MACT standards. The commenter (IV-D2-14) also requested that EPA include red and foul oil in the MACT exemption from RCRA/BIF for stripper overhead products. The commenter (IV-D2-14) also requested that EPA explicitly define turpentine, red oil , or foul oil burning at kraft mills as activities currently regulated by the Act and exempted from RCRA. Response: As explained in the March 8, 1996 supplemental notice, EPA has concluded that regulation of the combustion of condensates , whether rectified or dilute, is not needed under RCRA/BIF because the MACT controls will be adequately protective

(and certainly sufficiently protective to eliminate the need for RCRA controls until the residual risk determination under section 112(f) of the Act is conducted). The condensate does not contain chlorinated HAP's , and any organic HAP's in the condensate would be controlled to the level specified by the MACT standards. In addition , EPA maintains that the burning of this condensate does not produce any additional HAP's due to the high temperature and residence times found in the combustion devices that would be used to comply with the kraft pulping standards. Therefore, burning condensate will not increase the potential environmental risk over the burning of the steam stripper vent

16-14gases prior to condensation. Additionally, the use of the condensate as a fuel could reduce or eliminate the need for supplemental firing of fossil fuels in such combustion devices. The potential cost savings produced by allowing the burning of condensed steam stripper vent gases would be significant. Industry estimates that annual cost savings would be approximately $850,000 per mill , or $100 million for the entire kraft industry. Cost savings would come primarily through the reduction in fossil fuel purchases. In summary, regulation under RCRA is not necessary since the practice in question would not increase environmental risk, reduces secondary impacts , and provides a cost savings. Further considerations of risk should appropriately be handled as part of the section 112(f) residual risk determination required for all sources after implementation of MACT standards. For these

reasons, EPA will exclude from the BIF requirements of RCRA combustion sources that burn condensates derived from steam stripper overheads. This decision is consistent with RCRA section 1006, which requires EPA t o "integrate all provisions of [RCRA] for purposes of administration and enforcement and . . . avoid duplication, to the extent practicable , with the appropriate provisions of the Clean Air Act . . . "

. The EPA acknowledges that the imposition of RCRA regulations in this instance would result in the types of unnecessary duplication that section 1006 is intended to prevent. The EPA maintains that steam stripping with rectification followed by combustion of the concentrated condensates is MACT, given the energy, economic , and environmental impacts. See generally 60 FR 32587, 32593 (June 23, 1995), and 59 FR 29570, 29776 (June 9 , 1994) where EPA similarly found that RCRA

16-15regulation of secondary lead smelter emissions was unnecessary, at least until completion of the residual risk process. Some mills further process the condensate to extract turpentine and red and foul oils. The EPA notes that it considers the residues that are generated as part of this processing of the condensates to be within the scope of the exclusion when such residues are burned as fuels for the same reasons given above. (These residues also may not exhibit the ignitability characteristic , and so would not be hazardous in any case.) Also, the Agency notes that the turpentine and red and foul oils , which can be put to use as raw materials or non-fuel products, are not subject to RCRA under the existing regulations either because they are co-products and not secondary materials

(see 40 CFR 261, l(b) (3) and 261, 2(c)), or because they are used as ingredients or as substitutes for commercial chemical products

(40 CFR 261 , 2(e) (1 ) (i) and (ii)). 16.3 SECTION 112 RULES (112(g), 112(j), 112(r))
Comment: Section X.L

. of the preamble to the proposed regulation discussed regulations under development that could affect new, modified , or reconstructed sources at pulp and paper mills. The preamble encouraged commenters concerned with the interaction between the proposed 112(d) NESHAP, section 112(g), and 112(j) rules to submit those concerns as comments to the proposed 112(g) rule.
One commenter (20,054A2) indicated that they did not have time to fully evaluate the impact or interaction of the 112(g) rule because it was proposed during the MACT comment period. The
commente r (20,054A2) requested that EPA provide an additional comment period for further comments on the relationship between

16-16the broad definition of source proposed in the MACT standards and 112(g).

. Another commenter (20,027) asserted that pulp and paper sources should be exempt from 112(g) review. The commenter (20,027) also asserted that EPA's proposed MACT standards should not be used as the starting point for 112(g) determinations in view of the flaws contained in the proposal. The commenter

(20,027) advised that EPA should issue a public statement to that effect. Response: These comments address issues that are no longer relevant to the pulp and paper industry because section 112(g) will not apply to sources covered by this NESHAP. At the time that the pulp and paper standards were proposed (December 1993), the section 112(g) rules had not been proposed. Since then, the 112(g) rules have been proposed (63 FR 15504, April 1, 1994) and the public comment period was reopened (61 FR 13125, March 26, 1996) in a draft final rule. These actions have addressed issues associated with the relationship between section 112(g) and the MACT standards. Moreover, on February 14, 1996 , the Agency published an interpretive notice

(60 FR 8333) that deferred the applicability of section 112(g) until after the final section 112(g) regulations are promulgated. The section 112(g) rule was promulgated on December 27, 1996

(61 FR 68384). The final 112(g) rule should have no effect on the pulp and paper processes covered by the section 112(d) MACT standards. The section 112(g) program is a transitional measure to protect the public from HAP's until EPA issues the MACT standards for a listed source category. As stated in the final 112(g) rule, only sources that commence construction or reconstruction after

16-17June 29, 1998 , will be effected , unless a State program to implement the 112(g) provisions is adopted sooner. Since the 112(d) MACT standard for pulp and paper mills will be promulgated in 1997, the sources addressed in this rule will be exempted from 112(g) review.

Comment: Two commenters (20,102 , 20,103) suggested that EPA use its 45-day review period on all part 70 (title V) permits to evaluate case-by-case MACT determinations for consistency with any proposed but not yet promulgated MACT standards to provide consistency between 112(g) and MACT standards. Response: The 45-day review period for title V permits is in place to determine the adequacy and completeness of the permit application , and is not the place for reviewing consistency between rules. However, a case-by-case MACT determination under section 112(g) is not required for emission sources that are regulated by or specifically exempted by a relevant MACT standard. Modifications at the affected sources outlined in this rule are not subject to 112(g) review.

Comment: One commenter (IV-D2-15) stated that 112(g) should have no applicability to any units that are either covered by standards promulgated in this rule , or that are the subject of a "no regulation" decision. The commenter (IV-D2-15) asserted that MACT III sources would fall in the second category. The commenter (IV-D2-15) believes a broader definition of source than that proposed would allow the flexibility to implement equipment retrofits and rebuilds , restructure production processes and install new technology to comply with the MACT standard without triggering section 112(g) review. The commenter (IV-D2-15) contended that a plant-wide definition of source for implementing 112(g) is both legally required and represents sound policy.

16-18Response: For the final regulation, EPA is defining the affected source to which existing MACT requirements apply to include the total of all HAP emission points in the pulping and bleaching system (including pulping condensates). The EPA agrees with the commenters that certain emission points that are excluded from the definition of affected source in the rule, or are subject to a determination that MACT for these operations is no control , should not be required to undergo Act section 112(g) review. The sources that have been so identified in are wood yard operations (including wood piles), tall oil recovery systems , pulping systems at mechanical, secondary fiber, and nonwood fiber pulping mills , and paper making systems. With regard to wood yard operations , tall oil recovery systems, and pulping systems at mechanical, secondary fiber, and non-wood fiber pulping mills , EPA has determined that these sources do not generally emit large quantities of HAP's and is not aware of any reasonable technologies for controlling HAP's from these sources. For paper making systems , EPA has not identified any reasonable control technology , other than the clean condensate alternative, that can reduce HAP emissions attributable to HAP's present in the pulp arriving from the pulping and bleaching systems. Additionally, EPA has determined that the use of paper making system additives and solvents result in negligible emissions of

HAP's. Therefore, based on the applicability requirements of section 112(g) (40 CFR 63 part B, 63.40(b)), wood yard operations ; pulping systems at mechanical, secondary fiber, and non-wood fiber mills ; and paper making systems would not be required to undergo section 112(g) review.

Comment: On e commenter (20,027) requested that, because the provisions of 112(j) may be misconstrued to apply to sulfite

16-19recovery furnaces independent of the December 17, 1993 proposed rule, EPA should make a definite statement as to the status of sulfite recovery furnaces. The commenter (20,027) expressed concern that recovery furnaces will not be covered by the proposed non-combustion or combustion MACT standards and therefore will be subject to 112(j). Response: The EPA intends to cover sulfite recovery furnaces under a separate NESHAP for combustion sources at pulp and paper mills. The NESHAP covering combustion sources at pulp and paper mills will be proposed concurrently with the promulgation of this rule. Since the pulp and paper source category has been listed for promulgation by November 15, 1997, the section 112(j) provisions will not apply unless the combustion NESHAP is not promulgated by May 15, 1999.

Comment: One commenter (20,059) indicated that because the proposed rule would increase the reliance on the substitution of chlorine by C102, EPA should use its section 112(r) authority to establish accident prevention standards or monitoring requirements to minimize the risks of accidental release. The commenter (20,059) stated that such standards could ensure that is manufactured on site in small quantities for use in closedloop systems. Response: Accident prevention regulations under 112(r) were promulgated in the Federal Register (61 FR 31668) on June 20,
1996. These regulations included a list of 77 compounds for which accident prevention and response programs are required. Facilities storing over 1,000 pounds of Cl02 are subject to the 112(r) requirement of an approved accident prevention and response plan. Section 112(r) does not give EPA authority to require facilities to generate Cl02 on site. However, EPA has

16-20concluded that facilities using Cl02 will install on site, Cl02 generators since on-site generation has proven to be the most cost-effective method of providing chlorine dioxide.
16. 4 NEW SOURCE PERFORMANCE STANDARDS AND CONTROL
GUIDELINES
Comment: One commenter (20,059) recommended TECHNOLOGY

that EPA update the NSPS to include tighter emission limits for all criteria pollutants and establish numeric , enforceable emission limits for existing sources of TRS under section 111(d)(1 )

. The commenter

(20,059) also requested that EPA develop a Control Technology Guidelin e (CTG) for the pulp and paper industry to establish more stringent presumptive norms for VOC RACT, as well as requiring States with nonattainment areas to incorporate these new requirements into their SIP. One commenter (20,133) contended that EPA failed to update the 1978 sulfur dioxide emission standards and TRS compound standards. Three commenters (20,049A3, 20,082, 20,132) stated that EPA should retain in the final rule the proposed regulations to control the amount of TRS air emissions. Response: The pulp and paper NESHAP were developed under the section 112 of the Act. NESHAP are only applicable to the compounds contained in the HAP list in section 112(b). The EPA did not promulgate any sulfur dioxide emission standards for pulp and paper mills. The EPA is not, at this time, revising the TRS rules previously developed under section 111. However, the pulping streams controlled under this NESHAP contain most of the TRS compounds emitted from pulping system, and the HAP control required by this rule will also significantly reduce TRS emissions. The EPA estimates a reduction in TRS of 78,500 Mg/yr as a result of this rule.

16-21The promulgated rule will achieve significant VOC emission reductions since the technologies used to control organic HAP's that are subject to this rule also control VOC. The EPA estimates a reduction in VOC emissions of 409,000 Mg/yr as a result of this rule. All significant sources of VOC and TRS from the pulping and bleaching systems have been captured by this rule. The MACT standard is a uniform , national requirement that applies to all new and existing pulp mills. The EPA sees no need for additional regulatory measures for TRS or VOC control for pulp mills because any additional emission reductions would not be significant given the reductions obtained under this rule.

Comment: On e commenter (20,011) requested that process wastewaters subject to emission control in the proposed rule should not be additionally subject to RACT. Response: The EPA's analysis indicates that all significant VOC-laden pulping process condensates at pulp and paper mills will be subject to the MACT standards. The technology used for meeting MACT is also the best technology for VOC control. Since all new and existing mills are subject to the rule, no additional VOC reductions would be achieved by RACT. However, the level of control for bleaching wastewater streams was no control and some bleaching wastewater streams may contain significant levels of

voc . Therefore, consideration of RACT may be appropriate for these streams.
Comment: With regard to EPA's solicitation for comments on the potential overlap of the kraft NSPS and the proposed NESHAP standards in the March 8 , 1996 supplemental notice, two commenters (IV-D2-7 , IV-D2-15) contended that compliance with MACT should be considered compliance with the NSPS for those

16-22sources subject to both rules and any source covered by both rules should not have any further monitoring, recordkeeping, or reporting obligations under the NSPS. Another commenter

(IV-D2-10) supported the concept of consolidating the NSPS and MACT programs , noting that it should not be necessary to report things twice and that redundant or overburdensome monitoring or recordkeeping should be eliminated in a "common sense" rule that would combine these requirements. One commenter (IV-D2-4) disagreed, noting that allowing a facility to choose compliance with the NESHAP in lieu of the NSPS for certain process equipment is inappropriate. The commenter (IV-D2-4) asserted that the emission units that require TRS monitors under the NSPS (recovery furnaces, lime kilns, and brownstock washer, evaporator , and condensate stripper systems that are not incinerated) are not the same as those regulated under this NESHAP. The commenter also urged caution as the NSPS and the NESHAP standards were written to regulate different types of pollutants. Response: Sources that are affected by this NESHAP and the kraft mill NSPS are the pulping system, brownstock washer, and the steam stripper treatment system. The EPA agrees that duplication between this NESHAP and the kraft mill NSPS should be minimized. If an owner or operator complies with the NESHAP requirements for these sources with one of the combustion control options, the requirements of the NSPS would also be met. For the reporting requirements of this NESHAP, documentation of compliance with the combustion control option used for control of vents from the pulping system, brownstock washer, and the steam stripper would also satisfy the NSPS. In this case, only one set of monitoring, recordkeeping , and reporting requirements would be

16-23required in the facility's title V permit to satisfy both the NESHAP and NSPS requirements. However, if emissions from these sources are controlled by a means other than combustion, such as the clean condensate alternative , a mill will have to prove compliance with both the NESHAP and the NSPS. In this case, a mill would have to report HAP reductions obtained by the noncombustion control option (to satisfy the NESHAP) and TRS concentrations at any affected source vent (to satisfy the NSPS).

Comment: On e commenter (IV-D2-15) contended that because so many facilities have installed thermal oxidizers to meet the standards in the NSPS , and because these controls were considered in the MACT floor level of control, the MACT rule should include all the operating parameters associated with NSPS controls, not just the equipment itself. Response: The MACT floor level of control is based on the average of best 12 percent of the population, with respect to HAP reduction. In the case of this NESHAP , the best-performing mills controlled pulping system vents by combustion in power boilers, lime kilns , and recovery furnaces, all of which achieve 98 percent HAP reduction. Therefore, the MACT floor level of control was 98 percent control of HAP's from pulping system

vents. The operational parameters for thermal oxidizers defined in the NSPS for control of TRS emissions may not produce the 98-percent HAP emission reduction required by this rule. For example, the thermal oxidizer operating conditions specified in the NSPS (1200 OF, 0.5 seconds residence time) are not sufficient to provide the 98 percent HAP reduction that is achievable in a boiler, lime kiln , or recovery furnace (A-92-40, IV-B-18). Analysis of HAP destruction in thermal oxidizers show that an operation level of 1600 OF and 0.75 seconds residence time is

16-24required to meet the 98 percent HAP reduction requirement. However, this rule allows three options for a facility to show compliance when a thermal oxidizer is used to control HAP's in pulping vent streams. To meet the thermal oxidizer requirements of this rule , a facility must show that the thermal oxidizer is operating at 1600 OF and 0.75 seconds residence time, achieving 98 percent HAP reduction , or has an outlet HAP concentration no greater than 20 ppmv at 10 percent oxygen. Any existing thermal oxidizer designed to comply with the minimum NSPS requirements may have to upgrade to meet the requirements of this rule. 16.5 GENERAL PROVISIONS
Comment: One commenter (IV-D2-15) asserted that EPA should incorporate corrections to the general provisions definitions in the final rule. The commenter stated that these changes include changes to definitions of affected source, malfunction, new

source, and reconstruction. The commenter (IV-D2-15) also recommended eliminating a drafting error in the general provisions fo r "part 70 permit" by defining part 70 permit to

mea n "a permit issued by a State permitting authority pursuant to a program approved by EPA under part 70 of this chapter." This definition would recognize that permits are not issued pursuant to part 70 , but are issued by States that have permit programs approved pursuant to part 70. The commenter (IV-D2-15) recommended including a definition of working day in this rule since the definition was unintentionally left out of the general provisions to part 63. The commenter (IV-D2-15) recommended that working day mea n "any day on which the Federal government offices are open for normal business. Saturdays, Sundays, and official federal holidays are not working days."

16-25Response: Concurrently with this rulemaking the Agency conducted a separate rulemaking effort to revise the general provisions to part 63. The definitions mentioned by the commenter relate to broad policy issues that affect all sources subject to NESHAP. There is no basis for revising these definitions as part of the pulp and paper NESHAP because an individual NESHAP is not the proper mechanism for changing the definitions in the general provisions. Any revisions to the general provisions should be accomplished in the ongoing litigation. When the revised general provisions are completed, any changes will be applied to all sources subject to section 112 provisions , including pulp and paper mills. 16.6 PROJECT XL
Comment: The proposed rule did not address Project XL. One commenter (IV-D2-14) suggested that EPA use the promulgation process for the rule as an opportunity to build a foundation for the implementation of a portion of Project XL. The commenter (IV-D2-14) recommended changes to the proposed rule that would provide the foundation for the implementation of Project XL for affected facilities. The revised language would allow mills, with approved Project XL Final Project Agreements (FPA), flexibility in meeting the NESHAP. The commenter (IV-D2-14) reasoned that the additional language would allow for the implementation of Project XL at affected sources but does not require EPA to agree to a Final Project Agreement in lieu of

MACT . Response: The EPA interprets the commenter's concern to bethat the draft FPA for Project XL was just a non-binding, nonregulatory agreement that provided the XL participant no protection from being subject to the applicable rules. The EPA

16-26has reached agreement with the XL participant and reflected this

agreement in the draft FPA issued for public comments on October 9, 1996. The draft FPA stated that EPA intends to implement the agreement through a site-specific rulemaking, permit revisions, or other appropriate legal mechanisms.

16-2717.0 SCHEDULE ISSUES

17. 1 RULEMAKING SCHEDULE
Comment: One commenter (20,071) indicated that EPA should delay the final MACT standards until all data are submitted and the impacts for RCRA and PSD/NSR are clarified. One commenter

(20,027) reasoned that EPA should have waited to receive the industry test data before proposing the MACT standards. The commenter (20,027) challenged that EPA is legally bound to issue a responsible notice of proposed rulemaking and cannot plead time pressures as a reason for issuing an irresponsible rule. [Case law cited: NRDC v. Thomas, 805 F.2d 410, 433-437 (D.C. Cir. 1986); State of New Jersey v. Costle, 26, F.2d 1038,1042 (D.C. Cir

. 1980). ] However, one commenter (20,102) cautioned that promulgation of the rule should not be delayed for additional testing and data gathering because it would result in a delay in reaching the proposed limitations and additional exposure of the public and the environment to toxic emissions. Two commenters (20,027 , 20,056) stated that EPA should extend the rulemaking time line so that the costs and impacts of the combustion MACT standards are considered with the impacts from the MACT standards for non-combustion sources. One commenter (20,018) stated that the accelerated rulemaking schedule did not allow for development and proper analysis of data to determine MACT regulations.

17-lResponse: The December 17 , 1993 proposed rule acknowledged that more data would be collected for use in revising the proposed rule. Additional data were collected and announcements of data availability were published in the February 22, 1995 and March 8, 1996 Federal Register supplemental notices. The March 8, 1996 Federal Register supplemental notice also presented

EPA'S analysis of new data, proposed rule changes, and a solicitation for responses on the revisions to the December 17, 1993 proposed rule. The Agency believes this consideration of comments and new data is sufficient. There is no need to delay the rulemaking process for further consideration of data. In the March 8 , 1996 Federal Register supplemental notice, EPA included proposed responses to concerns raised about the potential impacts of RCRA and PSD/NSR on compliance with the December 17 , 1993 proposed rule. The supplemental notice also presented a strategy for streamlining the process of granting a PCP exemption from PSD/NSR. 17.2 COMPLIANCE SCHEDULE
Comment: In the December 17, 1993 proposed rule, existing MACT sources were given 3 years from the date of promulgation to reach compliance. New sources (those constructing after December 17 , 1993) were required to be in compliance at the time of startup , or upon promulgation of the final pulp and paper
rule , whichever is later. Numerous commenters (20,001, 20,015, 20,018, 20,054A2, 20,057, 20,057A2, 20,07OAl, 20,071 , 20,074) on the proposed rule expressed concern that kraft pulping mills could not meet the 3-year compliance schedule. The commenters (20,001, 20,015, 20,018, 20,054A2, 20,057, 20,057A2, 20,07OAl, 20,071, 20,074) submitted data supporting their position.

17-2Response: Based on the data received regarding the
December 17 , 1993 proposal , EPA proposed (in the March 8, 1996 Federal Register supplemental notice) to extend the MACT compliance schedule for kraft brownstock washers and oxygen delignification units by an additional 5 years. As outlined in the March 8, 1996 Federal Register supplemental notice, many kraft mills are currently considering the addition of oxygen delignification to their pulping lines by the year 2000. The addition of oxygen delignification has been shown to have significant environmental benefit, reducing the need for chlorinated chemical application in the bleaching process. A reduction in chlorinated compound use in the bleaching processes results in reduced loadings of chlorinated pollutants to the air and into the bleach plant effluent. The EPA considers that the addition of oxygen delignification would likely require redesigned brownstock washers to improve washing efficiency before the pulp is sent to the oxygen delignification system. The new brownstock washer designs are more efficient, less polluting, and easier to control. However, implementation of the new brownstock washers and oxygen delignification systems would probably not occur within a 3-year compliance schedule due to the cost and the need to design and construct these systems. Given a 3-year compliance schedule, time constraints would dictate that mills retrofit their current washers with a vent gas collection system to achieve compliance. Once such a collection system is installed, mills would likely postpone or cancel installation of oxygen delignification systems. The EPA concluded that allowing an additional 5 years to the 3-year compliance schedule for kraft mills would allow sufficient time for a complete evaluation of

17-3all pollution control options and provide an overall greater

benefit in terms of both air and water pollution control.

Comment: With regard to the proposed extension presented in the March 8, 1996 supplemental notice, several commenters (IV-D2-11, IV-D2-5, IV-D2-19, IV-D2-10, IV-D2-3, IV-D2-4, IV-D2-2, IV-D2-15) supported the EPA's decision and rationale for extending the compliance period for brownstock washing and oxygen delignification vents for 5 years. One commenter (IV-D2-8) argued that the 5-year extension for control of brownstock washer and oxygen delignification vents should be applied to all kraft mills instead of only those mills that are installing oxygen delignification systems. The commenter (IV-D2-8) noted that the decision to install an oxygen delignification system is very difficult and mill-specific, and that the goal of improving emissions reduction through improved brownstock washing systems is equally applicable to mills that determine that oxygen delignification is not an appropriate option. One commenter (IV-D2-8) noted that for mills where condensates are recycled back to brownstock washers or oxygen delignification systems, a potential compliance issue exists because, while the vents have been given a 5-year extension, these mills will be meeting the wastewater standards for which compliance is required 3 years after final promulgation. This conflict will have several negative impacts: all mills would not be treated equally; inaction would deny relief that EPA clearly intended to give to the regulated community; and inaction would arbitrarily penalize many companies who already have adopted a sound environmental approach to control of polluted streams (recycle and reuse) in advance of Federal regulations. The

17-4commenter (IV-D2-8) suggested extending the compliance time for wastewater streams recycled to brownstock washing and oxygen delignification systems to coincide with the compliance time for vents from those units. Several commenters (IV-D2-11, IV-D2-3, IV-D2-7, IV-D2-15) requested that the 5-year extension also be applied to weak black liquor tanks , pre-washer knotter and screening systems, and other HVLC vent streams because emissions from these sources will be transported and controlled by the same HVLC collection and incineration system as the brownstock washers. These commenters (IV-D2-11, IV-D2-3, IV-D2-7 , IV-D2-15) noted that extension of the compliance period for all HVLC sources also allows for proper consideration of the full range of emerging innovative control options. Response: The Agency reviewed the commenters' concerns and agreed that vents included in the HVLC system should be allowed a similar compliance time as the brownstock washing and oxygen delignification systems. The majority of emissions and vent gas flow from equipment associated with the HVLC vent streams occur from the washing system and the oxygen delignification system. Therefore , the design of the HVLC collection and transport system would be significantly influenced by these two systems. If different compliance times were provided for the components of the HVLC system , an affected source would expend significant amounts of capital to control systems required to comply in the 3-year time frame. The source would have to redesign the gas transport and control devices 5 years later to accommodate controlling the washing system and oxygen delignification system. This cost could discourage the implementation of low flow washing and oxygen delignification systems. This would serve as an

17-5obvious disincentive to installation of advanced wastewater treatment technology since mills would be understandably reluctant to replace a newly installed air pollution control system. Therefore, EPA concluded that additional compliance time is appropriate and necessary for the remaining equipment controlled by the HVLC collection and transport system as well as the brownstock washing system and the oxygen delignification system (see 61 FR 9394-95, March 8, 1996). The final rule allows affected sources to control all the equipment in the HVLC system at the same time , 8 years after publication of the pulp and paper rule. The compliance extension applies to HVLC systems at all kraft mills. The additional design and mill modification to meet the standards is a lengthy process. The Agency wanted to allow sufficient time for each kraft mill to fully consider all pollution control options. The Agency also recognized that the pulp and paper industry will be implementing both water and air rules essentially at the same time. Given the engineering requirements , capital expenditures , permitting requirements, and the resources necessary to implement both the water and air standards, the Agency decided that all kraft mills would be given a 5-year compliance extension for HVLC systems. The final rule includes requirements for kraft mills to submit a non-binding control strategy report along with the initial notification. The purpose of the control strategy report is to provide the Agency and the permitting authority with a means for measuring a mill's progress towards compliance. The control strategy report contains information such as a description of the emission controls or process modifications selected for compliance with the control requirements and

17-6compliance schedule. The information in the control strategy report must be revised or updated every 2 years until the mill is in compliance with the standards of § 63.443. Compliance with the pulping process condensate standards in th e 3-year time frame should not pose a conflict with the extended compliance schedule allowed for HVLC systems at kraft mills. Many of the changes a mill will need to implement to comply with the pulping process condensate requirements can be considered before air pollution control systems are implemented, since the standards do not address recycling patterns, only the HAP content of the recycled condensates. Additionally, standards for pollution control from pulping process condensates apply to streams that are typically not recycled or reused in the pulping process (namely the HVLC streams from the digester, evaporator, and turpentine recovery systems) without prior treatment. The control strategy of recycling uncontrolled process condensates to controlled equipment is also an option. If a mill cannot meet the pulping process condensates requirements using this option, it can choose to treat condensate streams in a stream stripper or convey condensate to a biological treatment unit.

Comment: One commenter (20,057) stated that EPA has no basis for concluding that compliance with the December 17, 1993 proposed rule can be achieved within 3 years by all mills. However, another commenter (20,059) argued that compliance deadlines should be set as expeditiously as possible and that EPA should not authorize any categorical l-year extensions. Several commenters (20,015, 20,018, 20,057A2, 20,054A2, 20,07OAl, 20,071, 20,142 , 20,146) indicated that due to the extensive amount of changes needed and the shortage of available engineering firms , the time period of 3 years was not sufficient

17-7for mills to perform the engineering analyses, modifications, and permitting efforts needed to comply with the proposed rule. One commenter (20,146) stated that the proposed wastewater requirements would trigger PSD/NSR permitting requirements that would make the compliance schedule unrealistic. One commenter

(20,015) suggested an extension of compliance dates along with a phased compliance schedule allowing the air and water components compliance dates to be staggered. One commenter (20,001) suggested EPA extend the compliance deadlines for all existing sources by 2 to 5 years , along with proposing interim targets for partial compliance. Another commenter (20,074) strongly recommended that EPA extend the compliance deadline by 2 years. One commenter (20,027) recommended that EPA should allow more time for compliance , particularly in view of the accelerated schedule for promulgation of MACT for this industry. The commenter (20,027) declared that EPA could issue a rule that allowed more than 3 years for compliance and still require MACT compliance within the original time frame envisioned by the Agency (November 15, 1997). One commenter (20,071) stated that it would realistically take up to 6 years for all facilities to be in compliance. Two commenters (20,027, IV-D2-15) claimed that because of the far-reaching scope of the proposed rule; its integration with the future combustion rule; potential PSD/NSR delays; and limits on available capital, equipment, and expertise, EP A should grant a l-year industry-wide compliance extension to provide a more reasonable time frame in which mills will be able to achieve compliance with the proposed rule. One commenter (20,061) suggested a compliance extension of 5 years for mills making an enforceable commitment to TCF technology. Two commenters (20,102, 20,103) suggested that EPA

17-8offer a l-year compliance extension as an incentive to mills that voluntarily switch to TCF processes. Two commenters (20,102, 20,103) recommended that the extension not be granted to mills that are required by the effluent guidelines to use TCF processes

(paper-grade sulfite mills). On e commenter (20,094) recommended adjusting the compliance schedule for bleach plant chlorine compound emission control to be in accordance with any modified compliance schedules for TCF mills required by the effluent guidelines. Response: The EPA considers the 3-year compliance period ample time for most mills to achieve compliance. For HVLC systems at kraft mills , EPA has provided an additional 5 years beyond the 3-year compliance time for a total of 8 years from the date of promulgation. The EPA believes that this additional time will be sufficient for kraft mills to completely evaluate all pollution control options for HVLC systems and to install pollution controls and pollution prevention processes. With regard to the combustion MACT for pulp and paper mills, compliance will be staggered approximately 2 years following this rule. If a facility realizes that it may not achieve compliance by the specified date due to shortages of materials or services needed to install pollution controls , it may apply for a l-year compliance extension. The process for receiving a compliance extension is outlined in § 63.6(i) of the general provisions. The Agency reviews requests for compliance extensions on a caseby-case basis and an extension may be granted if the Agency deems the request acceptable. Regarding the additional compliance period for meeting the effluent limitation guidelines and standards, EPA's OW has

17-9included several incentive packages in the final rule for

bleaching systems at paper-grade mills which have elected to treat wastewater to levels surpassing BAT requirements. Incentive packages include adding oxygen delignification prior to bleaching, implementing technologies that result in additional reduction of process wastewater use, reducing chlorinated bleaching chemicals use, and various bleaching system modifications. As an incentive to make this election, EPA is not requiring participating mills to achieve compliance with the more stringent portions of the "Advanced Technology" BAT limitations for 6, 11, and 16 years (for Tiers I, II, and III, respectively) in order to afford these mills sufficient time to develop, finance, and install the Advanced Technologies. In light of this, the Agency is concerned that requiring bleached paper-grade kraft and soda mills to comply in 3 years with MACT standards based on process substitution of chlorine dioxide for elemental chlorine would discourage these mills from electing to participate in the Advanced Technology program. This is largely because a mill that implements process substitution before it installs oxygen or other extended delignification systems is likely to construct more chlorine dioxide generating capacity than it ultimately will need. A mill thus compelled to invest first in process substitution may be very reluctant to abandon a portion of that investment soon afterwards in order to participate in the voluntary incentives program. The EPA also believes that requiring compliance in 3 years with a chloroform MACT standard based on baseline BAT for bleached paper-grade kraft and soda mills would present similar disincentives to achieving greater effluent reductions. A mill in those circumstances will have made a substantially larger

17-10capital investment than it will need to control chloroform once its array of advanced water technologies is installed. Also, depending on the degree of process modifications the mill makes, the mill may need a much smaller scrubber for the non-chloroform chlorinated HAP's and, in some cases, a scrubber may not be needed at all to meet the MACT standards for chlorinated HAP concentration limit. Thus, a mill otherwise interested in participating in the Voluntary Advanced Technology Incentives Program will find itself diverting capital to environmental controls that it ultimately will not need, instead of employing that capital to make more advanced process modifications that will benefit both the water and the air. Under these unusual circumstances where imposition of MACT requirements could likely result in foregoing substantial crossmedia environmental benefits , EPA believes that a two-stage MACT compliance scheme is justified for existing sources at bleached paper-grade kraft and soda mills that enroll in the water Voluntary Advanced Technology Incentives Program (se e 6 1 FR 9394 for a similar argument relating to compliance with MACT for washers and oxygen delignification systems). The first stage is an interim MACT of no backsliding--which reflects the current level of air emissions control. The second stage requires compliance with revised MACT based on baseline BAT requirements for all parameters for bleached paper-grade kraft and soda mills. (The second stage in effect revises MACT to reflect the control technologies which will be available at this later date. See Act sectio n 11 2(d)(6). ) The no-backsliding provisions apply to the period from 60 days from publication in the Federal Register until compliance with the second-stage MACT standards is required 6 years from publication in the Federal Register. This two-step

17-11alternative is available only to bleached paper-grade kraft and soda mills actually making the binding decision to comply with Tier I, II , or III water limitations. The EPA believes that providing these mills an additional 3 years to comply with MACT (i.e. , baseline BAT requirements for all parameters) is an appropriate and logical outgrowth of the discussions set forth in the March 8, 1996 Federal Register supplemental notice (61 FR 9393) and the July 15, 1996 Federal Register supplemental effluent guidelines notice (61 FR 36835- 58). In the March 8 , 1996 Federal Register supplemental notice, EPA solicited comments on its preliminary findings that MACT for chloroform air emissions should be compliance with baseline BAT. Commenters agreed with this preliminary determination. In the July 15, 1996 Federal Register notice, EPA set forth its vision of more stringent BAT for mills that voluntarily enter the Advanced Technologies Incentives program. As part of that voluntary program under the water standards, EPA is promulgating a requirement that mills in Tiers II and III, at a minimum, meet all the limitations promulgated as baseline BAT no later than 6 years after publication in the Federal Register. Thus, more stringent air emission controls than stage one MACT will likewise be available at this time since compliance with these interim BAT limitations will result in compliance with MACT. For Tier II and Tier III mills , this means that the second stage MACT requirement is compliance with the baseline BAT limitations by 6 years from date of publication in the Federal Register. The same is the case for Tier I mills , even though under the water regulation Tier I mills will be required to achieve more stringent limitations at that time. The EPA is defining MACT to be the baseline BAT limitations even in this situation because

17-12compliance with the more stringent absorbable organic halides limitations and other requirements unique to Tier I are unnecessary to control chloroform emissions at these mills. The EPA further believes that most plants likely to elect to comply with a tier option already control air emissions of chlorinated HAP's (both chloroform and other chlorinated HAP's) through application of the MACT technologies (process substitution for chloroform and caustic scrubbing for the remaining chlorinated HAP's). Thus, there will be some control of the emissions from these bleaching operations during the time preceding compliance with the second stage of MACT. To ensure that there is no lessening of existing controls, EPA also is promulgating a no backsliding requirement as an interim MACT -- reflecting current control levels. During the extended compliance period , mills may not increase their application rates of chlorine or hypochlorite above the average rates determined for the 3-month period prior to 60 days after promulgation in the Federal Register. The EPA notes that an affected bleached paper-grade mill must comply with the MACT requirements no later than 3 years from publication in the Federal Register , even if the mill's existing CWA NPDES permit does not yet reflect the corresponding effluent limitation guidelines and standards because its existing terms have not expired or it has been administratively extended. Put another way , even if a mill's existing NPDES permit serves as a shield (until reissuance) against imposition of new limits based on new effluent limitations guidelines (see CWA section 402(k)), the MACT requirement for bleached paper-grade mills to control chloroform emissions through compliance with all parameter requirements in the effluent limitation guidelines and standards

17-13take effect to satisfy the requirements of the Act. Similarly, if a bleached paper-grade mill's NPDES permit is reissued sooner than the expiration of the 3-year compliance schedule authorized for the chloroform MACT requirements and calls for immediate compliance with the BAT limitations , that deadline would prevail. The same principles will apply when effluent limitations guidelines and MACT standards are promulgated for dissolvinggrade mills.
Comment: One commenter (20,027) stated that the benefits of
the December 17 , 1993 proposed rule (i.e., orderly, coordinated approach to air and water pollution control) will not be realized unless the compliance schedules established in the December 17, 1993 proposed rule apply uniformly to all pulp and paper sources. Response: The benefit of the December 17, 1993 proposed rule is that regulatory requirements and compliance dates would be known in advance. This advance knowledge provides a mill with the opportunity to plan and choose the appropriate method of compliance that satisfies all rules and at the lowest cost for each mill. Additionally , the proposed rule contains extended compliance schedules for specified pulping area systems and incentive programs for bleaching systems to provide increased flexibility for mills to develop and implement compliance strategies.

Comment: One commenter (20,083) recommended extending the compliance deadline by 3 years for sources subject to different definitions o f "new source" under the Act and CWA. The result is that, if a source begins construction after the December 17, 1993 proposed rule but before promulgation, the source is "new" under Act but not under CWA. Consequently, the source would have to begin planning for compliance with the air requirements before

17-14promulgation , yet the final rule might impose water requirements that would make those plans and expenditures worthless. One
commente r (20,057A2) expressed that the proposed rule should not be applicable to construction or reconstruction during the period prior to the final promulgation. Response: The EPA proposed a broad definition of "source" for the proposed rule in order to reduce or eliminate the number of sources which would be defined differently by the Act and CWA.

I f "source" is defined to include all pulping processes, all bleaching processes , and all associated wastewater streams at mills, there will be far fewer instances in which a source will be constructed or reconstructed between proposal and promulgation than if a "source " is defined to be an individual piece of process equipment. If source is defined broadly, a piece of equipment that is added will not constitute a "new source" in most situations , but instead will be considered a change to an existing source. Such changes would be required to comply with the existing source standards at some period of time after promulgation of the standards , when all requirements of the guidelines are known.

Comment: With regard to the March 8, 1996 Federal Register supplemental notice , two commenters (IV-D2-18, IV-D2-17) supported EPA's OW suggestion to specify the application of BAT as the compliance mechanism for bleaching wastewater in place of numerical emission limits. The commenters suggested, however, that under such an approach the compliance date for dissolving mills would need to be deferred , because the BAT for these mills will not be established by the time the December 17, 1993 proposed rule is promulgated. One commenter (IV-D2-17) noted that there is significant environmental benefit for withdrawing

17-15and reserving dissolving-grade MACT until the ongoing technology development for BAT is completed. Namely, if EPA were to set MACT for chloroform now, based on current process technology, the
MACT floor level of control would be no control with no reasonable add-on control technology. Response: The MACT floor level of control for all bleaching systems is 99 percent reduction of chlorinated HAP's using caustic scrubbing and process modifications (100 percent chlorine dioxide substitution and elimination of hypochlorite as a bleaching agent). The technology basis for BAT under the CWA are at least equivalent to the MACT requirements. Since BAT and MACT are essentially the same , EPA therefore proposed in the March 8, 1996 supplemental notice that chloroform emissions be controlled by complying with the BAT requirements. No adverse comments were received to this proposal. As stated in the July 15 , 1996 Federal Register notice (61 F R 36835), EPA is evaluating new data on the technical feasibility of reducing hypochlorite usage and implementing high levels of chlorine dioxide substitution on a range of dissolvinggrade pulp products. Therefore, EPA is deferring issuing effluent limitation guidelines and standards for dissolving-grade mills until the comments and data can be fully evaluated. The EPA expects to promulgate final effluent limitation guidelines and standards for dissolving-grade subcategories at a later date. The EPA has decided to delay establishing these MACT standards for chloroform and for other chlorinated HAP's for dissolving-grade bleaching operations until promulgation of effluent limitation guidelines and standards for those operations, for the following reasons. With respect to the MACT standard for chloroform, first , as explained above and in the

17-16March 8, 1996 Federal Register notice, the control technology basis for the effluent limitation guidelines and standards and the MACT requirements will be the same. Second, at present, the Agency is unsure what level of chlorine substitution and hypochlorite use is achievable for dissolving-grade mills. Thus, although EPA has a reasonably good idea what the technology basis of MACT and effluent limitation guidelines and standards is likely to be for dissolving-grade mills , the precise level of the standards remains to be determined. Consequently, at present, EPA is unable to establish what the MACT floor would be for chloroform emissions from bleaching systems at these mills, and there is no conceivable beyond-the-floor technology to consider. The EPA will make these determinations based on data being developed, and then promulgate for these mills effluent limitation guidelines and standards and, concurrently, MACT standards based on those effluent limitation guidelines and standards. Covered mills would therefore be required to comply with the MACT standards reflecting performance of the effluent limitation guidelines and standards no later than 3 years after the effective date of those standards, pursuant to section 112(i )(3) (A) of the Act. The basis for delaying MACT requirements for chlorinated

HAP's other than chloroform (again , from dissolving-grade bleach operations only) differs somewhat. As noted above, the technology basis for control of these HAP's is use of a caustic scrubber. However, when plants substitute chlorine dioxide for chlorine and eliminate hypochlorite (in order to control chloroform emissions and discharges to water, as explained above), a different scrubber will be needed that can adequately control both the chlorine dioxide emissions for worker safety

17-17reasons and the emissions of chlorinated, non-chloroform HAP's. The Agency's concern (shared by the commenters who addressed this question) is that immediate control of the non-chloroform chlorinated HAP's could easily result in plants having to install and then replace a caustic scrubber system in a few years due to promulgation of effluent limitation guidelines and standards and MACT requirements for chloroform. This result is an inappropriate utilization of scarce pollution control resources.

Comment: On e commenter (IV-D2-15) contended that if an alternative technology will produce the same or greater emission reductions than specified in the rule, EPA should work with the source to develop a reasonable compliance timetable. If after the technology is installed and operating normally, it does not achieve the reductions that were predicted, or if operation of the technology does not turn out to be practicable, the source should be required to revert back to the original control requirements. In that event , the source should negotiate a new compliance date with the Administrator. The source should be required to comply with the original requirements as soon as practicable under the circumstances, but in no event later than 8 years after the technology has been found to be inadequate or impracticable. Response: If an affected source wishes to establish an alternative means of emission reduction, the affected source can apply for and obtain approval for this alternate compliance method through the procedures outlined in § 63.6(g) of the general provisions. The EPA maintains that the 3-year compliance schedule outlined in the rule is reasonable and further adds that all kraft mills have a 5-year extension for compliance on HVLC systems. If an alternate compliance method does not reach the

17-18standards set in the rule , and if the affected source cannot reach compliance by the target date , the affected source may apply for a l-year extension of the compliance date under the procedures outlined in section 112(i) (3) of the Act.

17-1918.0 MECHANICAL PULPING MILL, SECONDARY FIBER PULPING MILL, NON-WOOD FIBER PULPING MILL, AND PAPERMAKING SYSTEM (MACT III) COMMENTS

Comment: Several commenters (IV-D2-1, IV-D2-4, IV-D2-5, IV-D2-7, IV-D2-8, IV-D2-9, IV-D2-10 , IV-D2-12) stated that they supported the March 8 , 1996 standards proposed by EPA for MACT III sources (i.e. , floor for pulping systems at these mills and papermaking systems at all mills is no control and for bleaching systems at these mills that use chlorine or chlorine dioxide, control is caustic scrubbing). Three commenters (IV-D2-1, IV-D2-5, IV-D2-8) agree with EPA's findings that the floor level of control for papermaking systems is no control. The same commenters (IV-D2-1, IV-D2-5, IV-D2-8) also supported further examination of HAP emissions attributable to the use of papermaking system additives in order to determine if these emissions are a major source of HAP. Three commenters (IV-D2-2, IV-D2-3, IV-D2-6) disagreed with EPA's findings that the floor level of control for MACT III sources (mechanical mills, secondary fiber mills, non-wood fiber mills, and papermaking systems) was no control. Due to the lack of available data , the commenters (IV-D2-2, IV-D2-3, IV-D2-6) stated that EPA should wait for the conclusion of the MACT III testing program sponsored by industry before promulgating a final rule. The commenters (IV-D2-2, IV-D2-3, IV-D2-6) stated that

18-1they believed there were not enough data to substantiate a finding of no control for MACT III sources. Response: The information gathered during the MACT development process indicates that there are no air pollution control devices in place at mechanical mills, secondary fiber mills, and non-wood fiber mills except at elemental chlorine and chlorine dioxide bleaching stages. This information also indicated that no air pollution control devices are currently in place on papermaking systems at any mill (A-95-31, II-B-l). Through site visits , working with stakeholders, and reviewing the results of the industry-sponsored MACT III testing program, EPA maintains that the floor level of control for these sources is no control except for elemental chlorine and chlorine dioxide bleaching stages. The EPA has also concluded that going beyond the floor level of control requiring controls for MACT III sources would be cost-prohibitive given the estimated reduction in HAP's (A-95-31, IV-B-5, IV-B-6, IV-B-7, IV-B-8). Therefore, EPA decided to move forward with the MACT standard for the MACT III sources and promulgate in conjunction with standards for

MACT I sources. The EPA believes this is a sound decision that will result in time and money savings for the Agency and stakeholders , and that no environmental benefit would be gained by delaying promulgation of the standards for MACT III sources.

Comment: On e commenter (IV-D2-10) requested that EPA give MACT III sources additional time in which to comply if the promulgated rule is more stringent than the proposed rule. Response: The proposed standard for MACT III mills was no control except for chlorine bleaching stages. For chlorine bleaching stages , EPA concluded that scrubbers were already used to control chlorine and HCl for process and worker safety

18-2reasons. The final standard does not contain any additional control requirements for MACT III mills than stated at proposal. Therefore , EPA maintains that the promulgated standard is no more stringent than the proposed standard and additional compliance time is not necessary.

Comment: Several commenters (IV-D2-2, IV-D2-3, IV-D2-6) requested that EPA provide information on the industry sampling and testing protocol and any data collected through the industry test program. Response: The information provided on the industry test program is available in the Pulp and Paper MACT III docket

(A-95-31, IV-J-3 through IV-J-13). The sampling and testing protocol provided by the industry are entries II-D-5 and II-D-11.

Comment: Two commenters (IV-D2-2, IV-D2-3) requested that EPA publish the final MACT III rule in a separate Federal Register notice. The commenters (IV-D2-2, IV-D2-3) stated that the inclusion of MACT III sources at the end of the MACT I sources has inadvertently limited public comment on the proposed rule because State and local organizations without MACT I sources would not look for a MACT III rule in the document in which the rule was proposed. Response: The EPA concluded that the most efficient way to address MACT III sources was to propose standards for this source group in combination with the announcement in the March 8, 1996 Federal Register supplemental notice. Both actions were stated at the beginning of the notice after the title "National Emission Standards for Hazardous Air Pollutants for Source Category: Pulp and Paper Production, " followed by a summary of the action describing what was addressed in the notice. A separate section for the MACT III mills, section X, "Standards for Mechanical

18-3Mills, Secondary Fiber Mills, Nonwood Fiber Mills, and Paper Machines, " was provided. Consequently, EPA maintains that adequate notice was given for comment response on the proposed MACT III rule. During subsequent work group meetings which included State and local representatives, notification was given that EPA intends to combine the MACT III promulgation with the final pulp and paper rule.

Comment: One commenter (IV-D2-9) questioned whether or not the MACT standards for these sources were warranted. The

commente r (IV-D2-9) further stated that due to the low emissions from their mill they believed that no MACT standards were

necessary. Response: All categories and subcategories of major sources that are listed pursuant to section 112(c) of the Act must be evaluated for possible NESHAP. Since MACT III sources are major sources of a listed source category , EPA is legally bound to determine MACT standards pursuant to section 112(d) of the Act.
Comment: Two commenters (IV-D2-8 , IV-D2-10) confirmed that MACT III sources that bleach with elemental chlorine are already using scrubbers for chlorine emission control. Both commenters

( IV -~2-8, IV-D2-10) indicated that regulatory controls for elemental chlorine bleaching systems in addition to scrubbers such as incineration , would not be appropriate. One commenter (IV-D2-10) interpreted the term "chlorine bleaching" to exclusively represent the use of elemental chlorine as a bleaching agent, an d "non-chlorine bleaching" to represent any bleaching agent other than elemental chlorine. One commenter

(IV-D2-8) agreed that bleach plants at MACT III sources that are collocated with MACT I sources will be subject to the MACT I controls if any equipment is common to both process lines.

18-4Response: For collocated and stand-alone MACT III mills that have elemental chlorine or chlorine dioxide bleaching stages, these stages shall reduce the total chlorinated HAP mass in the vent stream entering the control device (scrubber) by 99 percent or more by weight, achieve a treatment device (scrubber) outlet concentration of 10 ppmv or less of total chlorinated HAP (other than chloroform), achieve an outlet mass emissions limit of 0.001 kg of total chlorinated HAP (other than chloroform) per Mg ODP. Information available to EPA (A-95-31, IV-B-5) indicated that MACT III mills bleaching with elemental chlorine or chlorine dioxide already employ scrubbers. Information from industry (A-95-31 , IV-B-5) also indicated that the majority of MACT III mills that have bleaching systems use hypochlorite and are not controlled. Furthermore, available test data show that HAP emissions from hypochlorite bleaching stages are not large. Therefore, EPA has concluded that control requirements for hypochlorite bleaching stages at MACT III mills are not warranted. MACT III mills with hypochlorite bleaching stages are exempt from any bleaching control requirements. In addition, MACT III mills that use TCF bleaching are also exempt from any bleaching control requirements.
Comment: On e commenter (IV-D2-3) stated that they supported capture and combustion of LVHC gas streams and requested that EPA investigate the feasibility of controlling these streams. Response: Based on available information, EPA believes that LVHC streams do not exist at MACT III mills. Information available to EPA (A-95-31 , IV-B-7) indicate the HVLC streams at MACT III mills are not controlled and that HAP emissions from these sources are low. Therefore, EPA concluded that little

18-5environmental benefit would be gained by controlling the HVLC streams at MACT III mills.
Comment: One commenter (IV-D2-14) stated that the definition for non-wood pulping should include other sources of non-wood fiber and not just flax. The commenter (IV-D2-14) also recommended a detailed process description for non-wood pulping. Response: The EPA agrees with the recommendation to adjust the definition for non-wood pulping. The EPA has defined non-wood pulping as the production of pulp from fiber sources other than trees. The non-wood fiber sources include, but are not limited to, bagasse, cereal straw, cotton, flax straw, hemp, jute, kenaf, and leaf fibers. Since the promulgated standard for non-wood pulping is no control , EPA determined that a detailed process description was not needed.

18-619.0 MISCELLANEOUS COMMENTS

19.1 INFORMATION OMITTED FROM THE DOCKET
Comment: One commenter (20,027) indicated that information submitted to EPA by Mead regarding process equipment, economic impacts, and non-water quality environmental impacts associated with soda pulping was not included in the docket at the time of proposal. The commenter (20,072Al) included the Mead Corporation information in their comments on the proposed rule. In addition, information submitted by Weyerhauser Corporation and NCASI was omitted from the docket at the time of proposal. The American Forest Products Association (AF&PA) has resubmitted this information as appendices MACT 7, 8, and 9 (20,027A7, 20,027A8, 20,027A9). Response: All of the data and public comments regarding the proposed MACT standards and the final MACT standards that were not claimed confidential were submitted to the public docket maintained by EPA's OW. 19.2 ADDITIONS OR CORRECTIONS TO THE PROPOSED RULE
Comment: One commenter (20,056) indicated the following corrections to the December 17, 1993 proposed rule: (1) the units of the de minimis level for the bleaching system should be standard cubic meters per minute (not standard cubic feet); (2) § 63.444(a) (5) referred to item (1) (iii) which does not exist; (3) in § 63.444(f) (1), th e "or" should be substituted for

19-l"and" in the following excerpt: "... knowledge of the process, and mass balance information... " so that process and mass balance information may be used. Response: Valid editorial mistakes identified by commenters
have been corrected.
Comment: One commenter (20,102) stated that procurement guidelines should be established to encourage the reduction of both HAP generation at the production facility and the quantity of solid waste produced after use of the paper product. Response: The EPA does not have the authority under the Act to establish procurement guidelines. 19.3 OTHER COMMENTS
Comment: One commenter (20,091) stated that verification of compliance by the regulatory agencies responsible for pollution control is essential for public confidence and environmental protection. The commenter (20,091) argued that this area of the system needed improvement and suggested more frequent unannounced inspections (with sampling and testing) should be conducted by State and Federal agencies. Response: All facilities will have to perform tests for compliance or acceptably document emission control. Notification is required prior to performance tests so that the tests can be attended by a State or Federal representative. Test results must be submitted to the regulatory agency to demonstrate compliance. Facilities will have to monitor operational parameters, established through performance testing , on an ongoing basis to prove compliance. Facilities must submit semi-annual reports of compliance status , and report any infractions. The EPA believes that the monitoring, recordkeeping , and reporting requirements of this rule provide acceptable assurance of compliance.

19-2Comment: One commenter (20,089) stressed that EPA failed to provide adequate public notice and opportunity for public comment on its general MACT determination for most segments of the regulated community. The commenter (20,089) stated that most of

EP A requests for general comments on the MACT floor have been contained in industry-specific rulemakings which do not affect large portions of the regulated community. The commenter (20,089) indicated that the notice of the rulemaking will likely reach only limited industry segments since EPA addresses general comments on the MACT floor determination within rulemakings for specific MACT categories. Response: The EPA requested comments on a discussion of the statutory interpretation and determination of the MACT floor for HON and other sources on March 9, 1994 (59 FR 11018). Comments were received from industries, trade associations, environmental

groups, State and local agencies, and labor unions. On June 6, 1994 (59 FR 29196), EPA published a discussion of the statutory interpretation and determination of the MACT floor. While this notice established general interpretation, it also stressed that EPA has certain areas of discretion within the statutory framework to determine how best to set the MACT floor for each source category considering the data available for each category. The notice also envisioned that as additional MACT standards are developed, they may raise new issues pertaining to the MACT floor

(although no such issues are present in this rule, and the Agency accordingly applied the interpretation out in the June 6 notice). As stated in the June 6, 1994 notice , to properly consider the specifics of each source category , EPA will solicit and fully consider comments on individual MACT standards, including comments on interpretation of section 112 regarding MACT floor

19-3determination. All section 112 standards are proposed in the Federal Register and anyone is free to submit comments on any proposed rule. A revision of EPA procedures for requesting public comment on MACT floor determinations is not planned.

Comment: One commenter (20,085) expressed an interest in establishing health monitoring or health surveillance programs to determine the effectiveness of pollution control programs. Response: This activity is not covered under the scope of this NESHAP. The purpose of the testing and monitoring requirements of the NESHAP must be to ensure compliance with the emissio n limit s in the rule. The EPA has no authorization under sectio n 11 2 to monitor public health because health data are not needed to determine compliance with the MACT standards.

Comment: One commenter (20,078) suggested that EPA conduct a pilot level regulatory/permitting process using the proposed rule to identify whether or not the chosen limits can be implemented. Response: Th e limit s specified in this rule have been set from actual emission levels obtained at the best performing (12 percent) mills in the nation. MACT standards are set in this manner to insure that the specified limit s can be actually met in practice.

19-420.0 ENVIRONMENTAL AND COST IMPACTS

20.1 INTRODUCTION This section summarizes the environmental and cost impacts of the final rule. This section also discusses the major revisions to the environmental impacts and associated analyses at proposal. A complete description of the methodology for estimating impacts was presented in the 1993 BID (A-92-40, II-A-35). The 1993 BID, along with this section, documents EPA's conclusions concerning demonstrated control technologies, HAP emissions, control costs , and other impacts upon which the final rule is based. The final rule covers chemical and semi-chemical wood pulping and bleaching processes and papermaking systems at the following types of mills:

. chemical and semi-chemical wood pulp mills;

. integrate d mills (mills that combine on-site production of both pulp and paper);

. mechanical wood pulping mills;

. secondary fiber deinking and non-deinking mills; and

. non-wood pulping mills.

20-lSuc h mill s typically fall under standard industrial classification (SIC) codes 2611 and 2621 for pulp and integrated mills, respectively. The only processes regulated at non-chemical mills (mechanical wood pulpin g mills, secondary fiber deinking and nondeinkin g mills , and non-wood mills ) are chlorine and chlorine dioxide stages in bleaching operations (see section 16.0). As a result, mos t of the analyses in this chapter center on chemical and semi-chemical pulping and bleaching processes because these are the processes that are most affected by the final rule and because the pulping and bleaching processes occur at the same mill. Unless otherwise specified , references to pulp mills or pulping or bleaching processes should be interpreted to mean only wood pulping and bleaching processes at chemical and semichemical pulp mills and integrated mills. The only regulated process condensates are from the kraft pulping process. This section presents an overview of the revisions made to the impacts analyses performed at proposal. Where the full rationale for specific revisions can be briefly presented, this chapter presents the relevant information. Fo r som e of the more complex technical issues , this section summarizes the technical approach, explains the assumptions, presents the results, and refers the reader to the documents contained in the public docket for the detailed technical analyses. 20.1.1 Section Organization Section 20.2 characterizes the pulp and paper industry and includes process descriptions , the emissions estimation approach and estimated baseline emissions. Section 20.3 discusses applicable control technologies. Section 20.4 presents the

20-2technical approach for estimating the impacts of the final rule. Section 20.5 relates the approach taken to estimate control costs and section 20.6 documents the development of the data base used to estimate national environmental and cost impacts for the pulp and paper industry. Section 20.7 summarizes the cost and environmental impacts of all MACT standards on the pulp and paper industry, before and after the effluent guidelines limitations have been implemented. 20.2 PROCESS DESCRIPTIONS AND EMISSIONS ESTIMATES This section characterizes mill processes and baseline emissions. Section 20.2.1 describes the nationwide distribution of pulp and paper mills in the U.S, section 20.2.2 describes changes to the emissions estimation approach used since proposal, and section 20.2.3 presents the baseline emissions estimates and control technology assumptions. 20.2.1 Industry Characterization The pulp and paper industry includes facilities that manufacture pulp, paper , or other products from pulp. Converting operations , such as the production of paperboard products

(e.g., containers and boxes) and coating or laminating, are not included in this assessment. There are approximately 566 operating pulp and paper mills in the United States. This estimate was determined from responses to a 1990 EPA OW survey. (The responses to the survey are considered Confidential Business Information.) This number reflects both chemical and non-chemical mills. Many of these pulp and paper mills operate more than one type of pulping

process ; for example , a mill may produce pulp using a chemical process (e.g. , kraft or sulfite) and a mechanical or semi20-3chemical process. Industry correspondence and literature

sources, reflecting closures and changes that have occurred since the initial survey , were used to adjust the total number of chemical and semi-chemical mills. As of fall 1996, there were 156 total mills operating some combination of kraft, semichemical, sulfite , or soda pulping processes. Table 20-l shows the distribution of the 156 mills in each State by type of chemical or semi-chemical pulping process used. The States with the highest concentration of chemical pulp mills are Washington, Alabama and Georgia. Of the 156 mills , 112 are kraft mills, 16 are semi-chemical mills, 2 are soda mills, 15 are sulfite mills, 10 are co-located kraft and semi-chemical mills, and 1 is a colocated kraft and sulfite mill. Other sources of information used to characterize mills at proposal included the 1992 voluntary NCASI survey, site visits, and literature sources (such as the Lockwood Post's Directory). After proposal , EPA received comments and new information from the industry (the March 8 , 1996 Federal Register notice presents a listing of the new data). As stated above, the OW survey has been continuously updated (with information on mill names, closures, production capacities, bleaching sequences, and number of process systems) as has the Lockwood Post's Directory (with information on mill names, pulping processes, and production capacities). The latest updates for the OW survey and Lockwood Post Directory (A-92-40 , IV-J-87) occurred in 1996.
20.2.2 Syste m Approach to Emissions Estimation
20.2.2.1 System Approach Issues. At proposal, EPA developed emission factors for each type of individual emission point typically found at pulp and paper mills. To estimate

20-4TABLE 20-l. DISTRIBUTION OF CHEMICAL AND SEMI-CHEMICAL PULP PROCESSES IN THE UNITED STATES a

State Kraft Semi-chemical Soda Sulfite Alabama Alaska Arizona Arkansas California Florida Georgia Idaho Indiana Iowa Kentucky Louisiana Maine Maryland Michigan Minnesota Mississippi Montana New Hampshire New York North Carolina Ohio Oklahoma Oregon Pennsylvania South Carolina Tennessee Texas Virginia Washington Wisconsin 14 2 1 1 7 2 7 1 12 2 1

2 10 7 1 1 3 3 2 6 1 1 1 1 2 5 1 2 1 7 2 3 6 1 2 1 6 4 2 6 3 4 4 1 5 Total 123 26 2 15

a In this table , mills with more than one pulp process are counted once for

each pulp process (e.g. , a mill with kraft and semi-chemical processes is listed in both kraft and semi-chemical columns). Of the 156 total mills, 112 are kraft mills , 16 are semi-chemical mills, 2 are soda mills, 15 are sulfite mills, 10 are co-located kraft and semi-chemical mills, and 1 is a co-located kraft and sulfit e mill

. Note that the sulfite mill in Alaska is closing.

Source: 1990 EPA OW Survey , adjusted as of Fall 1996

20- 5emissions, emission points (e.g., the digester, knotter, and washer) were grouped based on operating parameters believed to affect emissions. Their emission factors were averaged, and then assigned to a pulping line model process unit. After receiving additional test data following proposal , EPA adopted an emissions estimation approach based on mill systems. A mill system is a collection of equipment and ancillary tanks and piping that performs a discrete operation (e.g

. the pulp washing system consists of pulp washer, filtrate tank, and foam tank). Test data from systems where the complete system was evaluated

(i.e., all the emission points in the system were tested) were analyzed on a system basis rather than on an emission point basis, and emission factors for each system were developed. Emissions were then estimated for each mill based on which systems were present , according to survey results. The EPA has concluded, after assessing the additional test data and industry concerns regarding the emission point approach, that the mill system approach is a better tool for analyzing the data and yields results that more accurately reflect the actual emissions from the industry. Details of industry comment and EPA response on this issue are contained in chapter 2.0, Industry Characterization. Details of the system approach to estimating mill emissions , including estimated emission factors for each mill system , are contained in the revised Chemical Pulping Emission Factor Development Document (A-92-40, IV-A-8). A summary of the rationale for using the mill system approach is contained in the March 8 , 1996 Federal Register supplemental notice.

20-620.2.2.2 Pulping Processes. The proposal BID describes the pulping process and provides a general overview of pulping technologies and the types of equipment common to the industry. As a basis for the creation and selection of model process units, the document also notes which operating parameters influenced air emissions. Several assumptions and conclusions have been revised based on public comment and data submitted since proposal. Specifically , EPA has modified the following assumptions and conclusions since the proposal BID:

. At proposal , two model emission points had been assigned to digester blow gases on the assumption that digester blow gas emissions differ between batch and continuous digesters. (Specifically , batch digesters release gases in surges when the digester blows its entire load into a blow tank; continuous digester emissions are released at a constant rate.) Digester blow gases are now included in the "digester system and evaporators " mill system for both types of digestion because EPA's analysis of the data did not show a significant difference in the quantity of emissions as a function of digester type.

. The proposal BID suggested that brownstock washer emissions are a function of pulp production, type of digestion (batch or continuous), type of wood pulp

(softwood or hardwood) , and point of shower water application. New data, however, do not support establishing different emission factors for washer emissions on any basis other than washer type and HAP concentration in the shower water. The EPA's final analysis includes emission factors for low-flow washer systems (e.g. , belt presses and diffusion washers) and high-flow washer systems (i.e., rotary vacuum drum washers). Based on the data , rotary vacuum drum washer systems are differentiated by the HAP concentration in the shower water.

. The proposal BID noted a relationship between wood type and emission rates for semi-chemical pulping processes.

20-7The final analysis does not differentiate mill systems by wood type as the data do not support a significant difference in emission rates based on wood type for semi-chemical pulping processes.

20.2.2.3 Bleaching Processes. At proposal , EPA developed emission factors for each bleaching stage in the bleaching

process. Each bleaching sequence (i.e., series of bleaching stages) was assigned emission factors based on the type of stages present. Since proposal , EPA concluded that emissions from bleaching processes are more a function of mill operating parameters and equipment rather than bleaching sequence. The EPA statistically analyzed all the emission data from bleaching processes and the associated mill parameters (presence of oxygen delignification, bleaching sequence , degree of chlorine dioxide substitution, use of hypochlorite, wood type , inlet methanol concentration in the bleaching process shower water , and air flow rate of bleach plant vents). The results of the statistical analyses indicated that only the presence of a hypochlorite stage in the bleaching sequence and the degree of chlorine dioxide substitution significantly affect the level of chlorinated HAP emissions. The EPA was unable to detect a significant difference in emissions as a result of bleach sequence (apart from the presence of a hypochlorite stage or any of the other parameters). The EPA developed three emission factors to represent total bleach plant air emissions: one for bleach plants with a hypochlorite stage, one for bleach plants without a hypochlorite stage and with a low degree of chlorine dioxide substitution (60 percent or less), and one for bleach plants without a hypochlorite stage and with a high degree of chlorine dioxide substitution (greater than

20-860 percent). Details of the analysis of bleach plant air emissions are contained in the revised Chemical Pulping Emission Factor Development Document (A-92-40, IV-A-8). The emission factors were assigned to each bleaching process based on which case fit each bleach sequence at a mill.
20.2.3 Baseline Emissions Baseline emissions are the uncontrolled emission estimates adjusted for the effects of current State and Federal regulations , as well as additional controls known to be currently in place based on the MACT survey. The revised estimation of the baseline level of control for kraft, semi-chemical, soda and sulfite pulping processes and for bleaching processes is documented in detail in a memorandum contained in the public docket (A-92-40, IV-B-16). The memorandum also presents the percent of systems that are controlled at each type of mill. Two of the most significant revisions to the baseline level of control since proposal that affect the baseline emissions are the following:

. Control of all kraft LVHC vents (digester, evaporator and turpentine recovery system vents and steam stripper overheads) is now considered to be included in the baseline level of control.

. Control of only chlorinated HAP through caustic scrubbers at all bleach plants (and no control of non-chlorinated HAP) is now considered to be included in the baseline level of control. Additionally, OW is promulgating BAT controls that would affect pulping and bleaching processes. Under one OW control option (Option A) , the BAT controls would require 100 percent substitution of chlorine with chlorine dioxide and elimination of hypochlorite as a bleaching agent at all paper-grade bleaching

20-9processes. Option A would also require mills to replace vibratory screens with lower-emitting pressure screens and add a low- air flow washing stage to the washing system. These changes decrease the emissions from the pulping area. A second OW option

(Optio n B) would require bleached paper-grade kraft mills to apply oxygen delignification in addition to the requirements of Option A. The addition of an oxygen delignification system will increase the concentration of methanol in process water recycled to the decker system. Baseline emissions are increased because of additional oxygen delignification units and higher emissions from the decker system using dirtier (i.e., higher HAP concentration) process water from oxygen delignification filtrates. The BAT requirements have not yet been established for dissolving-grade bleaching processes. At proposal , data available to estimate HAP emissions from pulping and bleaching processes were limited. These data included a field test program of air and liquid samples from four kraft and one sulfite mills (referred to as EPA 5-mill study)

(A-92-40, II-A-17 a through d) and some limited industry data (see the proposal BID). In their comments to the proposed rule, industry representatives maintained that these data were insufficient to accurately characterize emissions. Following proposal, industry commenters supplied EPA with additional test data from kraft, sulfite, semi-chemical, and soda mills. The EPA evaluated and incorporated the data into its analyses. The revised emission factors for mill systems are contained in the revised Chemical Pulping Emission Factor Development Document (A92-40, IV-A-8).

20-10Uncontrolled emissions from pulping vent streams are calculated by multiplying the lb/ODTP for each pollutant in each equipment system (e.g., pulp washing system), the pulp capacity

(ODTP/day) for each equipment system at each mill, and the hours of operation per year. Baseline emissions from pulping vent streams are calculated by applying the emission reduction efficiency of existing control devices (e.g., 98 percent reduction for combustion devices) associated with each equipment system to the uncontrolled emissions from each system. Baseline emissions of chlorinated HAP from bleaching vent streams are calculated by applying the emission factors specific to the process conditions at each bleaching process (i.e., Cl02 substitution level and hypochlorite use). Baseline emissions of non-chlorinated HAP do not change because of process conditions. Emissions are calculated by multiplying the non-chlorinated HAP emission factors , the pulping capacity of the mill, and the operating hours. Uncontrolled emissions from pulping process condensates are calculated by multiplying the mass of each pollutant in the condensate by the fraction emitted (Fe) values developed from wastewater treatment models. The models are discussed in the revised Chemical Pulping Emission Factor Development Document

(A-92-40, IV-A-8). Baseline emissions from pulping process condensates are calculated by applying the reduction efficiency of existing control devices (e.g. , steam stripping combined with overhead vent combustion) associated with the condensate streams. Table 20-2 presents uncontrolled and baseline emissions for an example mill. Table 20-3 summarizes estimated national baseline emissions from the pulp and paper industry (before and

20-11afte r OW's BAT options are applied), and includes estimates for total HAP , total VOC, TRS , and the 25 highest emitted compounds. As shown in the table , methanol is the largest constituent contributing to total HAP emissions. The analysis does not include air emissions from mechanical wood pulping mills , secondary fiber deinking and non-deinking mills, non-wood pulping mills, paper machines, or chemical recovery at chemical and semi-chemical mills. Air emissions of HAP's from mechanical wood pulping mills, secondary fiber deinking and non-deinking mills , non-wood pulping mills and paper machines are discussed in the September 29, 1995 presumptive MACT report for non-chemical and other pulp and paper (MACT III) mills

(A-95-31, II-B-l). 20.3 EMISSION CONTROL TECHNIQUES This section discusses the assumptions made regarding control techniques applied to reduce HAP emissions from pulping, bleaching, and pulping process condensates. The MACT emission control technologies have design criteria and operating parameters (e.g. , combustion control device temperature and residence time) that were determined for proposal. Based on comments and subsequent evaluation , the Agency revised some of the assumptions previously presented. Section 20.3.1 discusses vent controls and section 20.3.2 discusses pulping process condensate controls. Section 20.3.1 also presents the theory and assumptions behind the clean condensate alternative, an alternative emission control strategy that was not described in the proposal BID.

20-12TABLE 20-2. EMISSIONS FROM AFFECTED SOURCES FOR AN EXAMPLE MILL (1,00 0 tons of oven-dried pulp per day kraft mill)

Affected Sourcesa Low Recycle "Open " High Recycle "Closed" Mill (Mg/yr)b Mill (Mg/yr)b Existinq controls HAPC HAPC Digester and evaporator d
Knotters Screens Pulp washing Rotary vacuum drum washers

LO W air flow washers Deckers Oxygen delignification Weak black liquor storage Pulping wastewater Tota l

- pulping area Bleaching system e,f Bleaching wastewater Tota l

- bleaching area 99.9% (combustion) 2.2 2.2 None 2.6 0.48 None 73 1.3

None 81 280 None 20 20 None 20 31 None 66 225 None 12 12 Biotreatment 115 115

Scrubber 390 690 65 46 None 64 24 130 70 Mill total 520 760

a Systems listed are assumed to exist at the example mill. b Emission factors taken from Chemical Pulping Emission Factor Development Document (A-92-40, IV-A-E).

Emissions (Mg/yr) = emission factor (lb/ODTP) * capacity (1000 ton/day) * (350 day/yr) * (1 Mg/l.l ton) * (1 ton/2000 lb). C Total HAP is calculated by summing emissions from all HAP species. d Combustion control efficiency of 99.9 percent assumed in the emissions presented. e No uncontrolled emission factor available. All data is post scrubber. Emissions reflect the presence

of a scrubber. f Assumed no hypochlorite stage and no chlorine dioxide substitution for the open mill. Assumed

100 percent substitution for the closed mill.

20-1320.3.1 Applicable Control Techniques for Vents This section discusses the applicable control technologies for pulping and bleaching process vents. The control technologies can be categorized into two types of control, add-on control devices applied to an emission point or condensate stream
to reduce HAP , and process modifications or substitutions that affect the formation or generation of HAP compounds. Vent control devices typically found in the industry include combustion control devices (i.e., lime kilns, power boilers, recovery furnaces, thermal oxidizers, and flares), scrubbers, and condensers. Pulping process modifications include extended cooking, oxygen delignification , use of pressure screens, and improved pulp washing. Bleaching process modifications include chlorine dioxide substitution , elimination of hypochlorite, using oxygen or peroxide in extraction stages , split chlorine addition and ozonation. All of these technologies are described in the proposal BID (and are not discussed in this document), but the approach for estimating the effect of process modifications and the removal efficiencies of scrubbing have been updated based on the Agency's evaluation of public comments and additional data. These changes are discussed below. 20.3.1.1 Process Modifications. Process modifications affect the generation of HAP compounds, and therefore, the amount of HAP's that can be emitted. Process modifications are accounted for through assigning different emission factors to a facility; one emission factor represents conditions before the process modification and another emission factor represents conditions following the modification (i.e., before and after using pressure screens , improved washers, 100 percent Cl02 substitution , elimination of hypochlorite). The environmental impact of the process modifications is estimated as the

20-15difference in emissions obtained from applying the two emission factors. The emission factors used at proposal were based on a collection of emission points for individual pieces of equipment. In the mill system analysis for the final rule, process modifications are still taken into account through separate emission factors, but the impact of process modifications is estimated on a mill system basis rather than on an equipmentspecific basis. The development of mill system emission factors that vary based on process modifications is detailed in the revised Chemical Pulping Emission Factor Development Document

(A-92-40, IV-A-8). 20.3.1.2 Removal Efficiencies for Gas Scrubber. Commenters stated that the non-chlorinated HAP removal efficiency for bleach plant vent scrubbers was overstated , especially for methanol. The commenters stated that the scrubbers in the bleach plant were designed and operated only for removal of chlorinated compounds, primarily chlorine and chlorine dioxide. Industry testing of air vent scrubbers at bleach plants (A-92-40, II-I-24), supported 99 percent removal of chlorinated HAP (measured as chlorine) and no reduction of non-chlorinated compounds. The EPA agreed with the commenters that bleaching systems achieve at least 99 percent control of chlorinated HAP's, but do not reduce non-chlorinated
HAP's. Detailed responses to comments on this topic are presented in chapters 4.0 and 6.0 of this document. The final impacts analysis reflects this updated information. 20.3.1.3 Clean Condensate Alternative. This section briefly describes the conceptual basis for the CCA, a pollution prevention option allowed in the final rule for compliance with the kraft mill air standards for HVLC system vents specified in 63.443. The CCA compliance option was not included in the proposal.

20-16The concept behind the CCA is that a portion of the HAP emissions from a process unit that receives recycled or reused process water is attributable to the HAP concentration in that
water. By reducing the HAP concentration in water that is used in open or vented process equipment, less HAP will be available to be volatilized to the atmosphere. Th e EPA's evaluation of emissions from pulp washing systems supports this concept since the emission factor for pulp washing systems that received process water with a relatively high HAP concentration was greater than the emission factor developed for pulp washing systems that used low HAP concentration process water (A-92-40, item IV-A-8). The industry submitted a CCA preliminary engineering study
to EPA (A-92-40, item s IV-Dl-5 9 and 92). The control technique presented in the study is based on biological treatment. Although no mills currently have this technology in place, the industry speculates that the CCA is capable of reducing the HAP concentration in process waters down to the 100 ppmw range. Industry asserts that the CCA can achieve HAP reductions equal to or greater than would have been achieved by implementing the MACT add-on controls on the HVLC system vents. The emission reductions would come from process equipment in the HVLC system

(e.g., pulp washing system) as well as other process areas that are not addressed by the MACT standard (e.g., causticizing system). 20.3. 2 Applicable Control Technologies for Pulping Process Condensates This section addresses the technical changes to the applicable control technologies for pulping process condensate emission points. The use of steam stripping systems and biological treatment systems (combined with hard-piping) are the two pulping process condensate control technologies used by the pulp and paper industry. In addition , volume reduction options

20-17for condensate streams to be controlled have been added to the analysis since proposal. 20.3.2.1 Stea m Stripping Systems. The HAP removal efficiency has been revised to reflect the comments and operating data received following proposal (A-92-40, IV-B-l0). Based on analyses of the comments and performance data, the removal efficiency for total HAP and methanol has been increased from 90 to 92 percent. The EPA has also determined that the hydrophilic properties of methanol relative to the other HAP compounds indicate that a 92 percent removal of methanol constitutes at least 92 percent removal of total HAP. Mass removal and steam stripper system outlet concentration options were determined based on the same set of performance data used to develop the 92 percent removal of total HAP (methanol). Therefore, the following control options are found to be equivalent to the 92 percent removal achieved by steam stripping: for bleached pulp mills , pulping process condensates treated to remove 4.6 kilograms or more of total HAP per megagram of ODP or achieving a total HAP outlet concentration of 330 ppmw from the steam stripper system ; and for unbleached pulp mills, pulping process condensates treated to remove 2.9 kg/Mg ODP or more or achieving a total HAP outlet concentration of 210 ppmw from the steam stripper system. 20.3.2.2 Biological Treatment Systems. In the proposed rule, a biological treatment system that achieved 90 percent reduction in total HAP was specified as one of the control options for pulping process condensates. A closed-collection system had to be used to convey the pulping process condensates to the biological treatment system (i.e., hard-piping). In the final rule, biological treatment systems are retained as a compliance option. However, the total HAP destruction efficiency has been increased from 90 percent to 92 percent to reflect the revisions made to the steam stripper system

20-18performance requirements. Additionally , the closed-collection system requirements for tanks, containers, surface impoundments, and drain system in the proposed rule were revised. In the final rule, the individual drain systems must meet the requirements specified in referenced §§ 63.960, 63.961, 63.962, and 63.964 of subpart RR of part 63. 20.3.2.3 Condensate Segregation. The final rule contains provisions for allowing mills the option of minimizing the volume of digester , turpentine recovery , and evaporator system condensates sent to treatment in the steam stripping or biological treatment systems. Condensate segregation is typically achieved using multistage condensation techniques on the vent stream gases or vapors. Industry commented that mills would perform condensate segregation in order to generate a low volume, high HAP concentration stream that would be sent to treatment and a high volume , low HAP concentration stream that could be sent to the mill's hot water tank for distribution to other process areas (e.g., pulp washing system). This practice will reduce the energy cost associated with steam stripping (more concentrated, lower volume stream sent to treatment) and reduce the demand for fresh water in the mill process. Based on industry data received since proposal, the mills that use this practice can achieve a 65/35 percent mass split

(A-92-40, item IV-B-24). This means that 65 percent of the total HAP mass is contained in the LVHC stream. In addition to achieving the percent mass split, the final rule contains an option for achieving the segregation option requirements based on sending a minimum HAP mass to treatment from the segregated digester, turpentine recovery , and evaporator system condensates and the LVHC and HVLC collection system condensates. 20.4 CONTROL OPTIONS AND ENVIRONMENTAL IMPACTS Section 20.4.1 presents the control options that were analyzed to estimate national impacts of the final rule.

20-19Sectio n 20.4.2 discusses emissions reductions and secondary environmental impacts. 20.4.1 Contro l Options This section presents the options analyzed to estimate the national impacts of the final rule. The rationale for choosing the MACT floor or going beyond the floor is discussed in the preambles to the proposed and final rules, and in chapter 4.0 of this document. The final rule specifies a MACT technology to be used to control emissions. The final rule also allows mills to use other control technologies , including control devices and process modifications or chemical substitutions, if they achieve equivalent control to the MACT technology. For purposes of estimating costs and environmental impacts, the Agency selected control technologies that would represent how mills could comply with the final rule. Table 20-4 presents the options considered for existing pulping sources in the national impacts analysis. Table 20-5 presents the options considered for new pulping

sources. The first option shows the option selected for the final rule. Additional options above the sources covered by the final rule, in order of cost-effectiveness, are also presented. Subsequent tables only present costs and impacts for the selected option. For bleaching systems , the MACT floor is control of chlorinated HAP's (by 99 percent) using a caustic scrubber. Information supplied by commenters to the proposed rule and industry survey responses indicate that all bleach plants use scrubbing technologies to reduce chlorinated HAP emissions. As stated in the proposal preamble , EPA analyzed more stringent controls, such as combustion of scrubber vent gases or combustion of bleaching vent gases followed by a scrubber. These more stringent options were determined to be unreasonable considering

20-20the cost and environmental impacts. The EPA's baseline analysis of air impacts on the bleaching system are after OW's BAT options are implemented (see section 20.2.2). No additional control technologies or options in the bleaching systems were identified. 20.4.2 Environmenta l Impacts This section discusses the methodology used to estimate national air, water, energy , and other environmental impacts of the final rule. For the final rule , impacts were estimated for each individual mill and summed to provide the national estimate. Mill-by-mill variations in costs and impacts are a function of mill-specific design, equipment , and operating parameters, which are based on the site specific mill data obtained from the 1992 voluntary MACT survey and the OW survey, and updated from comments and information provided in response to the proposed
rule. Section 20.6 (Data Base System for Estimating National Impacts) presents the procedure for assigning default process operations and equipment to mills where site specific information was unavailable. 20.4.2.1 Primary Air Impact s The primary air impacts include the reduction of HAP, VOC , and TRS emissions directly attributed to applying the control options. Emission reductions for kraft, soda , and semi-chemical pulping vents are calculated by applying the reduction efficiency of combustion devices

(98 percent) to the baseline emissions for systems not already controlling emissions using a combustion device. Emission reductions for sulfite mills are estimated based on the reduction from baseline necessary to meet the sulfite pulping emission limits.

20-22Table 20-6 presents primary air impacts for an example mill. Table 20-7 presents the national primary air impacts (baseline and emission reductions) of MACT controls, by mill type and mill area (pulping vents, pulping wastewater, bleaching vents, and bleaching wastewater) for methanol, total HAP, total VOC, and TRS afte r OW's BAT Option A has been applied. Table 20-8 presents similar information after OW's BAT Option B has been applied. 20.4.2.2 Energy Impact s . Additional energy is required for the control of vent streams and condensate streams. This energy may take the form of electricity, steam, or fuel. Table 20-9 lists the areas of the mills where energy is consumed to meet the MACT standard. For pulping vent streams , the amount of electricity required to operate equipment (e.g., fans , pumps) and auxiliary fuel needed to combust vent streams were determined from algorithms contained in the OCCM (A-92-40, II-A-4), in the proposal BID

(A-92-40 , II-A-35), and in supporting memoranda (A-92-40, IV-B-13, IV-B-28). The amount of electricity required to operate fans or pumps is estimated from the horsepower required to provide motive force to transport vent and condensate streams to control devices. Electricity demand was assumed to be met using off-site power generation facilities. Electricity demand was converted to equivalent fuel requirements assuming off-site power When a combustion device is used to control HAP emissions, auxiliary fuel may be required to sustain combustion. At proposal, vent streams were assumed to be combusted in existing combustion devices to estimate the effect on fuel usage requirements. Following proposal , EPA determined that some mills could use existing devices for combusting vent streams, while

20-23TABLE 20-6. PRIMARY AIR IMPACTS FOR AN EXAMPLE MILL (1,000 tons of oven-dried pulp per day kraft mill)

Affected sources Baseline HAP Emission reduction Emission reduction emissions after (percent) (Mg/yr) OW Option A Control (Mg/yr) a Option HAP VOC TRS HAP VOC TRS Digester and evaporator Knotters Screens Pulp washing Rotary vacuum drum washers

LO W air flow washers Deckers Oxygen delignification Weak black liquor storage Pulping wastewater Tota l

- pulping area 2.2 None None None None None 0.48 Combustion 98 98 98 0.47 1.3 Combustion 98 98 98 1.3

280

20 31 225

12 115 b

687 Combustion 98 98 98 Combustion 98 98 98 Combustion 98 98 98 Combustion 98 98 98 None None None None None None None None 274 20 31 220 None None

550 None None 0.60 0.11 1.6 0.31

810 190 62 14 300 35 63 20 None None None None 1200 260 Bleaching system 46 Bleaching wastewater 24 Tota l

- bleaching area 70 Mill total 757 None None None None None None None None None None None None None None

550 1200 260

a Baseline HAP emissions assumes control of digester and evaporator vents and OW Option A process changes

(including no hypochlorite state and 100 percent Cl02 substitution in the bleaching system). b The baselin e HAP emissions of 11 5 Mg/yr corresponds to a mill using biological treatment with a HAP

FE equal to 6.3 percent.

20-24others would need to construct a stand-alone incinerator (A-92-40, IV-E-93). For stand-alone incinerators , EPA assumed that natural gas would be used as the auxiliary fuel. For existing boilers, a mixture of hog fuel (i.e. , wood waste) (60 percent), oil

(10 percent) , natural gas (10 percent) , and coal (20 percent) was assumed based on fuel usage information supplied by the pulp and paper industry in responses to the OW survey (A-92-40, IV-B-28). The fuel energy required to combust vent streams was calculated in the incinerator and boiler design algorithms from the OCCM. For boilers , the fuel energy was converted to the mass of hog fuel, oil , natural gas , and coal needed using the fuel splits presented above and the heating value of each fuel (4,500 Btu per lb of coal ; 18,000 Btu per lb of oil ; 1,000 Btu per standard cubic foot of natural gas ; and 13,000 Btu per lb of hog fuel).

(A-92-40, IV-J-78) For kraft pulping condensates , increased steam is required for stripping HAP-laden condensate streams. Steam demand was converted to equivalent fuel requirements based on the same composite of fuels used in the existing boiler assumption. Table 20-10 presents energy impacts for an example mill. Table 20-11 presents national energy requirements.
20.4.2.3 Secondary Air Impacts

. The secondary air impacts evaluated are the increases in criteria pollutant emissions (SO2, CO, NO,, PM, and VOC) resulting from: (1) combustion of compounds in vent streams and (2) increased burning of fuel used as auxiliary fuel or for steam or electricity generation used for powering equipment.

20-30The combustion of vent gases results in secondary emissions of sulfur dioxide. The proposal BID presented secondary emissions of sulfur dioxide based on combustion of TRS compounds only (i.e. , hydrogen sulfide , dimethyl disulfide, dimethyl sulfide, and methyl mercaptan). For the final rule, secondary emissions of sulfur dioxide were estimated by assuming complete stoichiometric combustion of all sulfur containing compounds (i.e., the TRS compounds , and carbon disulfide and carbonyl sulfide) to the combustion end products of water, ClO2, and sulfur dioxide. For example, 1 kilogram of hydrogen sulfide oxidizes to form 1.88 kilograms of sulfur dioxide. The new methodology increases the sulfur dioxide emissions calculated for the final rule. The impacts calculated for the final rule may over-estimate sulfur dioxide emissions because mills may be able to use existing sulfur dioxide controls to reduce sulfur dioxide emissions. However, EPA does not have sufficient information on the number and effectiveness of these controls, so no reductions were taken. Also, mills may use other control options that may not increase sulfur dioxide emissions, such as the clean condensate alternative or low-emitting equipment. Criteria pollutants are also emitted from fuel used to generate electricity and steam , and from the burning of auxiliary fuel to combust vent streams. Areas where energy is consumed are presented in table 20-9. Criteria pollutant emissions were calculated from the amount of fuel required (as discussed in section 20.4.2.2) and criteria pollutant emission factors (usually in pound of pollutant per ton or gallon of fuel) presented in previous EPA studies for combustion of each fuel.

(A-92-40, IV-J-77)

20-33Scrubbing of bleaching system vent streams was assumed to generate no secondary air emissions because all bleached mills are assumed to be already operating a scrubber, and no additional control techniques were applied to the bleaching system. Table 20-12 presents secondary air impacts for an example mill. Tables 20-13 and 20-14 present national secondary air emissions from applying the MACT requirements and OW Option A and Option B , respectively , to the current baseline. 20.4.2.4 Water and Other Impacts

. No significant revisions were made to the assumptions or conclusions regarding water impacts and other impacts (i.e., noise, visual, odor, and solid waste). 20.5 ESTIMATED CONTROL COSTS This section presents the national cost of the final rule and the changes made to the costing methodology. Section 20.5.1 discusses the assumptions used for sizing and estimating the costs of control technologies ; section 20.5.2 presents estimated national costs. 20.5.1 Control Cost Methodology. The national costs are estimated by calculating the cost of each control option applicable to each mill and summing the millspecific results to obtain a national total. The OCCM was used to size and cost equipment in the proposed and final rules. In general , most of the inputs to the OCCM design and cost algorithms did not change from proposal. Some of the global changes were to the interest rate used to estimate capital recovery (7 percent was used in the final rule instead of 10 percent) and labor and utility rates were updated. The EPA has assumed some different control technologies and equipment for the final rule , which required a revision of the

costs. These changes are discussed below.

20-3420.5.1.1 Enclosures and Vent Gas Conveyance Svstems. The algorithms and assumptions used for estimating the cost of equipment enclosures , as presented in the proposal BID, have not been revised. However, assumptions regarding ductwork used for the conveyance of vent streams from either discrete emission points or from enclosures to the control devices have been revised (A-92-40, IV-B-13). Specifically, the following design assumptions affecting cost have been revised since proposal:

. Based on comments received following proposal, the duct length from the emission points and enclosures to existing combustion devices has been increased from 1,000 feet to 1,500 feet.

. At proposal , the equipment comprising the ductwork system was assumed to include ductwork and elbows, fan, knock-out drum(s), flame arrestor(s), rupture discs, supports, and insulation. Based on comments to the proposed rule , EPA also included the following additional equipment: condenser, condensate storage tank(s), and sampling port(s).

. Costs for ductwork at bleach plants were not evaluated because mills are already controlling the chlorinated vents. Analysis of non-chlorinated vents were dropped as an option as discussed earlier.

20.5.1.2 Control Technology Costs for Vents. For the thermal oxidizer system , heat recovery is a key variable affecting capital costs. At proposal , the model mill that was used to calculate costs was assumed to combust pulping vents in an existing combustion device (e.g. , lime kiln or power boiler). Therefore, no heat recovery for a thermal oxidizer was assumed. After proposal , EPA surveyed several mills on the capacity of existing combustion devices to combust additional vent streams

(A-92-40, IV-E-85). The results of the survey indicated that

20-40two-thirds may have the capacity in their existing combustion devices, while one-third would construct a stand-alone incinerator. This ratio was used to estimate national impacts. Because EPA did not have sufficient information to assign the control scenarios to each mill , costs were calculated assuming one-third of the costs for controlling pulping systems were from a stand-alone incinerator and two-thirds of the cost was from routing vent streams to an existing boiler. A 95 percent heat recovery was assumed in developing the final thermal oxidizer system costs. Costs associated with a thermal oxidizer were calculated using algorithms on the OCCM. These algorithms were previously used to cost thermal oxidizers to control bleaching system vents in the proposal BID. 20.5.1.3 Control Technology Costs for Pulping Process Condensates. This section describes the steam stripper design considerations. It also provides the design parameters affecting cost and the general methodology used to develop capital and annual costs for steam-stripping and for hard-piping condensate streams to wastewater treatment systems.
Stea m stripping costs. No revisions were made since proposal to the general methodology used to develop capital and annual costs for steam stripper systems, but some specific revisions were made to the steam stripper design assumptions used in the costing methodology. As discussed in section 20.3.2.1, the removal efficiency of methanol was increased from 90 to 92 percent. The volumetric flow rate of condensate sent to the stripper system was also revised. Based on industry data submitted following proposal (A-92-40, item IV-B-g), the flow rate was

20-41decreased from approximately 1 GPM per ADTP to 0.20 GPM per ADTP. The revised value is more accurately reflects the volumes of condensate treated in the existing steam stripper systems. The steam stripper column tray efficiency was reduced from 67 percent to 50 percent. This revision was made based on industry comments indicating that a 50 percent efficiency more accurately reflects the operation of steam strippers in the pulp industry due to plugging of tray openings associated with the fiber content of pulping process condensates. Steam stripper cost credits were developed for the methanol rectification process and the reduced amount of BOD sent to biological treatment system because of the operation of the steam stripper. The methanol rectification credit is based on costs savings associated with replacing fossil fuels used for power generation with the concentrated methanol condensates derived from the steam stripper vent gases (A-92-40, IV-B-17) The biological treatment system cost credit was developed based on information submitted by industry following proposal (A-92-40, IV-B-25). Hard-piping to biological treatment system costs. The cost of biological treatment was not estimated at proposal. Following proposal, several companies submitted estimates for the costs associated with hard-piping pulping process condensates to a biological treatment system. These costs were normalized to a dollar per ton of pulp produced basis ($1,230 per PDTP total capital investment , $197 per ODTP total annual cost). The normalized cost factor was then used to estimate the cost of hard-piping for other mills. (A-92-40, IV-B-25)

20-4220.5.2 National Costs for the Control Options Tables 20-15 and 20-16 present summaries of total capital investment and total annual cost by mill type for the control options chosen in the final rule (and options beyond the chosen option) after OW Option A and B have been implemented. Tables 20-15 and 20-16 present costs for controlling existing sources only. A summary and discussion of total capital investment and total annual costs for controlling new sources is contained in the new source costing memorandum (A-92-40, IV-B-l00). 20.6 DATA BASE SYSTEM FOR ESTIMATING NATIONAL IMPACTS This section summarizes the changes to the pulp and paper NESHAP data base that is used to estimate national impacts of the final rule. This section only presents changes to the original data base discussed in chapter 6 of the proposal BID. Section 20.6.1 discusses revisions to the data base. Section 20.6.2 presents the calculation of impacts and section 20.6.3 discusses revisions to the national impacts estimation methodology and analyses performed to incorporate effluent guidelines regulations , which are being promulgated simultaneously with the NESHAP. 20.6.1 Data Base Revisions 20.6.1-l Data Base Structure. At proposal , EPA developed model pulping and bleaching process units to represent the variety of emission points in a pulp mill. To estimate national impacts, the models were assigned to each mill based on As discussed in section 20.2.1 , EPA used a number of sources to develop a data base characterizing pulp and paper mills. When information from the various sources conflicted, the following

20-43Emission Factor Development Document (A-92-40, IV-A-8), and the average vent stream characteristics are detailed in a separate memorandum (A-92-40, IV-B-28). If no emission controls were reported in the surveys or in other data then generally none were assigned. The exceptions were the control status of the LVHC system and assignment of enclosures to pulp washers. Since a NSPS exists requiring LVHC vent streams at kraft mills to be controlled, the assumption was made that all LVHC systems at kraft mills were already controlled. As documented in the proposal BID, pulp washers constructed after 1978 were assumed to be enclosed. Information was not available to describe the pulping condensate characteristics (e.g., flow rate, HAP concentration, recycle/reuse patterns, etc.) at each mill. Condensate characteristics , per unit capacity , were developed based on the information contained in the NCASI condensate study (A-92-40, IV-A-8). These characteristics were used for all pulping types.
20.6.2 Calculation of Impacts For the final rule , national impacts were calculated using methodologies discussed earlier in this subsection and in sections 20.1 through 20.5. The structure of the data base remained relatively unchanged since proposal (see figure 6-l in the proposal BID). The only major changes are that actual system data was used rather than using model units, and default values were used to fill in data gaps. Therefore, the industry characterization did not include model mills. Baseline emissions and emission reductions resulting from control options were calculated for each equipment system and were summed for each system, each mill, and for all mills

20-47combined. Control costs were calculated by mill area (pulping vents, pulping wastewater , bleaching vents) and summed for the total mill, instead of by equipment system since add-on controls may be applied to multiple systems (i.e., multiple vents were assumed to be routed to control devices through a common header). As discussed in section 20.5 , after proposal EPA determined that for kraft, soda , and semi-chemical mills, some could use existing combustion devices while others would need to construct stand-alone incinerators to control vent streams. Because EPA did not have sufficient information to assign the control scenario to each mill , total costs were calculated by adding twothirds of the costs for routing to an existing device and onethird of the cost for constructing a dedicated incinerator. The control costs for sulfite mills were based on reducing the temperature of the vent gas streams before they are routed to the acid plant scrubber or nuisance scrubber to increase the removal efficiency. For kraft pulping condensates, baseline emissions were estimated based on the type of treatment process (i.e., biological treatment system or steam stripping) in place at existing mills. For mills where the configuration of the existing biological treatment systems were available, emissions were based on the configuration of the equipment and the model that calculates air emissions from wastewater systems. Emission reductions were estimated based on hard-piping pulping process condensates to well-operated biological treatment systems. Steam stripping emission reductions were applied to mills with existing biological treatment systems not arranged to meet the final rule

20-48without major reconstruction. For control purposes a new steam stripper was costed. For mills where no information was available regarding the configuration of the existing biological treatment systems and there was not existing steam stripper , the impacts were estimated by applying average factors , on a ton of pulp production basis. The average factors were calculated by dividing the total impacts, estimated for the mills with sufficient configuration data, by the total production for those mills.
20.6.3 Effects of OW Changes on Impacts As discussed in section 20.2.3 , OW is promulgating effluent guidelines that change pulping and bleaching processes. The baseline equipment configurations and assumptions were adjusted to represent the mill after the two OW options where enacted. The major adjustments that affect emissions and costing are:

. Use of low water flow washers (emitting less air emissions) at specific mills,

. More recycling condensates of in the pulping mill which increases air emissions for affected equipment,

. Use of oxygen delignification (which increases the number of emission sources to be controlled, and increases the HAP concentration in process water recycled into other systems), and

. Changes in the use of chlorinated compounds in bleach areas (which reduces chlorinated air emissions).
The effect the changes have on emissions and costs is presented in supporting memoranda (A-92-40, IV-B-28). Impacts presented in this section are after OW Options A and B have been implemented, and differences in environmental and energy impacts is shown on table 20-17.

20-4920.7 SUMMARY OF ENVIRONMENTAL AND COST IMPACTS OF THE MACT
STANDARDS Table 20-17 also summarizes the total impacts of the MACT standards after OW's effluent guidelines (Options A and B) have been implemented. The table presents the current baseline emissions, baseline emissions after OW Options A and B are implemented , and the MACT II baseline emissions (see MACT II BID for details on the MACT II estimates). The table also summarizes emission reductions, energy consumption, secondary impact generation , and costs resulting from applying MACT controls to the MACT I and MACT II sources.

20-50REFERENCES

Docket Citation A-92-40, II-A-35

A-92-40, IV-J-87

A-92-40, IV-A-8 Description Pulp, Paper, and Paperboard Industry-- Background Information for Proposed Air Emission Standards. Manufacturing Processes at Kraft, Sulfite, Soda, and Semi-Chemical Mills. Publication No. EPA-453/R-93-050a. October 1993 1996 Lockwood-Post's Directory of the Pulp, Paper, and Allied Trades. Miller Freeman Publications. pp. 37-152. Chemical Pulping Emission Factor Development Document. Revised Draft. Prepared by Eastern Research Group for
U.S. EPA. September 1997.
D.B. Greene , ERG, to Penny Lassiter,
EPA:WCPG. August 18, 1997. Addendum to the baseline level of control analysis. A-92-40, II-A-17 a Testing of Non-Combustion Processes in through d a Pulp an Paper Facility. Champion International, Cantonment, Florida. Final Draft Report. Entropy Environmentalists, Inc. Prepared for the U.S

. Environmental Protection Agency, Research Triangle Park, North Carolina. August 1992. A-92-40, IV-B-16

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A-92-40, IV-B-26

A-92-40, II-I-24

A-92-40, IV-B-24

A-92-40, II-A-4 J.R. Farmer , EPA, to Distribution. August 22, 1980. Thermal incinerators and flares.
R.V. Oommen , ERG, to Penny Lassiter,
EPA:WCPG. October 7, 1997. Memorandum presenting outputs from the pulp and paper NESHAP database. Bleach Plant Chlorine and Chlorine Dioxide Emissions and Their Control. National Council of the Paper Industry for Air and Stream Improvement (NCASI). Technical Bulletin No. 626. September 1991. 84pp.
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EPA:WCPG. September 10, 1997. Memorandum documenting the supplemental analysis to confirm the percent mass split requirements developed for condensate segregation. OAQPS Control Cost Manual. Fourth Edition. Publication No. EPA-450/3-0- -006. January 1990. pp. 2-25 thru 2- 29, 3-l thru 3-66, 7-38 and 7-39, an 9-l thru 9-76.

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A-92-40, IV-B-28

A-92-40, IV-E-85

A-92-40, IV-J-78

A-92-40, IV-B-9 R.V. Oommen , Radian Corporation, to Penny Lassiter, EPA:WCPG. February 26, 1996. Revisions to the approach used for the design and cost estimates for equipment associated with transporting, treating, and controlling emissions from vents at pulp and paper mills.

R.V. Oomen , ERG, to Penny Lassiter,
EPA:WCPG. September 25, 1997. Characterization of the industry population affected by the pulp and paper NESHAP. D. Greene, ERG, to P. Lassiter,

EPA:WCPG. August 26, 1997. Summary of the October 21 and 30, 1996 teleconference with AF&PA representatives to discuss biological treatment system issues.

Stea m - Its Generation and Use. Fortieth Edition. The Babcox and Wilcox Company. 1992. pp. 8-9, 8-15, 8-17, and 8-18.
D.B. Greene , Radian Corporation, to Penny Lassiter, EPA:WCPG. February 22, 1996. Memorandum presenting the development of kraft pulping condensate characteristics.

20-55A-92-40, IV-B-25

A-92-40, IV-B-100

A-92-40, IV-B-17

A-92-40, IV-Dl-59

A-92-40, IV-Dl-92 D.B. Greene , ERG, to Penny Lassiter,
EPA:WCPG. September 10, 1997. Memorandum documenting the development of the. Cost factors to hardpipe condensates to a biological treatment system.
R.V. Oommen , ERG, to Penny Lassiter, EPA:WCPG. August 18, 1997.

Memorandum presenting the analysis of control requirements for new pulping

sources. D.B. Greene , ERG, to Penny Lassiter,

EPA:WCPG. September 10, 1997. Memorandum presenting the development of the pulping process condensates treatment costing methodology. J.E. Pinkerton, NCASI, Inc., to P. Lassiter, EPA:WCPG. March 17, 1995. Description of Assumptions Used to Develop Comparison Between the Industry's Condensate Pretreatment Option and the EPA's Proposed MACT Standards. Kraft Mill Condensate Treatment System Conceptual Design and Order-ofMagnitude Costs Estimate. Prepared by CH2M Hill for NCASI. December 1994.

20-56A-92-40, IV-B-10

A-92-40, IV-J-77 D.B. Greene , Radian Corporation, to Penny Lassiter, EPA:WCPG. February 29, 1996. Steam stripper performance parameters for bleached and unbleached kraft pulping mills. Compilation of Air Pollutant Emission Factors (AP-42). Volume I: Stationary Point and Area Sources. Fourth Edition. Office of Air Quality Planning and Standards, Research Triangle Park , North Carolina. January 1995. pp. 1.1-3, 1.1-9, l.1-20, 1.3-9, 1.3-15, 1.4-4, through 1.4-6, 1.6-5, 1.6-7, and 1.6-8.

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