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 1997
This 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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X


1.0 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-l
In 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-2
7.0 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-3
BAT

BACT

BID

BIF

BLO

BMP

BOD

BOD5

BPT

Btu

CEMS

CCA

CFR

ClO2

CO

CO2

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

British thermal 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-4
EPA

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-5
NESHAP

NIOSH

NOCEPM

NODA

NOx

NPDES

NSPS

NSR

OAQPS

OCCM

ODP

ODTP

OMB

ORD

OSHA

OTR

OW

PCP

PM

PM10

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-6
ppmw

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

SO2 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 SUMMARY 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-7
persons 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-8
TABLE 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 of Hopewell

Hopewell, Virginia

Dianne M. Reid

State of North Carolina Department of

Environment, Health, and Natural Resources

Raleigh, North Carolina

l-9
TABLE 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

Hollingsworth & 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-10
TABLE 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-11
TABLE 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

Chadbourne & 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-12
TABLE 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

Proctor & 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

1-13
TABLE 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-14
TABLE 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

Dana Dolloff

Rayonier

Stamford, Connecticut

l-15
TABLE 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

Chadbourne & Parke

Washington, DC

Steve Mason

Mead

Dayton, Ohio

Alan Lindsay

International Paper

Memphis, Tennessee

Henry Clifford

Proctor & Gamble

Cincinnati, Ohio

Corrine Goldstein

Covington & Burling

Washington, DC

l-16
TABLE 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-17
TABLE 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

Sidley & Austin

Washington, DC

Ted Strong

Columbia River Inter-Tribal Fish Commission

Portland, Oregon

Donna Hayes

Dickinson Citizens for Clean Air

Norway, Michigan

David Driesen

Natural Resources Defense Council

Washington, DC

Bharat Shah

Wisconsin Tissue

Menasha, Wisconsin

Art Vosburg

Pope & 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

Joe Mayhew

Chemical Manufacturers Association

l-18
TABLE 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

Covington & 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-19
TABLE 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-20
TABLE l-l. LIST OF COMMENTERS ON THE

DECEMBER 17, 1993 PROPOSED RULE (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

41 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-21
TABLE 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

Albert 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-22
TABLE l-l. LIST OF COMMENTERS ON THE

DECEMBER 17, 1993 PROPOSED RULE (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-23
TABLE l-l. LIST OF COMMENTERS ON THE

DECEMBER 17, 1993 PROPOSED RULE (Continued)

Office of Water

docket control

number Commenter and affiliation

20,149 Paul Gerbec

Minnesota Pollution Control Agency

St. Paul, Minnesota

20,150

20,151

20,152

20,153

20,154

20,155

Bob 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

Nez Perce Tribal Executive Committee

Lapwai, Idaho

Paul C. Martyn

Los Angeles County Sanitation Districts

Whittier, California

Yogesh M. Mehta

Brown & 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-24
TABLE 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

Pope & 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

Proctor & Gamble

Cincinnati, Ohio

Thomas C. Jorling

International Paper

Purchase, New York

Phillip J. Arthur

Finch Pruyn & Co., Inc.

Glen Falls, New York

l-25
TABLE 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

Larry Tenth

Chemitics

Vancouver, British Columbia, Canada

IV-D2-20 Duane W. Marshall

Union Camp

Savannah, Georgia

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

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-27
TABLE l-3. LIST OF COMMENTERS ON MACT III SOURCESa

(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)

aMACT III sources include papermaking systems, mechanical pulping

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

l-28
specifying 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-29
kraft, 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 Control 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

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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.

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-31
water"). 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-32
fraction 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-33
causticizing 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-34
final 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., soluble BOD5) 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-35
Several 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-36
using 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 (ClO2)

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 ClO2 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-37
All bleaching systems are also required to control

chloroform emissions by using 100 percent ClO2 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

1-38
after 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 ClO2 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

1-39
compliance 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 ClO2 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-40
alternative 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-41
startups, 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

1-42
lines 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 OF 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-43
the 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

Act (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 Emission 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

409,000 Mg/yr (450,000 tpy), which represents a 49 percent

reduction by 2005 compared to emissions that would result in the

l-44
absence 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 1012 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

(NOx), sulfur dioxide (SO2), 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 NOx

emissions are expected to increase by approximately 5,230 Mg

annually. The PM emissions are expected to increase by

approximately 83 Mg annually.

l-45
1.5.4 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 Economic 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,

SO2, CO, and NOx. The benefits (damages) that accrue as a result

of the standard result from changes in human health effects

l-46
TABLE l-4. NATIONAL COST IMPACTS FOR NESHAPa

Cost category

Total capital Total annualized

investment costb

(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

aImpacts are for controlling air emissions after the CWA

effluent guidelines are implemented.

bAmortized capital costs plus operation and maintenance costs.

l-47
associated 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 SO2 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.

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2.0 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

2-1
Deterioration (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

2-2
concentrations 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

2-3
estimates 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 emission 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 ClO2 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 ClO2 substitution.

2-4
Response: 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 ClO2 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 ClO2 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 ClO2

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 ClO2 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.

2-5
2.2.2 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

2-6
factors 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

2-7
determining 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

strict "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.

2-8
Response: 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

2-9
factor 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

2-10
wastewater, 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: One 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.

2-11
Response: 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 ClO2 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

2-12
commenter (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

and 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

2-13
mill-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.

2-14
3.0 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-l
December 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 potential controls and the

best opportunity for integration with effluent 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

3-2
proposal 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 rationale 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 emissions 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

3-3
differences 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 percent ClO2 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.

3-4
In 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.

3-5

4.0 BASIS OF STANDARDS

4.1 STATUTORY INTERPRETATION

4.1.1 88th 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.

One commenter (20,054A2) indicated that the method for

determining the floor level of control was applied inconsistently

4-l
between components that were controlled at greater than

12 percent and those controlled at less than 12 percent. The

commenter (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

commenters (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 section 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

4-2
average these limitations. This interpretation of the statute

has been referred to as the "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

4-3
were grouped together to form mill systems in order to better

characterize emissions from this industry. In determining the

best-performing sources 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

4-4
proved 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.

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The 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

4-6
products 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. One 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

4-7
promulgation 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,

627 F.2d 418, 433, 452-53 (D.C. Cir. 1980); Weyerhauser Co. v.

Costle, 590 F.2d 1011, 1030 (D.C. Cir. 1978); Portland Cement

Assoc. v. Ruckelhaus, 486 F.2d 375, 392-93 (D.C. Cir. 1973);

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

Core v. EPA, 952 F.2d 473, 484 (D.C. Cir. 1991) quoting

Connecticut 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) .]

One 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).

4-9
The 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. One 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

4-10
section 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.

4-11
Response: 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 mills 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.

4-12
Several 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

commenter (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

4-13
source 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 deemed "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

4-14
requirements 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

4-15
reasonable 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

December 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

4-16
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 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.

4-17
4.2.2 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

4-18
do 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

4-19
sources 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

control 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

4-20
commenter (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

4-21
proposal 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: One 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

4-22
the 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 (ClO2 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

4-23
also 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

not require new MACT standards to be significantly more stringent

4-24
than 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: One 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

4-25
technologies 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.

Kraft 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

4-26
washing 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

no "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

1 imit would be the best way for mil 1s to determine which systems

4-27
would 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

and 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

4-28
emissions 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

4-29
and 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

4-30
systems 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

4-31
design. 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

4-32
were collected and incinerated. Nine 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

4-33
systems 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 ClO2.

4-34
One 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

4-35
interferences 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

4-36
and 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 on 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.

4-37
Response: 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.

4-38
Therefore, 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 SO2

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

4-39
control 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

ClO2 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

SO2 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.

4-40
Therefore, 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

limits 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

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, 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-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

4-41
of 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: One 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.

4-42
Therefore, 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.

4-43
Regarding 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 pulping MACT floor level of control

technology.

Comment: Regarding the December 1993 proposal, one

commenter (20,072) argued that since EPA has historically

4-44
regulated 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.

4-45
Closed-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

4-46
systems 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.

4-47
4.3.1.3 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.

4-48
Several 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

HAP only in the bleaching component and the MACT f loor shou.ld be

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 limits 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

4-49
substitution 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.

4-50
Several 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,

4-51
chloroform 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

4-52
significantly. 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

4-53
baseline 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

4-54
evaluated 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

4-55
demonstrated 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

4-56
mills. 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 FR 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

4-57
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 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-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.

4-58
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 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, one 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

4-59
of 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

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processes 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

4-61
stripping 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 SO2 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

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commenters (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 mills practice steam stripping.

Therefore, the MACT floor level of control for kraft wastewater

is steam stripping.

For sulfite, semi-chemical and soda mills 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

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(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

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unreflective of current industry practice. The 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 Stream 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

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December 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 de 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

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(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 from 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

4-67
relief 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

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of 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

4-69
commenter (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 the internal configuration of the equipment and that

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improved 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

4-71
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. 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

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mass 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 be1 ieves that achieving the min

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requirements 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

dioxide 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.

4-74
Response: 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

4-75
controlled 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

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floor 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-chlorinated 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, and 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

4-77
mills 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

commenter (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.

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One 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 same as the named streams that are

required to be treated in the steam stripper by the final rule.

Additionally, the final rule includes a control option allowing

mills 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.

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4.3.3 Beyond the MACT Floor Level of Control.

4.3.3.1 MACT Set 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 mills 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

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other 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 mill 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

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backup 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

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emissions 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

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(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

commenter (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.

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Two 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

commenter (20,054A2) provided information on how several States

regulate continuous compl iance, and indicated that the kraft pulp

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mill 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, EPA 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, EPA 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 LVHC system control

devices. For control devices used to reduce emissions from HVLC

systems, EPA has concluded that an appropriate excess emissions

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allowance 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

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supply 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

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EPA 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

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measure 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 limits 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

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chloroform 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. One 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 nonchlorinated 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

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chlorine 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

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process 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.

Innovative 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

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a 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 an

effort 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

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as 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

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emission 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).

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Response: 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.

Alternative compliance determinations.

Comment: One commenter (IV-D2-15) supported EPA's intention

to allow sulfite mills to 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 mass 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 sulfite mills. Rather, a mass emissions limit was

established for selected vents and wastewater emissions. This

format was intended to provide sulfite mills with flexibility in

complying with the sulfite rule. The final rule also includes

a percent mass reduction compliance option for additional

flexibility.

Sulfite pulping - statistical arguments concerning emission

limits and data variability.

Comment: One commenter (IV-D2-15) stated that EPA did not

establish the mass emission limits for sulfite mills properly.

The commenter stated that the mass limits are based only on " a

handful of ballpark values" and not a rigorous assessment of

emission rates. The commenter also stated that the variability

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of 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

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data 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:

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mass

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

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l-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 Alternative 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

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(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

commenters (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

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not 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.

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Response: 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

4-104
evaluation, 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

4-105
perform 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

meet 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 to choose any

wastewater treatment device for compliance purposes as long as

either the percent reduction, mass removal, or outlet

concentration is 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.

4-106
Miscellaneous 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

de 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

4-107
EPA'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.

4-108
Regarding 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.

4-109
The 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.

4-110
5.0 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-l
emission 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

5-2
they 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

5-3
sufficient 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 SO2 and NOx

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

5-4
data 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 nonchlorinated 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, SO2 and NOx 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. One 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

5-5
have 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.

5-6
The final rule sets standards only for chloroform and other

chlorinated 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) maintained that mills lack the existing combustion

capacity to handle the quantities of gases that would require

incineration under the December 19, 1993 proposed rule. One

commenter (20,018) maintained that current combustion units are

operating at their capacity. One commenter (20,027) indicated

that combustion of HVLC streams would increase the sensible heat

loss and therefore 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

5-7
commenter 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

the 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

5-8
existing 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.

One 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

5-9
issues 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

5-10
necessary. Therefore, these requirements are included in the

final rule. The EPA references "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

5-11
composition common in the paper industry. The 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

5-12
requirements 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, then 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)

5-13
referred 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

5-14
would 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,

5-15
EPA 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.,

5-16
temperature 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. One commenter (20,027) stated that normal oxygen

5-17
content 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. The EPA 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

5-18
combustion 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.

5-19
Response: 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

5-20
that 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

5-21
underestimated 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.

5-22
The 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,

5-23
20,057A2, 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,

78,500 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 NOx,

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

5-24
were 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

commenter (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: One commenter (20,027) stated that the economics

of combusting HAP's in a boiler with an SO2 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 SO2 control on

the boilers or incinerators used for HAP control, some existing

boilers already have SO2 control. To avoid adverse air quality

impacts locally, some of these facilities may be required to

install SO2 control on the boilers or incinerators that are used

for HAP control. The EPA agrees that SO2 control costs on an

incinerator may be less than SO2 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.

5-26
6.0 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/C102 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

6-1
chlorine 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/ClO2 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,

6-2
20,071, 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

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over 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.

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Another 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.

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6.1.2 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.

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Response: 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: One 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,

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installation 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

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considers 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.

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Oxygen 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/C102 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

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and 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: One 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

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

for chlorinated HAP's specified in the rule.

6-12
7.0 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)

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concluded 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

target (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

7-2
commenter (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

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

are steam stripped and streams that are uncontrolled at the floor

level of control. Control more stringent than the floor level is

not warranted given the small 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 level 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

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kraft 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

7-5
achieving 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,

7-6
with 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 of "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

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system 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.

7-8
One 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

7-9
requirements 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.

7-10
7.5 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 NOx, 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., NOx, 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

7-11
the 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 GPM 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,

7-12
20,114, 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

7-13
strippers) 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

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provided 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.

7-15
7.7 OTHER

Comment: One 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.

7-16
8.0 MONITORING

8.1 GENERAL

Comment: One commenter (20,059) stated that the monitoring

parameters in the December 17, 1993 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-l
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 "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

8-2
enforcing 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

8-3
monitoring, 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

8-4
schedule 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.

8-5
Response: 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

8-6
a 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

8-7
pulping 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

8-8
than 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

specific 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.

8-10
Response: 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

8-11
WATER8 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

segregation monitoring standards, EPA did not have sufficient

information to specify the parameters that should be monitored to

demonstrate continuous compliance. For those instances, or if an

alternative 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

8-12
measured. 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

8-13
specific 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

8-14
and 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, section 114 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

8-15
performance 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.

8-16
One 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 commenter (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: The EPA 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. The EPA 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

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performance 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

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oxidizer 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

monitor 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.

8-19
One 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 maintenance

program 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

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be 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

8-21
temperature. 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

commenter (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

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removal 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: One 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

8-24
and 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

8-25
mills, 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

8-26
these 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

8-27
industry'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.

8-28
If 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.

8-29

9.0 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-l
Response: 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

9-2
heated 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.

9-3
One 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

9-4
Association. 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.

9-5
The 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

9-6
either 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.

9-7
Response: 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 CO2 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 CO2 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

9-8
kilns 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

9-9
compliance 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.

9-10
10.0 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-l
Two 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.

10-2
One 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 are subject to control by the rule. This approach also 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.

10-4
Comment: 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.

10-5

11.0 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-l
urged 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.

11-2
The 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.

11-3
11.2 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: One 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

11-4
market 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

EPA 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

commenter (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

11-5
regulations 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

11-6
regulation, 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

the 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

11-7
to 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

11-8
shipments, 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 measures 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

11-9
anticipated 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 NOx. 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

11-10
obtained 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

11-11
specific 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.

11-12
12.0 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-l
result 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

NOx) 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.

12-2
Comment: 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. One 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

and 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 more

recent analysis (the Regulatory Impact Analyses for the

Particulate Matter and Ozone National Ambient Air Quality

Standards [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

12-3
revised 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.

One 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

12-4
and 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

12-5
the 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

12-6
achieved 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

12-7
upper 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

12-8
air 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

12-9
reductions 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

12-10
resulting 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.

12-11

13.0 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,

13-1
particularly 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

13-2
currently 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

13-3
implementing 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

13-4
equivalency 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

13-5
developed 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

13-6
the 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.

13-7

14.0 DEFINITIONS

14-1
Proposal/

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 on 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 The 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) (kof a sulfate (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.

proposal1
Term

Bleaching

component

Proposal/

supplemental notice

definition

All process equipment

beginning with the

first application of

chlorine or 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. include "but not

limited 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 of steam. Boilers of useful energy in the of steam. A boiler is adds any clarity to the

are not considered form of 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

system (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 word "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, lime 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

samefunction 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 the 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, lime 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, lime 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 the "term"

thermal oxidizer.

Therefore, only the
Term

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 or 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.

[Commenter 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] [Commenter 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

[Commenter 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

[Commenter 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 is 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) sulfite 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 more 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)

proposal]
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

with mass 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

liquid streams 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 machine "wet

end" systems (including

sheet formation, pressing

and vacuum systems),

paper machine white water

systems, broke recovery

systems, and "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 "Papermaking 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

"papermaking system.”

Part 70 None A permit issued by a The most 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. The 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 NCG 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

limited 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 and redstock

would not be needed) by

removing the term

"brown" and replacing

with word "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

system beginning with the changed to "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.

[Commenter 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 with "pulp washing

compounds. cooking compounds. system" replacing "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 of +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"

15-1
performance standards to control non-criteria pollutants, such as

TRS, and to require State Implementation Plans (SIP) to

incorporate these standards.

One 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

15-2
be 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: One 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

15-3
water 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

15-4
pollutants 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

15-5
complete 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

15-6
scrubber 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

that 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.

15-7
15.3 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

15-8
would 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 on 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 December 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 mills 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: One commenter (20,053Al) suggested that emission

standards for black liquor oxidation (BLO,) systems should be

included in the proposed pulping emission standards. The

15-10
commenter (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.

15-11

16.0 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 SO2 and NOx; (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-l
proposed 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

commenters (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.

16-2
One 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

mills is not necessary because EPA 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 mill 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 is "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

16-3
PSD increment, or an air quality related value (AQRV) in a

Federal Class I PSD area (e.g., national parks). The 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

considered "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. One 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 to "modified " 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

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additional 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 are "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 SO2 results in potential violation of SO2 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 are "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

16-6
appropriate 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, and 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 as "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

16-7
through 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 NOx emission

increases associated with the control of pulping systems. First,

most of the mills that will experience significant SO2 and NOx

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

16-8
issuing 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 NOx

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

16-9
very large compared to the potential increases in NOx emissions

(about 75 to 1). The rule will decrease VOC emissions by

409,000 Mg/yr and may increase NOx emissions by 5,230 Mg/yr,

nationally. The EPA recognizes that some of those increases will

occur in the northeast OTR. These increases in NOx are very

small in comparison with current national and regional NOx

emissions and with current NOx emissions from pulp and paper

plants subject to the final rule. Increases in NOx emissions

from compliance with the MACT standard are estimated at about

5,230 Mg/yr (5,753 tons/yr). National NOx emissions in 1994 were

approximately 21.4 million Mg/yr (23.6 million tons/yr).

Increases in NOx 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 NOx emissions.

Facilities installing boilers or increasing boiler capacity

to meet the increased steam demand may have to meet NOx, RACT

standards or LAER. For these facilities, EPA has provided

guidance on meeting NOx standards in a documented entitled

Alternative Control Techniques Document -- NOx Emissions from

Industrial/Commercial/Institutional (ICI) Boilers,

EPA-453/R-94-022, published in March 1994. This document

outlines several options for reducing NOx from industrial

boilers.

For combustion devices used to combust pulping vent streams,

EPA does not believe that guidance on NOx 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

16-10
construct 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 NOx increases at these mills. The

facilities using existing combustion devices should not trigger

any additional NOx RACT requirements beyond those already in

place for these devices.

For the 30 percent of facilities EPA estimates will install

new incinerators, NOx 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 NOx

formation mechanisms show that below 1800 OF, negligible levels

of NOx are generated. Therefore, the standard tends to minimize

the additional formation of NOx. In the event that a facility

that does become subject to NOx RACT, available technologies

include low-NO, burners, selective catalytic reduction (SCR), or

selective non-catalytic reduction (SNCR) technologies.

Comment: One 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

of "modification" in NSPS regulations.

16-11
Response: 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.

16-12
One 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

16-13
re-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

16-14
gases 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 to "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

16-15
regulation 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

commenter (20,054A2) requested that EPA provide an additional

comment period for further comments on the relationship between

16-16
the 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

16-17
June 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.

16-18
Response: 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: One commenter (20,027) requested that, because the

provisions of 112(j) may be misconstrued to apply to sulfite

16-19
recovery 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

16-20
concluded 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

Guideline (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.

16-21
The 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: One 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

16-22
sources 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

16-23
required 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: One 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

16-24
required 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 for "part 70 permit" by defining part 70 permit to

mean "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 mean "any day on which the Federal government offices

are open for normal business. Saturdays, Sundays, and official

federal holidays are not working days."

16-25
Response: 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 be

that 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

16-26
has 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.

16-27

17.0 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-l
Response: 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.

17-2
Response: 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

17-3
all 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

17-4
commenter (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

17-5
obvious 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

17-6
compliance 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

the 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

17-7
for 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, EPA 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

17-8
offer 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). One 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

17-9
included 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

17-10
capital 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 (see 61 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

section 112(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

17-11
alternative 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

17-12
compliance 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

17-13
take 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 of "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

17-14
promulgation, yet the final rule might impose water requirements

that would make those plans and expenditures worthless. One

commenter (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.

If "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

17-15
and 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 FR 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

17-16
March 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

17-17
reasons 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: One 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

17-18
standards 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.

17-19

18.0 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

18-1
they 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: One 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

18-2
reasons. 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

18-3
Mills, 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

commenter (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, and "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.

18-4
Response: 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: One 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

18-5
environmental 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.

18-6
19.0 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), the "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.

19-2
Comment: 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

EPA 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

19-3
determination. 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

emission limits in the rule. The EPA has no authorization under

section 112 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: The limits 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 limits can be actually met in

practice.

19-4
20.0 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;

. integrated 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-l
Such mills 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 pulping mills, secondary fiber deinking and nondeinking mills, and non-wood mills) are chlorine and chlorine

dioxide stages in bleaching operations (see section 16.0). As a

result, most 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. For some 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

20-2
technical 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 semi20-3
chemical 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 System 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

20-4
TABLE 20-l. DISTRIBUTION OF CHEMICAL AND SEMI-CHEMICAL PULP

PROCESSES IN THE UNITED STATESa

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

aIn 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 sulfite mill. Note that the sulfite mill in Alaska is

closing.

Source: 1990 EPA OW Survey, adjusted as of Fall 1996

20- 5
emissions, 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.

20-6
20.2.2.2 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.

20-7
The 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

20-8
60 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

20-9
processes. 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

(Option 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).

20-10
Uncontrolled 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

20-11
after 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.

20-12
TABLE 20-2. EMISSIONS FROM AFFECTED SOURCES FOR AN EXAMPLE MILL

(1,000 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 evaporatord

Knotters

Screens

Pulp washing

Rotary vacuum drum washers

LOW air flow washers

Deckers

Oxygen delignification

Weak black liquor storage

Pulping wastewater

Total - pulping area

Bleaching systeme,f

Bleaching wastewater

Total - 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

aSystems listed are assumed to exist at the example mill.

bEmission 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).

CTotal HAP is calculated by summing emissions from all HAP species.

dCombustion control efficiency of 99.9 percent assumed in the emissions presented.

eNo uncontrolled emission factor available. All data is post scrubber. Emissions reflect the presence

of a scrubber.

fAssumed no hypochlorite stage and no chlorine dioxide substitution for the open mill. Assumed

100 percent substitution for the closed mill.

20-13

20.3.1 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

20-15
difference 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.

20-16
The 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.

The 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, items IV-Dl-59 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

20-17
for condensate streams to be controlled have been added to the

analysis since proposal.

20.3.2.1 Steam 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

20-18
performance 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.

20-19
Section 20.4.2 discusses emissions reductions and secondary

environmental impacts.

20.4.1 Control 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

20-20

the 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 Environmental 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 Impacts 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.

20-22
Table 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

after 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 Impacts. 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

20-23
TABLE 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

LOW air flow washers

Deckers

Oxygen delignification

Weak black liquor storage

Pulping wastewater

Total - 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

115b

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

Total - bleaching area 70

Mill total 757

None

None

None None None None None None

None None None None None None

550 1200 260

aBaseline 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).

bThe baseline HAP emissions of 115 Mg/yr corresponds to a mill using biological treatment with a HAP

FE equal to 6.3 percent.

20-24





others 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.

20-30


The 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)

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Scrubbing 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.

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20.5.1.1 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

20-40
two-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.

Steam 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

20-41
decreased 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)

20-42
20.5.2 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

20-43



Emission 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

20-47
combined. 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

20-48
without 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.

20-49
20.7 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.

20-50


REFERENCES

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

20-53
A-95-31, II-B-1

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. 

D.B. Greene, ERG, to Penny Lassiter,

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.

20-54
A-92-40, IV-B-13

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.

Steam - 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.

20-55
A-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.

20-56
A-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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