# 1 

# UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

SECTOR POLICIES AND PROGRAMS DIVISION

OFFICE OF AIR QUALITY PLANNING AND STANDARDS

O FFICE OF AIR AND RADIATION

January 13, 2012



# MEMORANDUM

SUBJECT: Meeting notes for the January 12, 2012 meeting with AF&PA

FROM: Kelley Spence (EPA/OAR/OAQPS/SPPD/NRG)

John Bradfield (EPA/OAR/OAQPS/SPPD/NRG)

TO: Docket EPA

- HQ

- OAR

- 2007

- 0544

This memorandum summarizes the meeting between The American Forest and Paper

Association (AF&PA) and the EPA on January 12, 2012 . This meeting was requested in

response to the R isk and Technology Review (RTR) of the National Emission Standards for

Hazardous Air Pollutants (NESHAP) for the pulp and paper in dustry. M e e t i n g h a n d o u t s a r e

a t t a c h e d

.

Meeting Attendees:

John Bradfield, EPA John Pinkerton, NCASI

Corey Brandt, Rock Tenn Annabeth Reitter, New Page Corp.

Mike Curtis, Georgia

- Pacific Brittany Robinson, URS

Robin Dunkins, EPA Bill Schrock, EPA

Rich Garber, Boise Inc. Jeff Shumaker, IP

Katie Hanks, RTI Kelley Spence, EPA

Tom Holloway, RTI Nick Swanson, EPA

Tim Hunt, AF&PA Jim Taylor, MWV

Ashok Jain, NCASI Elineth Torre s, EPA

Rob Kaufmann, KCPS Vipin Varma, NCASI

Paul Noe, AF&PA Cliff Whitam, IP

# 2 

# Discussion Points :

**•** Introductions

**•** Review agenda

**•** Kraft mill condensate treatment efficiency

o Discussed proposed changes to the condensate standard

o Review of the process and generation of condensates

o Review of the development of the NESHAP compliance options

o Discussed the cost of the proposed changes to the condensate standard

**•** Emission Allowances

o Discussed the cost of removing the emission allowances

o Reviewed request for information in preamble

o Discussed whether there are emission data available, or work practices that could be

used to address the emission allowances

**•** Comment Period

o AF&PA to request an extension to the comment period

# E P A H a n d o u t s

# AF&PA Informational Meeting

1/12/12

Introductions

Kraft Mill Condensate Treatment Efficiency (120 minutes)

**•** Industry compliance with Subpart S

– compliance flexibility and performance variability

o Cluster Subpart S

o Hardpiping

o Clean Condensate Alternative (CCA)

**•** Basis for proposed changes

– how was ICR data used

**•** Control Efficiency (proposal to increase from 92 to 94%)

o Removal efficiency vs. collection efficiency

– clarify intent

o Methodology to convert % incremental removal to lb/ton and concentration

– possi ble

mathematical inconsistency

o ICR data and initial performance tests

o F bio 

# variability

o Stripper capacity and operational limitations at higher levels

o Data quality review

**•** Cost impacts

Emission Allowances (30 minutes)

**•** Questions in preamble

– understand wh at is behind questions

**•** Understand better the alternatives being considered:

1. Narrowing the provisions

2. Setting an alternative numerical emission limit

3. Setting a work practice under 112(h) or

4. Lengthening the averaging period of the current standard to accommodate the periods of

excess emissions

Risk Findings (10 minutes)

– Defer if run out of time

**•** HEM input and output files being examined

**•** Focus on few remaining outliers

– confirm how companies enter changes in NEI

Wrap

- up/Next Steps (15 minutes)

**•** Conde nsate issues

**•** Allowance issues

**•** Extension of comment period

# Unbleached Kraft Condensate Compliance Data

Using 6.6 LB./ODTP Treatment Option

NEISiteID Predominant Treatment

Method Compliance

Measure Compliance

Demonstration

NEI11251 Stripping 6.6 7.3

NEI12492 Biotreatment 6.6 8.5

NEI18338 Biotreatment 6.6 9.2

NEI18657 Biotreatment 6.6 8.9

NEI26471 Stripping 6.6 19.5

NEI26491 Stripping 6.6 11.0

NEI33025 Stripping 6.6 9.8

NEI34070 Biotreatment 6.6 7.8

NEI41252 Stripping 6.6 9.5

NEI41552 Biotreatment 6.6 11.6

NEI42338 Biotreatment 6.6 11.7

NEI42357 Biotreatment 6.6 6.6

NEI42689 Biotreatment 6.6 13.7

NEI42710 Stripping and biotreatment 6.6 9.6

NEI45182 Stripping 6.6 10.6

NEI46931 Stripping 6.6 8.2

NEI47104 Stripping and biotreatment 6.6 14.9

NEI6057 Biotreatment 6.6 11.3

NEI8186 Stripping and biotreatment 6.6 8.8

NEI8619 Stripping and biotreatment 6.6 8.8

NEI26495 Stripping and biotreatment 6.6 8.7

NEI7933 Stripping 6.6 12.0

Average 10. 4

Highlighted facilities below proposed compliance demonstration

# Bleached Kraft Condensate Compliance Data

Using 10.2 LB./ODTP Treatment Option

NEISiteID Predominant Treatment

Method Compliance

Measure Compliance

Demonstration

NEI11338 Biotreatment 10.2 12.0

NEI12368 Stripping/Recycle 10.2 18.9

NEI18334 Biotreatment 10.2 16.3

NEI18335 Biotreatment 10.2 10.7

NEI18373 Biotreatment 10.2 12.3

NEI18390 Stripping 10.2 13.7

NEI18660 Biotreatment 10.2 16.6

NEI26476 Stripping 10.2 15.9

NEI26514 Biotreatment 10.2 16.5

NEI26526 Biotreatment 10.2 14.2

NEI33883 Stripping 10.2 13.5

NEI34064 Stripping 10.2 12.9

NEI34066 Stripping 10.2 16.4

NEI40282 Stripping 10.2 20.4

NEI41314 Stripping and biotreatment 10.2 15.5

NEI41628 Biotreatment 10.2 14.9

NEI42410 Biotreatment 10.2 13.3

NEI42695 Stripping 10.2 17.1

NEI45474 Biotreatment 10.2 16.7

NEI46599 Stripping 10.2 15.7

NEI46739 Stripping/Recycle 10.2 11.9

NEI46760 Stripping 10.2 14.4

NEI46835 Stripping 10.2 11.7

NEI47074 Stripping 10.2 16.7

NEI47077 Stripping 10.2 17.4

NEI47091 Biotreatment 10.2 18.1

NEI6261 Biotreatment 10.2 15.0

NEI6273 Stripping/Recycle 10.2 12.4

NEI7181 Biotreatment 10.2 15.0

NEI7559 Stripping 10.2 13.5

NEI759 Stripping 10.2 14.6

NEI8177 Stripping 10.2 20.8

NEI8278 Stripping 10.2 17.8

NEI8601 Biotreatment 10.2 18.1

NEI33887 Stripping/Recycle 10.2 18.4

Average 15. 4

Highlighted facilities below proposed compliance demonstration

# A F & P A H a n d o u t s

# Agenda for AF&PA-EPA Meeting on

Proposed Pulp and Paper Risk and Technology Review Rule

January 12, 2012 (12:30 to 3:30 PM)

Attending: Corey Brandt (Rock Tenn), Jeff Shumaker (IP), Cliff Whitam (IP), Rob Kaufmann

(Koch/GP), Mike Curtis (GP), Jim Taylor (MWV), John Pinkerton (NCASI), Vipin Varma

(NCASI), Ashok Jain (NCASI), Brittany Robinson (URS), Tim Hunt (AF&PA), Rich Garber

(Boise), Paul Noe (AF&PA)

Introductions

Kraft Mill Condensate Treatment Efficiency (120 minutes)

**•** Overview of condensate treatment efficiency concerns

**•** EPA Perspectives on proposed change

**•** Industry compliance with Subpart S – compliance flexibility and performance variability

o Generation and Handling of Condensates

o Condensate collection and treatment

o Clean Condensate Alternative

**•** Control Efficiency (proposal to increase from 92 to 94%)

o Methodology to convert percent incremental removal to lb/ton

o ICR data – margin of safety, initial performance tests

o F bio 

# variability

o Stripper capacity and operational limitations at higher levels

**•** Cost impacts – stripper, WWTS, and increased collection

Emission Allowances (30 minutes)

**•** Potential cost

**•** Questions in preamble on allowances

**•** Understand better the alternatives being considered:

1. Narrowing the provisions

2. Alternative numerical emission limit

3. Work practice under 112(h)

4. Adjusting averaging period for emission allowances

Risk Findings (10 minutes) – Defer if run out of time

**•** HEM input and output files being examined

**•** Focus on few remaining outliers– confirm how companies enter changes in NEI

Wrap-up/Next Steps (15 minutes)

**•** Condensate issues

**•** Allowance issues

**•** Request for extension of comment periodEquivalencyCalculationusedbyEPA•%ImprovementinStandardwhentreatmentwasincreasedfrom92%to94%–2%ofthemaximumpossible8%inimprovementisachieved:OR2/8=25%oftheremainingpossibletreatment–i.e.,25%oftheremainingpossibletreatmentisachieved•The%ImprovementinStandardforeach1%increaseintreatmentefficiency(from93%to98%)wascalculated–At93%‐1%ofmaxpossible8%=1/8=12.5%–At94%‐2%ofmaxpossible8%:2/8=25%–At95%‐3/8=37.5%92%100%%TreatmentScale98%94%96%MaxImprovementPossible=8%Improveto94%=2%8%2%1EquivalencyCalculationusedbyEPA2•PercentageImprovementsinstandardweredirectlyappliedasFACTORStoscaleupthelb/ODTPtreatmentlimitfromthecurrentasfollows:RecalculatedNumericalLimits(lb/ODTP)%Treatment(%controlimprovement)MultiplicationFactorUsedBleachedMillsUnbleachedMills92%10.26.693%(12.5%)1.12511.5(=10.2x1.125)7.4(=6.6x1.125)94%(25%)1.25012.8(=10.2x1.25)8.3(=6.6x1.25)95%(37.5%)1.37514.09.196%(50%)1.50015.39.997%(62.5%)1.62516.610.798%(75%)1.75017.911.6`Thisapproachofconvertingtothelb/ODTPscaleisincorrect`Doesnotaccountforwhatthemaximumleveloftreatmentachievableatthe100%removallevel`Resultsinlb/ODTPstandardsgreaterthancurrentcollectionlevelsApplyingthepercentstandardimprovementtorecalculatenumericalstandards•Thepercentstandardimprovementmetriccanbeusedtorecalculatenumericalstandardsasfollows–At100%‐Collectionlevelsare7.2lb/ODTPand11.1lb/ODTP(unbleachedandbleachedrespectively)–At92%‐Treatmentlevelsare6.6lb/ODTPand10.2lb/ODTP–Forinstance,25%oftheremainingpossibletreatmentisachievedbychangingthestandardfrom92%to94%•6.6+25%of(7.2– 6.6)=6.8lb/ODTP‐unbleachedmills•10.2+25%of(11.1– 10.2)=10.4lb/ODTP‐bleachedmills92%100%%TreatmentScale 98%6.67.2lb/ODTP(Unbleached)10.211.1lb/ODTP(Bleached)94%96%Newlimitsat94%Eff.6.8lb/ODTP10.4lb/ODTPCurrentCollectionCurrentTreatment3

# January 11, 2012 

# GENERATION AND HANDLING OF CONDE NSATES IN THE KRAFT PROCESS

Ashok K. Jain, NCASI

1. Introduction

When the kraft process is used to pulp wood chips, methanol and several other HAPs are

produced as byproducts. The pulp and paper MACT rule has been promulgated to minimize the

potential for the release of these compounds to the air. Among the sources regulated by this rule

are the process condensates. The MACT rules require management and treatment of process

condensates in a specified manner.

EPA recently proposed revisions to the MACT regul ations as a part of its review of these

regulations to consider improvements in contro l technology and residual ri sks to the potentially

exposed population. The proposal by EPA in cludes changes to condensate HAP treatment

requirements. Recent industry discussions with EPA of the condensate co llection and treatment

requirementssuggests the importance of a common knowledge of the technical aspects of the

kraft process that result in the generation of condensates. This document highlights the basic

concepts of the pulping process and shows the ar eas where the condensates are generated. It

should be noted that the equipment installed at mills varies significantly in details, although the

principles are the same.

2. Kraft Process

In the kraft process, wood chip s are cooked with white liquor in batch or continuous digesters

which are maintained at elevated temperature an d pressure. The resulting pulp is washed and

sent to the paper machine at unbleached mills. At bleached mills, the pulp is bleached prior to

being sent to the paper machine. The cooki ng chemicals recovered from pulp washing are

recovered, concentrated, and burne d in a recovery furnace to pr oduce the cooking chemicals. A

lime kiln is also operated to produce caustic from the recovered cooking chemicals to complete

the closed-loop cooking process.

3. Batch Digesters

When batch digesters are used, as shown in Figure 1, noncondensible gases, along with steam

and HAPs, are released from the digester duri ng the cook. This stream is cooled to produce

batch digester relief steam condens ate. It is possible to conden se this steam in two or more

stages to produce segr egated condensates.

If the mill is pulping softwood, especially pine , the resulting condensates contain significant

levels of byproduct turpentine. These condensates are sent to a turpentine recovery system for

the recovery of turpentine (Figure 2). The underflow from the turp entine decanter system,

termed turpentine decanter underflow, has high le vels of HAPs and reduced sulfur compounds.

At the end of the cook, as shown in Figure 3, the c ontents of the digester are sent to a blow tank,

# 2

January 11, 2012 

# where great quantities of steam, and some meth anol, are released. This steam is normally

condensed in two stages, with a direct contact primary, followed by an indirect secondary. The

condensates formed are called batch digester blow steam condensate. In some cases,

condensates from the secondary condenser also go to turpentine recovery. It is possible to

control the two stage condensing of this steam to produce segregated condensates with the

secondary condenser condensates containing a large fract ion of methanol in a small volume.

The fraction of the methanol that does not leave with the relief and blow steam leaves the blow

tank with the pulp and weak black liquor. The weak black liquor is separated from the pulp and

sent to multiple-effect evaporators.

4. Continuous Digestion

When continuous digesters are used, as shown in Figure 4, hot pressurized black liquor is

separated from the pulp and removed from the digest er. During this operation when the liquor is

depressurized (a process referred to as “flashing”) to bring it down to atmospheric pressure,

some of the volatile HAPs produced during pulping are carried with the st eam that leaves the

system. The flash steam can come directly from the flash tanks, and from the steaming vessel,

where the flash steam is used to preheat incomi ng chips. The flash steam is condensed to

produce continuous digester flash steam condensate.

The flash steam is generally condensed in two or more stages to produce segregated condensates.

If the mill is pulping softwood, especially pine, th ese condensates contain turpentine and are sent

to a turpentine recovery system for removal of the turpentine (Figure 2). The foul condensates

leaving the turpentine recovery areas are called turpentine decanter underflow.

The portion of the methanol that does not leave with the flash steam leaves the digester with the

pulp and weak black liquor blown from the bottom of the digester . The weak black liquor is

separated from the pulp and sent to the evaporators.

5. Evaporation of Black Liquor

Weak black liquor from brownstock washers is se nt to multiple-effect evaporators for increasing

its solids content prior to burning in the recove ry furnace. As shown in Figure 5, in multipleeffect evaporators, the weak black liquor is fed to one or two effects which are referred to as

“feed effects.” The first time the liquor is subj ected to evaporation, most of the methanol is

removed from the liquor along with the water vapor evaporated from the liquor. In essence, the

evaporator acts as a stripper to remove the meth anol. This water vapor, along with the methanol,

is condensed in a subsequent effect or a conde nser, producing evaporator condensates. It is

possible to condense this vapor in two or more stages to prod uce segregated rich and lean

streams of condensates.

The remaining methanol is removed in the othe r evaporators, and shows up in the combined

condensates from these effects. The methanol concentration in these combined condensates is

much lower.

# 3

January 11, 2012 

# The liquor feed end of the evaporators is operated under a very high vacuum. This vacuum is

maintained by two stage steam ejectors or by a v acuum pump (Figure 6). Evaporator vacuum

system condensates are formed by these devices , and although these condensates have a low

volume, they contain HAPs and high le vels of reduced sulfur gases.

6. Condensate Segregation (Figure 7)

Many mills practice segregation of condensates into two streams, one containing a low volume

with a high concentration of HAPs, and one cont aining a high volume with a low concentration

of HAPs. This practice is based on the fact that , at any given pressure, different compounds have

different boiling points.

For example, the boiling point of water is higher than the boiling point of methanol. What this

means is that if we have a gaseous mixture of water and methanol, and we pass them over heat

exchanger surfaces, the gases start to cool and c ondense. Because higher boiling point materials

condense more quickly than lower boiling point materials, condensate from the first heat

exchange surfaces will be rich in the higher boili ng point material (water), and lean in the lower

boiling point material (methanol). On downstream heat exchange surfaces, the concentration of

methanol increases because less vapor is available to condense.

Separation of higher and lower boiling point materi als occurs when condens ates from different

heat exchanger surfaces are collected separatel y, or “segregated.” A single condenser body can

be baffled to segregate rich and lean condens ates, or residual vapors from one condenser body

can be passed to a second, separate condenser to achieve the same effect. Thus, if we can control

the condensing in two stages, we can achieve a good separation of water and methanol.

The amount of separation depends on many fact ors, namely temperature, pressure and the

relative amounts of water and me thanol in the gas stream. Fo r condensing these vapors in a

typical kraft pulp mill, the practical limit is to get 65% of the methanol in 20% to 30% of the

water.

Condensate segregation allows mills to reduce the size of the steam stripper and conserve steam

by reducing the volume of the condensates which are sent to the steam stripper.

7. Noncondensible Gases

Mills have installed noncondensib le gas (NCG) systems to collect and burn the reduced sulfur

gases from the digesters and evaporators. Alt hough these gases are generally maintained at an

elevated temperature, some condensates form in these NCG systems. These condensates are

collected and removed at low points in th e system. Again, although the NCG system

condensates have a low volume, they have hi gh levels of methanol and reduced sulfur

compounds.

# 4PulpReliefSteamCondenserNCGReliefSteamBatchDigesterBlow TankBlow SteamPulp & LiquorWashersLiquor to EvaporatorsRelief SteamCondensateFigure 1Batch Digester System

# 5 5Relief Steam Condensatesand/orFlash Steam CondensatesTurpentineTurpentineDecanterTurpentine DecanterUnderflow(Foul Condensate)Figure 2Turpentine Recovery

# 6 6SecondaryCondenserNCG to LVHCPrimaryCondenserOverflowAccumulatorCondensingWaterBlow SteamBatch Digester BlowSteam Condensate(Foul Condensate)Note: It is possible to design and operate thissystem so that only thesecondary condenser condensate is foul condensate.Figure 3Blow Steam Condensers

# 7 7PulpReliefSteamCondenserNCG to LVHCPulp &LiquorWashersLiquor to EvaporatorsContinuous DigesterFlash SteamCondensate(Foul Condensate)Cooking ChemicalsChipsSteaming VesselFlashSteam#1#2FlashTanksFlashSteamDigesterHotLiquorFigure 4Continuous Digester System

# 8 8SteamSteamSteamTo VacuumSystemSurfaceCondenserRich StreamLiquorLiquorLiquorCondensateCondensate#4#5#6EvaporatorFoul CondensatesCombinedCondensates(100 ppm MeOH)Weak BlackLiquor FeedLeanStreamSteamFigure 5Multiple-Effect EvaporatorsShowing only last 3 effects of 6 effects

# 9 9HotwellNCGAfterCondenserInterCondenserFrom SurfaceCondenserHigh Pressure SteamEvaporatorVacuum SystemCondensates(Foul Condensates)Figure 6Evaporator Vacuum System

# 10 10IncomingWater/MethanolVaporsPrimaryCondenserSecondaryCondenserClean CondensateWater 200,000MeOH 2001000 ppmFoul CondensateWater 80,000 28%MeOH 450 69%5600 ppmWater 280,000MeOH 650Figure 7Condensate SegregationTypical Example – All values as pounds/hour unless otherwise noted

# January 11, 2012 

# KRAFT MILL PULPING PROCESS CONDENSATE COLLECTION

AND TREATMENT – RULE BACKGROUND

Ashok K. Jain, NCASI

**•** 1993 EPA proposal required collection and steam st ripping (90% efficiency) of all condensates

containing >100 ppm HAPs.

**•** Industry survey showed that only 32 mills had steam/air strippers.

**•** NCASI conducted a study to document HAP coll ection and treatment at all sources (TB 661).

**•** EPA and industry agreed that the best perfo rming 15 mills, which represented 12% of the 125

pulp mills, collected on an average 11.1 lb metha nol/ODTP and achieved a treatment efficiency

of 92%. All the best performing mills practiced bleaching.

**•** Since unbleached mills generated only 64% as much methanol as bleached mills (TB 702), the

collection requirements for unbleached mills were established at 7.2 lb methanol/ODTP (64% of

bleached mills).

**•** There were parallel discussions of the concept of named streams. Based on these, the following

were defined as named streams: (1) digester condensates, (2) turpentine recovery system

underflow, (3) evaporator condensates from vapors from feed stages and vacuum system, (4)

HVLC condensates, and (5) LVHC condensates.

**•** Survey results showed that the floor mills did not collect or treat all the named streams.

However, it was noted that the final rule s hould accommodate mills wh ich did not generate

enough methanol to meet the collection requirement.

**•** The importance of condensate segregation to mills with steam strippers was discussed in detail.

**•** The final rule, which addresses all these issues, provi des options to collect (1) all named streams,

or (2) LVHC and HVLC condensates plus 65% of HAP mass from digesters and evaporators, or

(3) 11.1 lb methanol/ODTP at bleached mills (7.2 at unbleached mills).

**•** The condensate treatment options in the final ru le include the following: (1) return 10.2 lb

methanol/ODTP to an enclosed sy stem (6.6 for unbleached mill), or (2) remove 92% methanol, or

(3) remove 10.2 lb methanol/ODTP (6.6 for unbl eached) or achieve a HAP concentration of 330

ppm (210 ppm for unbleached mills) at the outlet to the control device.

**•** To allow for the hard piping option, the treatme nt requirement was adjusted which divided the

lb/ODTP treatment value by (1 - r ), where r is the fraction of non-methanol HAPs in the

condensate.



# • For most mills, r is approximately equal to 0.02. T hus for hard piping mills the effective

treatme 

# nt requirement is 94% treatment.

# January 11, 2012 

# Not All Condensate Streams Are Created Equal

.Collection & Treatment OptionsCollection OptionsTreatment Options1`Collect all Named Streams,or`Collect 65% of NamedStreams & LVHC/HVLCcondensates, or`Collect 11.1 / 7.2 lb/ODTP`Treat to 92%, or`Treat 10.2 / 6.6 lb/ODTP,or`Achieve 330 / 210 ppm atthe outlet of the controldeviceThe Pulp and Paper NESHAPRTR Rule1.EquivalencyCalculationusedtoEstablishNumericallb/ODTPTreatmentLimitsforKraftProcessCondensates2.CleanCondensateAlternative(CCA)inBriefa.ComplianceStrategiesforCCAmillsb.Over‐collectionandOver‐treatmentforCCAcompliance3.MACTIPhaseIKraftCondensateTreatmentReportinginthe2011ICR– OtherConsiderationsa.Variability(seasonalandoperational)inFbiodatab.SteamStripperPerformancedatac.Theneedforcompliancemarginsd.FlexibleComplianceOptions(lb/ODTPor%removal)Industry Group Meeting with EPAJanuary, 12, 20121Equivalency Calculation used by EPA`%ImprovementinStandardwhentreatmentwasincreasedfrom92%to94%`2%ofthemaximumpossible8%inimprovementisachieved:OR2/8=25%oftheremainingpossibletreatment`i.e.,25%oftheremainingpossibletreatmentisachieved`The%ImprovementinStandardforeach1%increaseintreatmentefficiency(from93%to98%)wascalculated`At93%‐1%ofmaxpossible8%=1/8=12.5%`At94%‐2%ofmaxpossible8%:2/8=25%`At95%‐3/8=37.5%92%100%%TreatmentScale98%94%96%MaxImprovementPossible=8%Improveto94%=2%8%2%2Equivalency Calculation used by EPA3`PercentageImprovementsinstandardweredirectlyappliedasFACTORStoscaleupthelb/ODTPtreatmentlimitfromthecurrentasfollows:RecalculatedNumericalLimits(lb/ODTP)%Treatment(%controlimprovement)MultiplicationFactorUsedBleachedMillsUnbleachedMills92%10.26.693%(12.5%)1.12511.5(=10.2x1.125)7.4(=6.6x1.125)94%(25%)1.25012.8(=10.2x1.25)8.3(=6.6x1.25)95%(37.5%)1.37514.09.196%(50%)1.50015.39.997%(62.5%)1.62516.610.798%(75%)1.75017.911.6`Thisapproachofconvertingtothelb/ODTPscaleisincorrect`Doesnotaccountforwhatthemaximumleveloftreatmentachievableatthe100%removallevel`Resultsinlb/ODTPstandardsgreaterthancurrentcollectionlevelsApplying thepercent standard improvementto recalculate numerical standards`Thepercentstandardimprovementmetriccanbeusedtorecalculatenumericalstandardsasfollows`At100%‐Collectionlevelsare7.2lb/ODTPand11.1lb/ODTP(unbleachedandbleachedrespectively)`At92%‐Treatmentlevelsare6.6lb/ODTPand10.2lb/ODTP`Forinstance,25%oftheremainingpossibletreatmentisachievedbychangingthestandardfrom92%to94%`6.6+25%of(7.2– 6.6)=6.8lb/ODTP‐unbleachedmills`10.2+25%of(11.1– 10.2)=10.4lb/ODTP‐bleachedmills92%100%% Treatment Scale98%6.67.2lb/ODTP (Unbleached)10.211.1lb/ODTP (Bleached)94%96%New limits at 94% Eff.6.8 lb/ODTP10.4 lb/ODTPCurrentCollectionCurrentTreatment4`AlternateapproachtodirectlycomputenewlimitsfromCurrentCollectionnumbers`7.2lb/ODTPx0.94=6.8lb/ODTPforunbleachedmills`11.1lb/ODTPx0.94=10.4lb/ODTPforbleachedmills92%100%% Treatment Scale98%6.67.2lb/ODTP (Unbleached)10.211.1lb/ODTP (Bleached)94%96%New limits at 94% Eff.6.8 lb/ODTP10.4 lb/ODTPCurrentCollectionCurrentTreatment5Recalculating numerical standards –Alternate Approach6`ReductionsinannualHAPemissionsclaimedbyEPAare4000tons/yr`Thereductionbasedon97millsoperating355days/yrand1000ODTP/dayisa0.2lbHAP/ODTP.Thiscalculationisconsistentwiththe94%treatmentrequirementforlb/ODTPbasedoncurrentcollectionrequirements,ratherthantheproposedlimits.Additional Calculation Inconsistencies in thePreamble to the RuleAll numbers in lb/ODTPBleached UnbleachedCollection Requirement11.17.2Current Proposed TreatmentRequirement10.26.6Proposed Requirement12.88.3Increase in Treatment Requirement2.61.7Requirement based on 94% of currentcollection requirement10.46.8Increase in Treatment Requirement0.20.2Using the 2011 ICR Responses to IdentifyImprovements in Operating Practices- Other Considerations72011 ICR responses on treatment efficiencies also reflectsafety margins and compliance with other standards8`MethanolBiodegradation(Fbio,MeOH)inASBs`Limiteddatafrom4quarterlyperformancetests(RY2009)`Excludingprocessupsets,median“intra‐facility”variabilityinFbio,MeOHwas~3%`Processupsetsresultinhigherlevelsofvariability`AdditionalquarterlyperformancedataneededtoadequatelyrepresentongoingASBperformance`Giventheinherentvariability,observedtreatmentefficienciesreflectsafetymarginsrequiredtodemonstratecompliance`ForCCAmills,reportedtreatmentlevelsreflectcompliancewithbothMACTIPhase1andCCA`NeedtodecouplethetwoinordertoidentifytreatmentlevelsassociatedwithMACTIPhase1complianceHardpipe Mills: Relationship between Fbiomethanoland Fbioadjusted9`Hardpipe Millshaveestablishedan‘r’factortoaccountforthetreatmentofnon‐methanolHAPs`‘r’factorsareapproximately0.02`Demonstratecompliancewithtreatmentrequirementseitherusinglb/ODTPremovedoranadjustedFbioof92%`AdjustedFbioof92%isequaltoFbioofmethanolof94%`Fbioadjusted=Fbiomethanol/(1+1.087r)`Atthenewtreatmentlevelof94%,Fbiomethanolwouldneedtobeapproximately96%10`Percenttreatmentefficienciesforsteamstrippers`Limiteddatafrominitialperformancetests`Indicativeofsteamstripperperformanceimmediatelyfollowinginstallationorscheduledmaintenance`Includescompliancemarginsbuiltintosteamstripperdesign`Datafromongoingperformancetestsessentialtoaccountfordriftsinsteamstripperoperatingefficiency`Reflectiveofongoingcomplianceandoperationaldriftsduringthemaintenancecycle`Amorestringentpercentremovalstandardwouldimpactcompliancemargins2011 ICR responses on treatment efficiencies also reflectsafety margins and compliance with other standards11`Higherthanrequiredlb/ODTPcollectionnumbers`ReflectscompliancewithPhases1and2forCCAmillsusingcondensateover‐collectionaspartofthecompliancestrategy`Reflectstheneedforflexiblecomplianceoptionsaspromulgatedinthe1998NESHAP`“lb/ODTPremoved”OR“percentremoval”complianceoptions`Enablesfacilitiestocomplywithrequirementsevenif%removaldropsbelow92%2011 ICR responses on treatment efficiencies also reflectsafety margins and compliance with other standardsImpact of the current RTR Proposal on CCAcompliance1294% treatment level AND/OR revised lb/ODTPstandards`Facilitiesover‐collectingandover‐treatingcondensatesinSteamStrippersorASBswouldloseaportionoftheresultingemissioncredits`InsufficientemissioncreditstodemonstratecomplianceunderCCA`ComplianceoptionwouldlikelyinvolvetheinstallationofHVLCcollectionsystems`Capitalcostsofupto$15– 20million/installationTheCleanCondensateAlternative(CCA)1BrownstockWasher(BSW)PaperMachineWastewaterTreatmentPulpWastewaterEffluentDischargeContaminatedCondensateCleanCondensateCCA98%ReductionRequired0.31.1CCABaselineEmissions0.20.2CCABaselineEmissions1.42.1SourceBaselineHAPEmissionswithMACTControls,lb/tonCCAHAPEmissions,lb/tonBrownstock Washer1.1 x 0.02 = 0.020.3OxygenDelignification0.3 x 0.02 = 0.0060.3PaperMachine0.20.2WastewaterTreatment System2.11.4Total2.32.2CCAExample(BleachedMill)CCA emissions are below baseline emissions withbrownstock washer gas collection and treatment.= baseline= CCAOOxygenDelignification(OD)98%ReductionRequired0.3CCA0.3PulpPulpAdditional Condensates in Hard PipeAdditionalTreatment3BrownstockWasherPaperMachineWastewaterTreatmentPulpWastewaterEffluentDischargeContaminatedCondensateCleanCondensateCCA98%ReductionRequired0.31.1CCA0.51.0CCABaselineEmissions1.42.1BaselineHAPEmissionswithMACTControls,lb/tonCCAHAPEmissions,lb/tonBrownstock Washer1.1 x 0.02 = 0.020.3PaperMachine1.00.5WastewaterTreatment System2.11.4Total3.12.2CCA emissions are below baseline emissions withbrownstock washer gas collection and treatment.= baseline= CCABaselineEmissionsPulpAdditionalTreatmentAdditional Condensates in Hard PipeCCAExample(UnbleachedMill)CCAComplianceStrategiesreportedinthe2011ICR4•38millscomplywithMACTIPhase2usingCCA–FacilitieswithcleanercondensatesonBSWshowerseither•Over‐collectcondensatesfortreatmentinSteamStrippersOR•RouteadditionalcondensatestotheASBfortreatment–20millsutilizeadditionalhardpipingofcondensatesand/oradditionaltreatmentinASB•OverandaboveMACTIPhaseIrequirements•ForCCAmills,collectionandtreatmentlevelsreportedinthe2011ICRreflectongoingcompliancewithMACTIPhase1andCCA–InappropriatetoattributethesenumberstoMACTIPhase1treatmentrequirements

# Impact of Additional Treatme nt & Collection for CCA Mills

This example is for a bleached mill that se lected the collection and treatments options

as follows: collect 11.1 lb/ODTP and treat 10.2 lb/ODTP.

MACT I Phase

The Mill identified the streams necessary to meet the collect ion and treatment

standards. In order to include a margin of safety, the Mill collected enough streams to

average 12 lb/ODTP and thus was over collecting condensates by 0.9 lb/ODTP.

MACT I Phase II

The Mill determined that collecting HVLC str eams would not be the most efficient or

cost effective approach. Rat her, they determined they woul d prefer to select another

option (i.e., projects that reduce the concent ration of hazardous air pollutants in process

water before the process equipment emit s the HAP), also known as the Clean

Condensate Alternat ive (CCA).

The Mill determined what the reduction in emissi ons would be if they were to collect the

HVLC streams and then developed an alternat e approach to show the reductions would

be greater using the alternat e approach. It is noted that the basis for CCA credit

calculations are from HAP emission reductions and not mass of condensate collected.

Impact of Requirement to Colle ct & Treat Additional Streams

It is noted for these options, t hat what was collected in MACT I Phase I was set as the

baseline and the facility could not take credi t for over collection during this phase.

Therefore, 12 lb/ODTP was the baseline and the Mill had to implement additional

options to offset not collecting the HVLC streams identified in the rule 1 

# . Collection of the

streams that contained the excess 0.9 lb/ODTP in essence became a requirement.

Collection Requirement under Subpart S 11.1 lb/ODTP

Baseline Collection for MACT I Phase I 12 lb/ODTP

New Collection Requirement under

Subpart S 12.8 +

(Assume collection requirement is 13.6

lb/ODTP)

In the proposed rule bleached mills must treat 12.8 lb/ODTP based on 94% treatment

efficiency which would require collection over the 12.8 lb/ODTP. For this example, any

1 

# Letter from R. Douglas Neeley, EPA Region IV, to Larry Webber, Georgia EPD, March 27, 2003. “Any

extra streams or additional mass of condensate used as an operating cushion, or for determine the need

for flexibility provided by a longer averaging time ca nnot be used as credit for the CCA, since it was

granted and used to meet the co llection requirements of 63.446.”

# collection requirement over 12 lb/ODTP woul d then eliminate the credits gained during

CCA and the Mill would need to identify additional options to meet the new collection

standard and/or collect the gases from HVLC streams.

It is noted that the breakdown of the CCA compliance approach is likely for all CCA Mills

even if only the treatment requirement is altered from 10.2 lb/ODTP for bleached mills to

10.4 lb/ODTP (94% of 11.1 lb/ODTP collect ion requirement) as the mill will need to

ensure collection of enough condensates to consistently meet the new treatment

requirement. The Mill may not have other st reams available for collection and therefore

may need to utilize streams collected for CCA; thus voiding this compliance approach.

In the ICR responses received by EPA, 38 out of 97 mills (39%) utilized the CCA

compliance approach for MACT I Phase II. For most of thes e Mills, over collection of

condensates is “required” due to the CCA a pproach and how baseline conditions were

established in MACT I Phase II. Based on t he information in Table 1 in the October 20,

2011 Memo from John Bradfield and Kelley Spence, EPA to the Docket (EPA-HQ-OAR2007-0544), it appears that only 4 mills did not utilize collection of additional condensate

streams or clean water substitution for CCA implementation. This means that

approximately 35% of all Mills subject to th e standard would be requi red to modify their

compliance approach for MACT I Phase II. This would most likely mean collecting

HVLC gases at a cost of $15 M per Mill 2 

# or $510 M across the industry.

2 

# This capital cost assumes that the Mill is only r equired to install ductwork for treatment to a single

control device (the 4% HVLC vent allo wance remains.) Data is not available to estimate O&M costs. It is

noted that Mills may require additional expenditures for compliance if require to treat to 94% (or its

equivalent) and collect additional condensate streams).Cost Estimates of ProposedCondensate Treatment Requirements1Cost Impacts of Proposed Rule Changes –Condensate Collection & Treatment2DescriptionCapital CostStripper Upgrades$43 MAeration$11 MHVLC Collection Systems$510 MCost to Modify Compliance Approach$91 MTOTAL Capital Cost$655 MAssumptions:1. Only the Eight Steam Strippers Identified by EPA will need upgrades2. 1/3 of Mills that Utilize Biological Treatment will each need to install ten 75-hp motors3. 34 of the 38 CCA Mills will need to install HVLC Controls (CCA demonstration willnot be possible.4. Costs are for increased treatment from 92 to 94% only5. Costs do not include additional O&M Costs which could be in excess of $27 M/yr6. If additional condensate collection is alsorequired, lb/ODTP collection mills wouldprobably modify their collection strategyto 65% collection at a capital cost of$1M/facility or a total of $91 M for the industry7. Costs do not include increase water use required for Hardpipe Mills (~ 3-5 MGD)Cost Estimates of Potential Changesin Emission Allowances3Cost Impacts of Proposed Rule Changes – Removal ofVenting/Stripper Downtime Allowances4DescriptionCapital CostHVLC Backup Control System$485 MRedundant HVLC/LVHC SourceCollection Systems$730 MBack-up Stripper Installation$555 MTOTAL Capital Cost$1,770 MAssumptions:1. HVLC Backup Control Systems are for ductingand associated equipment. It is assumedthat the facility has another potential HVLC control device.2. All HVLC/LVHC collection systems will need tobe duplicated to collected gases fromindividual sources without venting.3. All facilities that utilize strippers as the condensate control device will need to installanother unit for backup control.4. Costs do not include increase water use required for Hardpipe Mills (~ 3-5 MGD)Potential Modifications of Venting/StripperDowntime Allowances56`Allowanceswerepartoffloordeterminations`Modelresultsshowacceptableriskswhichincludedventingemissions`LVHC/HVLCcollectionsystems`Concentration&Flowaredifficulttomeasureandvarybetweensourcesandbetweenfacilities(dependentuponmanyfactors).SafetyIssues/pressurerelief– ventsarenot“malfunctions”butapartofthesystemdesign`Somecontroldevicescannothaveventlesstransferforsafetyreasons(i.e.,ThermalOxidizers,Kilns,RecoveryFurnaces)`MostHVLCsystemsdonothaveabackupcontroldevice`DatacompiledbyEPA(BethPalmaspreadsheet)doesnotcontaindetailsforventsasrequestedinthepreamble`Immediateshutdowns(ratherthanorderly)toceaseventingcouldhavegreaterenvironmentalimpact(Emissions,WWTS,SolidWaste)`Strippers`FacilitiesdonothavebackupstrippersorsufficientstoragethatwouldaccommodatelackofastripperdowntimeallowanceTechnical Issues Surrounding Allowances7`GatherDatainresponsetoEPApreamblequestions`Whatarethereasons,frequency,anddurationforvents`Howareventsmeasuredandmonitored`Whatworkpracticesarecurrentlyinplacetoreduceemissions`WhatarethecircumstanceswhereallowanceshavebeenreliedonanddotheyincludeSSMeventsandhowfrequentlyaretheallowancesused`Technicalnecessityforreleases`Timetoswitchbetweencontrolsystemsandifventingisnecessary`DevelopPossibleSolutions`CanVentAllowancesRemain(legalissue)`Whatarepossiblesolutionsthatinvolvenarrowingtheexistingprovisions(i.e.,whentheywouldapply)`NumericalStandards– Canwecalculateventingreleaseratesanddevelopastandardbasedonthatinformation`IdentifyPotentialWorkPracticesbasedonindustrydata`IsamodificationintheaveragingperiodpracticalandapossiblesolutionAdditional Time Needed

# Potential Removal of Excess Emission Allowances from Pulp and

Paper Industry NESHAPs

December 12, 2011

National Emission Standards for Hazardous Air Pollutants for the Pulp and Paper

Industry, 40 C.F.R. Part 63 Subpart S, require that various processes in the pulp mill be enclosed

and vented into a closed-vent system and routed to a control device. The regulations provide

that periods of excess emissions must be reported but will not be considered a violation if, for

each semi-annual reporting period, the time of excess emissions (excluding periods of startup,

shutdown, or malfunction) divided by the total process operating time does not exceed 1% for

control devices used to reduce emissions from the low volume, high concentration system and

4% for control devices used to reduce emi ssions from the high volume, low concentration

system (or used for both LVHC and HVLC sy stems). 40 C.F.R. § 63.443(e). For control

devices used to treat pulping process condens ates (wastewaters) from specified pulp mill

processes, the excess emissi on allowance (including periods of startup, shutdown, or

malfunction) is 10%. 40 C.F.R. § 63.446(g). In addition to continuous monitoring of the

control devices, the regulations require indicators on closed-vent system bypass lines, periodic

inspections for leaks, procedures for prompt re pair of defects in the enclosures or piping,

inspection and maintenance r ecordkeeping, and so forth.

In the course of conducting the eight-year review of developments in control

technologies under Clean Air Act section 112(d)(6) and the residua l risk review under Clean Air

Act section 112(f) for the Pulp and Paper categor y, EPA has indicated recently that it plans to

propose to eliminate the excess emission allowan ces in 40 C.F.R. § 63.443(e) and 40 C.F.R. §

63.446(g). It would be improper and unlawful to do so, for the reasons set forth below.

Emission standards incorporating the exce ss emission allowance represent the Maximum

Achievable Control Technology

The excess emission allowance provisions in the current Subpart S regulations reflects

EPA’s careful determination, afte r years of study of a large quantity of emissions information

and public comments, that th e “MACT floor,” representing the emissions of the “best

performers,” includes emissions during unavoida ble periods of releas es of uncontrolled or

partially controlled pulping process vent ga ses and unavoidable sewe ring of untreated or

partially treated pulping process condensates. See 63 Fed. Reg. 18,504, 18,529 (April 15,

1998). “EPA established appropriate excess emi ssion allowances to approximate the level of

backup control that exists at the best-performing mills and the associated period of time during

which no control device is available.” Id . After “an analysis of the public comments and the

available data regarding excess emissions and th e level of backup contro l in the industry,” EPA

determined that the “best-performing mills achieve a one percent downtime in their LVHC

system control devices” and “best-performing mills achieve a four percent downtime in the

control devices used to reduce emissions from their HVLC system to account for flow balancing

problems and unpredictable pressure change s inherent in HVLC control systems.” Id . “The

allowances address normal opera ting variations in the LVHC a nd HVLC system control devices

for which the equipment is designed. The variat ions would not be consid ered startup, shutdown,

or malfunction under the Part 63 General Pr ovisions....” 63 Fed. Reg. at 18,530. The 10

# 2 percent excess emission allowance for steam strippers systems “accounts for stripper tray

damage or plugging, efficiency losses in the stri pper due to contamination of condensate with

fiber or black liquor, steam supply downtime, and combustion control device downtime.” Id

.

EPA adopted the excess emission allowances after reviewing extensive data from

continuous monitoring systems and consideri ng industry comments that although some mills

had backup combustion devices as part of their LVHC control system, venting of pulping gases

is an essential safety practice (because of thei r explosion hazard) even for those systems with

backup control devices, since the startup of, and tr ansfer of vent gases to, the backup controls

cannot be immediate or automatic for safety reas ons, and operating variab ility in the control

devices themselves was unavoidable for process and other reasons. See, e.g., Pulp, Paper and

Paperboard Industry – Background Information fo r Promulgated Air Emission Standards – Final

EIS, EPA-453/R-93-050b (October 1997) (“BID”) at 4-81, 4-82 to 4-84. For HVLC systems,

few mills had backup controls that could handle th e large volume of vent gases, so any standard

that required the use of backup devices would ha ve been beyond the MACT floor and would not

have been cost-effective due to the low concentra tion of pollutants in the large gas stream. See

63 Fed. Reg. at 18,529; BI D at 4-81 to 4-82.

In short, the MACT determinations that EPA made when promulgating the Subpart S

emission standards correctly concluded that available technology involves unavoidable periods

where not all vent gases or condensates can be routed to the control device, and/or when the

control device is inoperable or necessarily operating at a reduced rate. Th e Subpart S emission

standards (including the excess emission allowan ces) were designed to reflect the performance

of the MACT technology and the actual performa nce of the “best performing” mills. Without

the excess emission allowances, the remainder of the Subpart S emissions standards would

impose limitations not achieved even by the “best performers” and not demonstrated as

achievable at any facility. This plainly is not what Congress intended. See, e.g., Sierra Club v.

EPA , 353 F.3d 976, 980 (D.C. Cir. 2004).

EPA has no technical justification for el iminating the excess em ission allowances

EPA is supposedly carrying out Congress’ di rective in Clean Air Act section 112(d)(6)

that, at least every eight years, EPA review whether “developments in practices, processes, and

control technologies” nece ssitate revision of MACT emissions standards. Nothing has changed

about the technology available to control volatile HAP emissions at pulp mills that eliminates

the unavoidable excess emission the events that EPA accurately described when promulgating

the current MACT standards. Absent such ne w technology, there is no st atutory predicate for

EPA to go back and change the MACT standards at this time. Cf

. NRDC v. EPA , 529 F.3d

1077, 1084 (D.C. Cir. 2008) (rejectin g contention that CAA sec tion 112(d)(6) requires EPA to

“start from scratch” and de velop new MACT standards).

But even if the section 112(d)(6) technol ogy review were an opportunity to secondguess and revise the existing MACT standards, EPA has no techni cal basis for eliminating the

Subpart S excess emission allowances. An agen cy cannot simply change its mind and reach a

diametrically opposed conclusion from the determina tion is made in a prior rulemaking. Rather,

EPA must demonstrate sufficient basis for changing its prior conclusions; in this case, technical

justification for concluding that mills with MACT do not exp erience the unavoidable variability

accommodated by the excess emission allowance. See, e.g., FCC v. Fox Television Stations,

# 3 Inc. , 556 U.S. 502, 129 S. Ct. 1800, 1811 (2009) (“a reasoned explanation is needed for

disregarding facts and circumstances that underlay...the prior policy”); Transactive Corp. v.

United States , 91 F.3d 232, 237 (D.C. Cir. 1996).

Nor is there any health or environmental im perative for eliminating the excess emission

allowances in Subpart S. EPA has just complete d an assessment of the risk to human health and

the environment from emissions in compliance with Subpart S, for its “residual risk” review.

The tentative conclusion of that assessment is that there is no significant risk from those

emissions, including excess emissions allowed unde r the Subpart S regulation. (The emissions

data that EPA used in its risk modeling included emissions during bypassing of control

equipment or other excess emissions covered by the Subpart S excess emission allowances.)

Intervening court decisions do not justify eliminating the excess emission allowances

The Subpart S NESHAPs were never judicial ly challenged, and the time for such a

challenge under CAA section 307(b) has long passe d. Even if there were some portion of an

opinion in one of the many cases challenging othe r NESHAPs that was contrary to the approach

EPA took in promulgating the Subpart S NESHAP s, that would not provide a means nor a

justification for reopening the Subpart S standard s that were never challenged on that grounds.

But in any event, none of the holdings in thos e other cases undercuts EPA’s determination to

include the current excess emission allo wances in the Subpart S regulations.

EPA may believe that elimination of the excess emission allowances is justified or

required by the D.C. Circuit’s decision in Sierra Club v. EPA , 551 F.3d 1019 (D.C. Cir. 2008),

cert. denied , 130 S. Ct. 1735 (2010), which vacated the “exemption” for excess emissions

during SSM events contained in the 40 C.F.R. Part 63, Subpa rt A General Provisions for

emission standards for hazardous air pollutants. The D.C. Circuit’s Sierra Club decision does

not, however, compel or even support EPA’s retr oactive elimination of the Subpart S excess

emission allowances.

First, the Sierra Club decision interpreted the NESHAP s General Provisions, not the

Subpart S NESHAPs or indeed any categorical NESHAPs. Secondly, the decision addressed an

exemption for startups, shutdowns, and malf unctions, while the Subpart S excess emission

allowance for pulping vent gases specifically does not address excess emissi ons during startup,

shutdown, and malfunction (and the allowance for pulping condensates only covers such events

because EPA did not have data to distinguish those situations from “normal stripper operating

emissions”). See 72 Fed. Reg. at 18,529-30.

Thirdly, the Sierra Club decision rejected the General Provisions’ bla nket, open-ended

exemption for emissions during startup, shutdown, and malfunction periods, finding it to be

inconsistent with Congress’s in tention that “there must be continuous section 112-compliant

standards” for sources subject to MACT standards, rather than periods where no standard of any

kind applies. See 551 F.3d at 1027. The Sierra Club opinion did not addre ss a situation, such as

the Subpart S standards, where EPA finds that the MACT standa rd, which applies continuously,

must account for periods of higher emissions during unavoidable operational variability to

accurately reflect the available technol ogy and the best performers’ emissions.