1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

SECTOR POLICIES AND PROGRAMS DIVISION

OFFICE OF AIR QUALITY PLANNING AND STANDARDS

OFFICE 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 Risk and Technology Review (RTR) of the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) for the pulp and paper industry. Meeting handouts are

attached.

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 Torres, 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
EPA Handouts
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 – possible 

mathematical inconsistency

o ICR data and initial performance tests

o Fbio variability

o Stripper capacity and operational limitations at higher levels

o Data quality review 

• Cost impacts 

Emission Allowances (30 minutes) 

• Questions in preamble – understand what 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)

• Condensate 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
AF&PA Handouts
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 Fbio 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 period 

1
Equivalency Calculation used by 

• % Improvement in Standard when treatment was incre

from 92% to 94%

– 2% of the maximum possible 8% in improvement is achieved: OR 2/8 = 25% 

remaining possible treatment

– i.e., 25% of the remaining possible treatment is achieved

• The % Improvement in Standard for each 1% increase in

treatment efficiency (from 93% to 98%) was calculated

– At 93% ‐ 1% of max possible 8% = 1/8 = 12.5%

– At 94% ‐ 2% of max possible 8%: 2/8 = 25%

– At 95% ‐ 3/8 = 37.5%

92% 

% Treatment Scale

94% 96% 98%

Max Improvement

Possible = 8%

Improve to 94% = 2%

8%

2%
Equivalency Calculation used by 

• Percentage Improvements in standard were directly applied a

to scale up the lb/ODTP treatment limit from the current as fol

Recalculated Numerical Limits (lb/ODTP)

% Treatment

(% control

improvement)

Multiplication

Factor Used Bleached Mills Unbleached Mills

92% 10.2 6.6

93% (12.5%) 1.125 11.5 (= 10.2 x 1.125) 7.4 (= 6.6 x 1.125)

94% (25%) 1.250 12.8 (= 10.2 x 1.25) 8.3 (= 6.6 x 1.25)

95% (37.5%) 1.375 14.0 9.1

96% (50%) 1.500 15.3 9.997% (62.5%) 1.625 16.6 10.798% (75%) 1.750 17.9 11.6

` This approach of converting to the lb/ODTP scale is incorrect

` Does not account for what the maximum level of treatment ac

the 100% removal level

` Results in lb/ODTP standards greater than current collection l
Applying the percent standar

improvement to recalculate num

standards

• The percent standard improvement metric can be 

recalculate numerical standards as follows

– At 100% ‐ Collection levels are 7.2 lb/ODTP and 11.1 lb/ODTP (un

bleached respectively)

– At 92% ‐ Treatment levels are 6.6 lb/ODTP and 10.2 lb/ODTP

– For instance, 25% of the remaining possible treatment is achieve

the standard from 92% to 94%

• 6.6 + 25% of (7.2 – 6.6) = 6.8 lb/ODTP ‐ unbleached mills• 10.2 + 25% of (11.1 – 10.2) = 10.4 lb/ODTP ‐ bleached mills

% Treatment Scale 98% 92% 

lb/ODTP (Unbleached) 6.6 lb/ODTP (Bleached) 10.2 

94% 96%

New limits at 94% Eff. 6.8 lb/ODTP

10.4 lb/ODTP

CurrentTreatment
 

January 11, 2012 

GENERATION AND HANDLING OF CONDENSATES 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 regulations as a part of its review of these 

regulations to consider improvements in control technology and residual risks to the potentially 

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

requirements. Recent industry discussions with EPA of the condensate collection 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 areas 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 chips are cooked with white liquor in batch or continuous digesters 

which are maintained at elevated temperature and 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 cooking chemicals recovered from pulp washing are 

recovered, concentrated, and burned in a recovery furnace to produce 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 during the cook. This stream is cooled to produce 

batch digester relief steam condensate. It is possible to condense this steam in two or more 

stages to produce segregated 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 turpentine decanter system, 

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

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

5
2 

January 11, 2012 

where great quantities of steam, and some methanol, 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 fraction 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 digester. 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 steam 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 incoming 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, these 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 sent to multiple-effect evaporators for increasing 

its solids content prior to burning in the recovery 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 subjected 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 methanol. This water vapor, along with the methanol, 

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

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

streams of condensates. 

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

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

much lower. 

6
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 vacuum 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 levels 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 containing 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 condense. 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 boiling 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 materials occurs when condensates from different 

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

be baffled to segregate rich and lean condensates, 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 factors, namely temperature, pressure and the 

relative amounts of water and methanol in the gas stream. For 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 noncondensible gas (NCG) systems to collect and burn the reduced sulfur 

gases from the digesters and evaporators. Although 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 the system. Again, although the NCG system 

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

compounds. 

7
Pu

Relief 

Steam 

Condenser

NCG

Relief 

Steam

Batch 

Digester

Blow Tank

Blow Steam

Pulp & Liquor

Washers

Liquor to Evapora

Relief Steam 

Condensate

Figure 1

Batch Digester System
Relief Steam Condensates 

and/or 

Flash Steam Condensates

Turp

Turpentine 

Decanter

Turpentine Decanter

Underflow

(Foul Condensate)

Figure 2

Turpentine Recovery
SeconConde

NCG to LVHC

PrimaryCondenser

Overflow

Accumulator

Condensing 

Water

Blow Steam

Batch Digester Blow 

Steam Condensate 

(Foul Condensate)

Note: It is possible to design and operate this system so that only the 

secondary condenser condensate is foul condensate.

Figure 3

Blow Steam Condensers
Relief 

Steam 

Condenser

NCG to LVHC

Pulp & 

Liquor

Washers

Liquor to E

Continuous Digester 

Flash Steam 

Condensate

(Foul Condensate)

Cooking Chemic

Steaming Vessel Chips

Flash Steam

#1

#2

Flash Tanks

Flash 

Steam Digester

Hot

Liquor

Figure 4

Continuous Digester System
Steam Steam Steam 

SC

Rich Stream

Liquor Liquor Liquor

Condensate Condensate

#4 #5 #6

Evaporator

Foul Condensate

Combined 

Condensates

(100 ppm MeOH)

Weak Black

Liquor Feed

LeanStream

Steam

Figure 5

Multiple-Effect Evaporators

Showing only last 3 effects of 6 effects
Hotwell

NCG

After

Condenser

InterCondenser

From Surface

Condenser

High Pressure Steam

Eva

Vacuu

Cond

(Foul Co

Figure 6

Evaporator Vacuum System
Incoming

Water/Methanol

Vapors Primary Condenser Seco

Cond

Clean Condensate

Water 200,000

MeOH 200

1000 ppm

Foul Condensate

Water 80,000 28%MeOH 450 69%

5600 ppm

Water 280,000

MeOH 650

Figure 7

Condensate Segregation

Typical 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 stripping (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 collection and treatment at all sources (TB 661). 

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

pulp mills, collected on an average 11.1 lb methanol/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 should accommodate mills which 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, provides 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 rule include the following: (1) return 10.2 lb 

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

(3) remove 10.2 lb methanol/ODTP (6.6 for unbleached) 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 treatment 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. Thus for hard piping mills the effective 

treatment requirement is 94% treatment. 

15
January 11, 2012 

Not All Condensate Streams Are Created Equal. 

16
Collection & Treatment Options

Collection Options Treatment Option

1

` Collect all Named Streams, 

or

` Collect 65% of Named 

Streams & LVHC/HVLC condensates, or

` Collect 11.1 / 7.2 lb/ODTP

` Treat to 92%, or` Treat 10.2 / 6.6 lb

or

` Achieve 330 / 210 

the outlet of the device
The Pulp and Paper NESH

RTR R

1. Equivalency Calculation used to Establish Numerical

lb/ODTPTreatment Limits for Kraft Process Condensa

2. Clean CondensateAlternative (CCA) in Brief

a. Compliance Strategies for CCA millsb. Over‐collection and Over‐treatment for CCA compli

3. MACT I Phase I Kraft CondensateTreatment Reporting 

the 2011 ICR – Other Considerations

a. Variability (seasonal and operational) in

Fbio data

b. Steam Stripper Performance datac. The need for compliance marginsd. Flexible Compliance Options (lb/ODTP or

% remova

Industry Group Mee

Jan

1
Equivalency Calculation used by E

`

% Improvement in Standard when treatment was increased 

to 94%

` 2% of the maximum possible 8% in improvement is achieved: OR 2/8

= 25

remaining possible treatment

` i.e., 25% of the remaining possible treatment is achieved

` The

% Improvement in Standard for each 1% increase in trea

efficiency (from 93% to 98%) was calculated

` At 93% ‐ 1% of max possible 8%

= 1/8

= 12.5%

` At 94% ‐ 2% of max possible 8%: 2/8

= 25%

` At 95% ‐ 3/8

= 37.5%

92% 

% Treatment Scale

94% 96% 98%

Max Improvement

Possible

= 8%

Improve to 94%

= 2%

8%

2%

2
Equivalency Calculation used by E

3

` Percentage Improvements in standard were directly applied as F

scale up the lb/ODTP treatment limit from the current as follows:

Recalculated Numerical Limits (lb/ODTP)

% Treatment

(% control

improvement)

Multiplication

Factor Used Bleached Mills Unbleached Mills

92% 10.2 6.6

93% (12.5%) 1.125 11.5 (= 10.2

x 1.125) 7.4 (= 6.6

x 1.125)

94% (25%) 1.250 12.8 (= 10.2

x 1.25) 8.3 (= 6.6

x 1.25)

95% (37.5%) 1.375 14.0 9.1

96% (50%) 1.500 15.3 9.997% (62.5%) 1.625 16.6 10.798% (75%) 1.750 17.9 11.6

` This approach of converting to the lb/ODTP scale is incorrect

` Does not account for what the maximum level of treatment ac

the 100% removal level

` Results in lb/ODTP standards greater than current collection l
Applying the percent standard improv

to recalculate numerical standards` The percent standard improvement metric can be 

recalculate numerical standards as follows

` At 100% ‐ Collection levels are 7.2 lb/ODTP and 11.1 lb/ODTP (unbl

bleached respectively)

` At 92% ‐Treatment levels are 6.6 lb/ODTP and 10.2 lb/ODTP` For instance, 25% of the remaining possible treatment is achieve

the standard from 92% to 94%

` 6.6 + 25% of (7.2 – 6.6) = 6.8 lb/ODTP ‐ unbleached mills` 10.2 + 25% of (11.1 – 10.2) = 10.4 lb/ODTP ‐ bleached mills

% Treatment Scale 92% 98% 

lb/ODTP (Unbleached) 6.6 lb/ODTP (Bleached) 10.2 

94% 96%

New limits at 94% Eff. 6.8 lb/ODTP

10.4 lb/ODTP

Current Treatment

4
` Alternate approach to directly compute new limits fro

Current Collection numbers

` 7.2 lb/ODTP x 0.94 = 6.8 lb/ODTP for unbleached mills` 11.1 lb/ODTP x 0.94 = 10.4 lb/ODTP for bleached mills

% Treatment Scale 92% 98% 

lb/ODTP (Unbleached) 6.6 lb/ODTP (Bleached) 10.2 

94% 96%

New limits at 94% Eff. 6.8 lb/ODTP

10.4 lb/ODTP

Current Treatment

5

Recalculating numerical standards –Alternate Approach
6

` Reductions in annual HAP emissions claimed by EPA are 4000 t

` The reduction based on 97 mills operating 355 days/yr and 1000 OD

0.2 lb HAP/ODTP. This calculation is consistent with the 94% treat

requirement for lb/ODTP based on current collection requirementsthe proposed limits.

Additional Calculation Inconsistencies in the Preamble to the Rule

All numbers in lb/ODTP Bleached UnbCollection Requirement 11.1 Current Proposed Treatment Requirement

10.2 

Proposed Requirement 12.8 Increase in Treatment Requirement 2.6 

Requirement based on 94% of current collection requirement

10.4 

Increase in Treatment Requirement 0.2 
Using the 2011 ICR Responses to Ide

Improvements in Operating Prac

- Other Considera

7
2011 ICR responses on treatment efficiencies also 

safety margins and compliance with other standar

8

` Methanol Biodegradation (Fbio, MeOH

) in ASBs

` Limited data from

4 quarterly performance tests (RY 

` Excluding process upsets, median “intra‐facility” variabilit

MeOH was

~ 3%

` Process upsets result in higher levels of variability` Additional quarterly performance data needed to adequa

represent ongoingASB performance

` Given the inherent variability, observed treatment e

reflect safety margins required to demonstrate com

` For CCA mills, reported treatment levels reflect com

with both MACT I Phase

1 and CCA

` Need to decouple the two in order to identify treatment l

associated with MACT I Phase

1 compliance
Hardpipe Mills: Relationship between Fbio me

and Fbio adjusted

9

` Hardpipe Mills have established an ‘r’ factor to a

for the treatment of non

‐methanol HAPs

` ‘r’ factors are approximately 0.02

` Demonstrate compliance with treatment require

either using lb/ODTP removed or an adjusted

Fb

` Adjusted

Fbio of 92% is equal to

Fbio of methanol of 94

`

Fbio adjusted

=

Fbio methanol

/ (1 +1.087r)

` At the new treatment level of 94%,

Fbio methano

need to be approximately 96%
10

` Percent treatment efficiencies for steam strippe

` Limited data from initial performance tests

` Indicative of steam stripper performance immediately fol

installation or scheduled maintenance

` Includes compliance margins built into steam stripper des

` Data from ongoing performance tests essential to ac

drifts in steam stripper operating efficiency

` Reflective of ongoing compliance and operational drifts d

maintenance cycle

` A more stringent percent removal standard would im

compliance margins

2011 ICR responses on treatment efficiencies also safety margins and compliance with other standar
11

` Higher than required lb/ODTP collection numbe

` Reflects compliance with Phases 1 and 2 for CCA mil

condensate over‐collection as part of the complianc

` Reflects the need for flexible compliance options as

promulgated in the 1998 NESHAP

` “lb/ODTP removed” OR “percent removal” compliance op` Enables facilities to comply with requirements even if % r

drops below 92%

2011 ICR responses on treatment efficiencies also safety margins and compliance with other standar
Impact of the current RTR Proposal on 

compliance

12

94% treatment level AND/OR revised lb/ODT

standards

` Facilities over

‐collecting and over

‐treating conde

in Steam Strippers or ASBs would lose

a portion 

resulting emission credits

` Insufficient emission credits to demonstrate complia

under CCA

` Compliance option would likely involve the insta

HVLC collection systems` Capital costs of up to $15 – 20 million

/ installation
The Clean Condensate Alternative (C

1
Brownstock 

Washer

(BSW)

Paper 

Machine

Wastewater 

Treatment

Pulp Wastewater 

Contaminated 

Condensate

Clean 

Condensate

CCA

98%

Reduction

Required

0.3

1.1 CCA

Baseline

Emissions

0.2 0.2

CCA

Baseline

Emissions

1.4

2.1

Source

Baseline HAP Emissions

with MACT Controls,

lb/ton

CCA HA

Emissio

lb/ton

Brownstock Washer 1.1 x 0.02 = 0.02 0.3

Oxygen Delignification 0.3 x 0.02 = 0.006 0.3

Paper Machine 0.2 0.2

Wastewater Treatment System 2.1 1.4

Total 2.3 2.2

CCA Example (Bleached Mill)

CCA emissions are below baseline emissions with brownstock washer gas collection and treatment.

O

Oxygen

Delignification

(OD)

98%

Reduction

Required

0.3

CCA

0.3

Pulp

Pulp

Additional Condensates in Hard Pipe

Additional 

Treatment
Brownstock 

Washer

Paper 

Machine

Wastewater 

Treatment

Pulp Wastewater 

Contaminated 

Condensate

Clean 

Condensate

CCA

98%

Reduction 

Required

0.3

1.1

CCA

0.5

1.0

CCA

Baseline

Emissions

1.4

2.1

Baseline HAP Emissions

with MACT Controls,

lb/ton

CCA H

Emissio

lb/to

Brownstock Washer 1.1 x 0.02 = 0.02 0.3

Paper Machine 1.0 0.5

Wastewater Treatment System 2.1 1.4

Total 3.1 2.2

CCA emissions are below baseline emissions with brownstock washer gas collection and treatment.

Baseline

Emissions

Pulp Additional 

Treatment

Additional Condensates in Hard Pipe

CCA Example (Unbleached Mill)
CCA Compliance Strategies repor

the 2011 ICR

• 38 mills comply with MACT I Phase 2 using CCA

– Facilities with cleaner condensates on BSW show

• Over‐collect condensates for treatment in Steam Stripp

• Route additional condensates to the ASB for treatment

– 20 mills utilize additional hard piping of condensa

and/or additional treatment in ASB

• Over and above MACT I Phase I requirements

• For CCA mills, collection and treatment levels r

in the 2011 ICR reflect ongoing compliance wit

I Phase 1 and CCA

– Inappropriate to attribute these numbers to MAC

1 treatment requirements
Impact of Additional Treatment & Collection for CCA Mills 

This example is for a bleached mill that selected 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 collection 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 streams would not be the most efficient or 

cost effective approach. Rather, they determined they would prefer to select another 

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

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

Condensate Alternative (CCA). 

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

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

be greater using the alternate 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 Collect & Treat Additional Streams 

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

baseline and the facility could not take credit 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 rule1

. 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 cannot be used as credit for the CCA, since it was 

granted and used to meet the collection requirements of 63.446.” 

34
collection requirement over 12 lb/ODTP would 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 collection 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 streams 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 these Mills, over collection of 

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

established in MACT I Phase II. Based on the 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 the standard would be required 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 Mill2

 or $510 M across the industry. 

                                                            

2

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

control device (the 4% HVLC vent allowance 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). 

35
Cost Estimates of Propo

Condensate Treatment Requireme

1
Cost Impacts of Proposed Rule Chang

Condensate Collection & Treatment

2

Description Capital Cost Stripper Upgrades $43 MAeration $11 MHVLC Collection Systems $510 MCost to Modify Compliance Approach $91 MTOTAL Capital Cost $655 M

Assumptions: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 75-3. 34 of the 38 CCA Mills will need to install HVLC Controls (CCA demonstr

not 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 $2

6. If additional condensate collection is also required, lb/ODTP collection mill

probably modify their collection strategy to 65% collection at a capital cost $1M/facility or a total of $91 M for the industry

7. Costs do not include increase water use required for Hardpipe Mills (~ 3-5 
Cost Estimates of Potential Chan

in Emission Allowan

3
Cost Impacts of Proposed Rule Changes – Rem

Venting/Stripper Downtime Allowances

4

Description Capital Cost HVLC Backup Control System $485 MRedundant HVLC/LVHC Source Collection Systems

$730 M

Back-up Stripper Installation $555 MTOTAL Capital Cost $1,770 M

Assumptions:1. HVLC Backup Control Systems are for ducting and associated equipment. 

that the facility has another potential HVLC control device.

2. All HVLC/LVHC collection systems will need to be duplicated to collected g

individual sources without venting.

3. All facilities that utilize strippers as the condensate control device will need 

another unit for backup control.

4. Costs do not include increase water use required for Hardpipe Mills (~ 3-5 
Potential Modifications of Venting/Stri

Downtime Allowa

5
6

` Allowances were part of floor determinations` Model results show acceptable risks which included venting em` LVHC/HVLC collection systems

` Concentration & Flow are difficult to measure and vary between so

between facilities (dependent upon many factors). Safety Issues/pr

– vents are not “malfunctions” but a part of the system design

` Some control devices cannot have ventless transfer for safety reas

Thermal Oxidizers, Kilns, Recovery Furnaces)

` Most HVLC systems do not have a backup control device` Data compiled by EPA (Beth Palma spreadsheet) does not contain 

vents as requested in the preamble

` Immediate shutdowns (rather than orderly) to cease venting could 

environmental impact (Emissions,WWTS, SolidWaste)

` Strippers

` Facilities do not have backup strippers or sufficient storage that wo

accommodate lack of a stripper downtime allowance

Technical Issues Surrounding Allowan
7

` Gather Data in response to EPA preamble questions

` What are the reasons, frequency, and duration for vents` How are vents measured and monitored` What work practices are currently in place to reduce emissions` What are the circumstances where allowances have been relied on 

include SSM events and how frequently are the allowances used

` Technical necessity for releases` Time to switch between control systems and if venting is necessary

` Develop Possible Solutions

` CanVent Allowances Remain (legal issue)` What are possible solutions that involve narrowing the existing pro

when they would apply)

` Numerical Standards – Can we calculate venting release rates and d

standard based on that information

` Identify Potential Work Practices based on industry data` Is a modification in the averaging period practical and a possible so

Additional 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 emissions from the high volume, low concentration 

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

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

processes, the excess emission 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 repair of defects in the enclosures or piping, 

inspection and maintenance recordkeeping, 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 residual risk review under Clean Air 

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

propose to eliminate the excess emission allowances 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 excess emission allowance represent the Maximum 

Achievable Control Technology 

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

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

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

performers,” includes emissions during unavoidable periods of releases of uncontrolled or 

partially controlled pulping process vent gases and unavoidable sewering of untreated or 

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

1998). “EPA established appropriate excess emission 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 the level of backup control 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 changes inherent in HVLC control systems.” Id. “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....” 63 Fed. Reg. at 18,530. The 10 

43
2

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

damage or plugging, efficiency losses in the stripper 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 considering 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 their explosion hazard) even for those systems with 

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

cannot be immediate or automatic for safety reasons, and operating variability in the control 

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

Paperboard Industry – Background Information for 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 the large volume of vent gases, so any standard 

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

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

63 Fed. Reg. at 18,529; BID 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. The Subpart S emission 

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

of the MACT technology and the actual performance 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 eliminating the excess emission allowances 

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

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

control technologies” necessitate 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 new technology, there is no statutory 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) (rejecting contention that CAA section 112(d)(6) requires EPA to 

“start from scratch” and develop new MACT standards). 

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

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

diametrically opposed conclusion from the determination 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 experience the unavoidable variability 

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

44
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 imperative for eliminating the excess emission 

allowances in Subpart S. EPA has just completed 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 under 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 judicially challenged, and the time for such a 

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

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

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

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

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

include the current excess emission allowances 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, Subpart 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 retroactive elimination of the Subpart S excess 

emission allowances. 

First, the Sierra Club decision interpreted the NESHAPs General Provisions, not the 

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

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

allowance for pulping vent gases specifically does not address excess emissions 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’ blanket, open-ended 

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

inconsistent with Congress’s intention 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 address a situation, such as 

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

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

accurately reflect the available technology and the best performers’ emissions. 

45