UNITED STATES ENVIRONMEN TAL PROTECTION AGENCY

SECTOR POLICIES AND PROGRAMS DIVISION OFFICE OF AIR QUALITY PLANNING AND STANDARDS

OFFICE OF AIR AND RADIATION

Date: July 30, 2012

Subject: Ample Margin of Safety Analysis for Pulping and Papermaking Processes

From: John Bradfield U.S. Environmental Protection Agency Research Triangle Park, NC 27711

To: Pulp & Papermaking Docket [EPA-HQ-OAR-2007-0544]

As directed by section 112(f)(2), EPA conducted an analysis to determin e if the final pulp and
papermaking (40 CFR part 63, Subpart S) standa rd following our risk and technology review
provides an ample margin of safety to protect pu blic health. Under the ample margin of safety
analysis, we first considered the health impacts for the source category. In our analysis we
identified cancer risk as the most signifi cant form of residual risk remaining after
implementation of maximum achievable control t echnology (MACT) in the category. The final

risk assessment 1 identified the emission process groups in the category whose emissions resulted
in projected cancer risk in excess of one in one million and were responsible for the majority of

cancer incidence. Chronic non-cancer health im pacts the subpart S source category were less
than the target organ specific hazard i ndex threshold of concern (TOSHI of 1).

We analyzed the potential for emissions reducti ons at the emission proc ess groups responsible

for most of the residual risk within the source category by evalua ting available control
technologies and their capabilities for further reductions of the resi dual risk. We found that three
HAPs (hexachloroethane, acetaldehyde and naphthalene) emitted from three process groups
(bleaching, kraft wastewater and papermaking) were the predominant risk drivers for the chronic

cancer/non-cancer and acute residual risk and that emissions reduc tions for these pollutants and
processes would result in the most appreciable reductions in ris k. We identified technologies
that could potentially reduce cance r risk associated with kraft wa stewater from 5 to 26 percent,
and cancer risk from papermaking by 0.5 to nearly 100 percent. However, the actual emissions

reductions that could be achieved and the resulti ng risk reduction benefits are highly uncertain.
With respect to the risk from hexachloroetha ne emissions from bleaching, our review of

1 U.S. EPA. Residual Risk Assessment for the Pulp & Paper Source Category . July 2012.information provided in comments lead us to concl ude that the risk originally assessed from that
emission group is not present. See Attachment 1 for details.

Next we evaluated the potential costs, environm ental and energy impacts of additional controls
for kraft wastewater and papermaking that could potentially reduce risk. We estimated that the
cost of additional controls (e.g., steam strippers ) to reduce risk from the kraft wastewater emission source would be $163,658,750 per year at a cost effectivenes s of $353,000/ton. There
are also negative secondary air emission impacts from combustion sources needed to generate

additional steam. We estimated that the cost of additional controls to reduce risk from the papermaking source would be $21,269,385 per year at a cost effectiveness of $22,560/ton (see

Attachment 1).

These analyses represent our assessment of the highest remaining residual risk sources in the
subpart S category that have the greatest pot ential for emissions reductions and could
meaningfully reduce risk. Cons idering the cost, environmental, and energy impacts of the only
current means of further reducing risk associ ated with kraft wastew ater acetaldehyde and
naphthalene emissions (incremental condensate treatment efficiency improvement, or steam
stripping), it is our conclusion that currently there are no feasib le options for increasing the
margin of safety under CAA section 112(f)(2) fr om the kraft wastewater emissions process
group. For papermaking, two options were evaluate d for the further reduction of residual risk:
(1) a new substance review work practice, and (2) numerical emissi on limits relating to the HAP
concentration in the papermaking stock). It is our conclusion that no feasible options were
identified for reducing the emissions from fo r papermaking sources. Neither papermaking
option is cost-effective when compared to the acetaldehyde and naphthalene HAP risk reduction
that could be achieved under a section 112(f) ample margin of safety analysis. The actual risk

reductions that could be achieved with either papermaking option are highly uncertain. In
addition, there could be water usag e and wastewater impacts at m ills needing to install a screw
press to remove liquid from the papermaking st ock. Although not cost-effective under a section
112(f) analysis, the EPA intends to evaluate pape rmaking in a future sector rule proposed under
section CAA 112(d)(2) and (3) auth ority, and that evaluation coul d reach different conclusions.

Based on this analysis, we conclude that the cu rrent standard protects public health with an
ample margin of safety.Attachment 1

Ample Margin of Safety Analysis for Pulp ing and Papermaking Emission Process GroupsDate: July 25, 2012

Subject: Ample Margin of Safety Analysis for Pulping and Papermaking Emission Process Groups EPA Contract No. EP-D-11-084; Work Assignment No. 0-03

From: Katie Hanks Thomas Holloway

To: John Bradfield

Bill Schrock U.S. Environmental Protection Agency Research Triangle Park, NC 27711

I. Introduction

The purpose of this memorandum is to present information used in the ample margin of safety decision for the U.S. Environmental Protec tion Agency’s (EPA’s) residual risk review of

the national emission standards for hazardous air pollutants (NESHAP) for the Pulp and Paper Industry (40 CFR part 63, subpart S) in accordan ce with section 112(f)(2) of the Clean Air Act (CAA). The EPA proposed the subpart S residua l risk review on December 27, 2011 (76 FR 81328).

As described in the preamble to the proposed rule, CAA section 112(f)(2) refers to a twostep process for developing standard s to address residual risk. The first step in this process is the determination of acceptable risk. The second step provides for an ample margin of safety to protect public health, which is the level at whic h the standards are set (unless a more stringent standard is required to prevent, taking into cons ideration costs, energy, safety and other relevant factors, an adverse environmenta l effect). In the ample margin of safety decision process, the agency again considers all of th e health risks and other health information considered in the acceptability determination. Beyond that inform ation, additional factors relating to the appropriate level of control are also consid ered, including costs and economic impacts of controls, technological feas ibility, uncertainties and any other re levant factors. Considering all of these factors, the agency will establish the standard at a level that provides an ample margin of safety to protect the public health, as required by CAA section 112(f). (76 FR 81330-81332)

The EPA concluded at proposal that risks from the pulp and paper source category are acceptable. For the ample margin of safety dete rmination at proposal, the EPA referred to the conclusions from the technology review pe rformed for CAA section 112(d)(6) that no technologies (beyond those already in place) were identified for reducing HAP emissions from5 pulp and paper production processes other than for kraft condensates. The EPA proposed

amendments to the kraft condensate standards un der section 112(d)(6) th at would have achieved

incremental emissions reductions. The incrementa l risk reductions associated with the HAP reductions proposed for kraft conde nsates were not specifically quantified. The EPA concluded that the current subpart S sta ndard (regardless of the amendm ents to the kraft condensate standards proposed under 112( d)(6)) protects public he alth with an ample margin of safety. (76 FR 81344).

This memorandum provides additional details re levant to EPA’s ample margin of safety

determination for the final rule. Section II identifies the subpart S HAP and process risk drivers. Section III discusses post-proposal revisions to mill emissions inventories (including the near elimination of hexachloroethane [HCE] emissions ). Section IV discusses the ample margin of safety analyses, and Section V summarizes findings useful for informing EPA’s ample margin of safety decision.

II. Identification of Subpart S Risk Driver HAPs and Processes

A total of 68 mills had cancer risk estimates equal to or greater than 1 in 1 million (1x10 -6 ) for the proposed rule. The risk report for the proposed rule identified HCE and naphthalene from kraft processes such as pulp st orage, wastewater and bleaching as the drivers for chronic cancer risks. Although not listed in the risk re port as a driver for ch ronic cancer risks, acetaldehyde is of importance for chronic cancer risk and was listed as the predominant HAP

driver for chronic and acute non-ca ncer risks. Out of the 45,000 t ons/yr of HAP in the inventory for subpart S (of which 86 percent is methanol), the risk report not ed that emissions of the three HAP risk drivers were as follows in Table 1. (EPA 2011, EPA 2012a)

Table 1. Risk-Driver HAP for Subpart S Risk Driver HAP Emissions, to ns/yr Percent of subpart S HAP emissions (% of 45,000 tons/yr) Acetaldehyde 2,029 5%

HCE 207 0.5% Naphthalene 24 0.05%

Appendix A presents a summary of the cance r risk by emission process group. As shown in Appendix A, the vast majority of the cance r incidence for the subpart S source category is

associated with three emission process groups:

1. Papermaking,

2. Kraft Wastewater, and

3. Bleaching.

The overall cancer incidence for the subpart S source category is 0.01 excess cancer cases per year. As shown in Appendix A, cancer incidence from facilities wi th cancer risks greater than 1 in a million make up 0.008 of this total, and for these facilities papermaking, kraft wastewater, and bleaching are the greatest contributers to th e cancer incidence. The subpart S inventory was queried to cross-check which processes emit th e three risk-driver HAP shown in Table 1. The majority of HCE emissions were associated w ith kraft bleaching pro cesses. Papermaking and6 kraft wastewater were responsible for appr oximately 70 percent of the acetaldehyde and naphthalene emissions. Thus, any si gnificant reductions in risk for the subpart S source category would be obtained through incremental reductions in:

 HCE from bleaching, or

 acetaldehyde and naphthalene from papermaking and wastewater.

Therefore, the ample margin of safety analysis discussed for the remainder of this memorandum focuses on these risk-driver HAPs and processes.

Baseline emissions for the subpart S categ ory prior to MACT implementation were 230,000 tpy. As shown in Figure 1 below, papermaki ng and wastewater emi ssions are significant in terms of their post-MACT total mass of emi ssions of all pollutants. Kraft pulping emissions are already well-controlled, and therefore, signifi cant reductions in emissions or risk would not be achieved through additional contro ls for kraft pulping processes.

III. Post-proposal Revisions to Emissions Inventories

Revisions to the emissions inventories for 81 facilities were submitted during the public comment period following proposal of the subpart S residual risk and t echnology review (RTR). A separate memorandum provides mill-by-mill deta ils on the inventory changes requested. The inventory revisions were reviewed and it was co ncluded that the net effect of the inventory

revisions would influence risk in the downwar d direction. Risks were not remodeled for the subpart S source category since EPA had previous ly concluded that risks from the subpart S 0 2000 4000 6000 8000 10000 12000 14000 16000 18000TotalHAP,tpy Figure 1. Nationwide HAP Emissions by Subpart S Process

Total = 45,000 tpy7 source category were acceptable and the inventory revisions woul d only serve to reduce risk. For the ample margin of safety determinati on for the final rule it is notable that:

(1) HCE emissions were nearly eliminated from the subpart S source category inventory. A total of 201 tons/yr (97 percent) of the HCE was removed through post-proposal inventory revisions. Appendix B presents the rationale submitted by commenters for elimination of HCE, which is also discu ssed in the response-to-comments document. (EPA 2012b)

(2) A more-detailed review of the risk driv er pollutants and pro cesses (supplemented by risk modeling information from commenters ) suggests that the inventory revisions submitted are likely to have reduced chronic cancer risks to 1x10 -6 for 26 of the 68 mills

with cancer risks estimated to be greater than 1x10 -6 . This review where we considered the percent reduction in risk needed to get to 1x10 -6 is presented in Appendix C. Similar

detailed information from commenters was not available for mills with cancer risks

between 1x10 -6 and 2x10 -6

.

IV. Ample Margin of Safety Analyses

A. Bleaching

Bleaching processes are already well-controlled. Caustic scrubbers are used to reduce chlorinated HAP emissions (e.g., HCE, 1,1,2-trichl oroethane, carbon tetrach loride) by 99 percent or greater. Nationwide chlorinated HAP emissions from bleaching (other than chloroform) are the residual emissions remaining after implemen tation of 99+ percent control. Chloroform emissions are currently reduced from the pre- MACT baseline because the industry has shifted from bleaching with elemental chlorine and hypochl orite to chlorine dioxid e (elemental chlorine free bleaching). No other technologies exist to reduce emissions from kraft bleaching further. Although some totally chlorine free (TCF) bleaching processes exist, these technologies are not applicable for virgin kraft fibers in which th e lignin must be removed to obtain target final product brightness.

Furthermore, as noted above, the majority of risk-driving HCE emissions in the risk modeling inventory are associated with bleaching pr ocesses. HCE was the risk driver at the mill with the highest chronic cancer risk estimate, but this mill has eliminated the HCE emissions from their inventory. In additi on, nearly all HCE emissions have been eliminated from the modeling inventory. It is expect ed that HCE emissions would no longer be a risk driver if

emissions were to be remodeled using the inventory revisions.

B. Kraft Wastewater

The section discusses two potential measur es for reducing HAP emissions from kraft wastewater processes: (1) incremental improvement in condensate treatm ent efficiency, and (2) steam stripping of wastewater streams.

Incremental Improvement in Condensate Treatment Efficiency . Emissions from kraft wastewater operations are limite d by the subpart S kraft condensate standards in §63.446(e)(2).

The kraft condensate standards reduce emissions from handling and reuse of process liquids.8 Facilities meeting the kr aft condensate standards are required to treat the condensates to destroy total HAPs by 92 percent by weight, or to remove 6.6 (unbleached) or 10.2 (bleached) pounds (lb) of HAP per oven-dried ton of pulp (ODTP), or to achieve a total outlet HAP concentration of 210 (bleached) or 330 (unbleached) parts per million by weight (ppmw) or less. The predominant technologies used to reduce emissions from kraf t condensates are steam stripping and biological treatment. Mills using biologi cal treatment systems designed for wastewater treatment (e.g.,

aerated stabilization basins or activated sludge treatment) are re quired to discharge condensate below the liquid surface of a biological treatment system.

The costs, environmental, and energy imp acts of more stringen t condensate treatment standards were analyzed for the final subpart S rule and documented in a separate “impacts memo.” (RTI 2012) As shown in the impacts memo, an incremental increase in the kraft

condensate standards to raise the treatment effi ciency from 92 to 94 percent would reduce nationwide acetaldehyde emissions by approxima tely 23 tons/yr. The baseline emissions estimates for acetaldehyde and naphthalene fr om the proposal risk modeling inventory are estimated to be 457 tons/yr (acetaldehyde) and 6.6 tons/yr (naphthalene ), for a total of 463 tons/yr. Thus risk associated with acetaldehyde emissions from wastewater treatment would be reduced by 23/457 = 5 percent. The reduction in na phthalene was not quantified in the impacts memo (RTI 2012) because of the small baseline naphthalene mass value, but it follows that an additional 2 percent incremental reduction from 6.6 tons/yr would be 1.7 tons/yr assuming the 6.6 tons/yr baseline is al ready a post-control value. 2 Thus risk associated with naphthalene from wastewater could be reduced by 1.7/6.6 = 26 per cent through an increm ental increase in condensate treatment to 94 percent. The cost associated with thes e risk reductions is documented in the cost impacts memo, and is $423 million cap ital cost and $85.1 milli on per year annualized

cost. The cost effectiveness of this incrementa l increase is $37,000/ton of HAP reduced considering all HAP (including methanol). Ho wever, looking only at the risk-drivers (acetaldehyde and naphthalene) the cost effectiveness is $3.4 million/ton. 3 These costs are documented in the impacts memo and are based on a mill-by-mill analysis of the treatment levels currently achieved, and the improvements in te chnology that would be required to meet an incremental improvement in control efficiency. The impacts memo also presents the energy and secondary air emissions impacts associated with an incremental improvement in condensate treatment efficiency. Electrical energy usag e would increase by 113,685 million British thermal units per year (MMBtu/yr) and steam energy us e would increase by 910 MMBtu/yr. Secondary

emissions increases were estimated as follows:

 593 tons/yr PM

 2,870 tons/yr CO

 1,986 tons/yr NOx

 901 tons/yr SO 2

 1,402,084 tons/yr CO2eq for GHG

These costs, environmental, and energy imp acts were considered in EPA’s decision to abandon the proposed incremental in crease in condensate co ntrol efficiency for the final rule for

2 Assumes 6.6 tons/yr is the residual emissions following 92 percent control. A 2 percent incremental reduction of 94 percent is estimated as follows: 6.6 tons/yr / (1-0.92) = uncontrolled emissions of 83 tons/yr; 0.02 incremental reduction * 83 tons/yr = 1.7 tons/yr incremental reduction.

3 23 tons/yr + 1.7 tons/yr = 24.7 tons/yr; $85.1M/24.7 tons/yr reduction = $3,445,344/ton.9 the section 112(d)(6) technology review. However, under the sect ion 112(f) ample margin of safety analysis, the costs ($3.4 million/ton), envi ronmental, and energy impacts are compared to the 23 tons/yr reduction in acetald ehyde emissions (and associated 5 percent reduc tion in risk) and 1.7 tons/yr reduction in napht halene emissions (and associated 26 percent reduction in risk from naphthalene) for kraf t wastewater sources.

The highest cancer risk estimate associated with acetaldehyde from a kraft wastewater treatment process was 6x10 -6 . Eight of the 94 kraft wastewater emissions units reported in the inventory had cancer risk estimates exceeding 1x10 -6 . A 5 percent reduction in acetaldehyde

emissions would not decrease the hi ghest risk estimate to below 1x10 -6 (i.e., the highest risk

estimate would remain 6x10 -6 ).

Although naphthalene was identified as a risk driver for kraft wa stewater sources, no naphthalene cancer risk estimates exceeded 1x10 -6 for kraft wastewater sources. The highest

cancer risk estimate for a kraf t wastewater source was 6x10 -7 , which if reduced by 26 percent would drop to 4x10 -7

.

Other Technological Improvements . We are unaware of a ny feasible technological improvements beyond incrementally improving the kraft condensate treatment efficiency. Pollutants entering the wastewat er treatment system come fr om kraft condensates entering biological treatment, but also can be present in liquid streams from various other parts of the mill in low concentrations. Acetaldehyde and naphthalene in process liqui ds are expected to originate from the wood raw material being processed, so there is no feasible way of eliminating these HAP from the process through pollution preventi on (with the possible exception of eliminating these HAP from papermaking additives, as discu ssed below). As noted in public comments, kraft mills have already undertaken a substantial engin eering effort to collect the kraft condensate streams containing the highest HAP concentra tions and consolidate HAP in the condensate streams for treatment under §63.446(e)(2). Concen trating and minimizing the volume of HAPladen streams to be treated is particularly impor tant if a steam stripper is the treatment method because of the boiler steam demand needed to powe r the stripper. Generation of steam in boilers is an energy impact of steam stripping and resu lts in secondary air emissions from the boiler.

Despite the energy and secondary air emissions impacts, assuming hypothetically only that it could be technologically feasible to irradiate the acetaldehyde and naphthalene entering kraft wastewater treatment sy stems by consolidating the liqui d streams containing these HAP into a single stream a new steam stripper coul d handle, the costs of treatment would be unfavorable. From the impacts memo, the cost of a single new steam stripper designed to treat kraft condensates is $7,400,000 (cap ital) and $2,241,900/yr (annualized). 4 Using these costs, the

nationwide annualized cost for the 73 kraft m ills reporting acetaldehyde and/or naphthalene emissions from kraft wastewater processes would be $163,658,750 for a cost effectiveness of $353,000/ton if 463 tons/yr and 100 pe rcent of the risk associat ed with acetaldehyde and naphthalene could be reduced. We note that this is only a hypothetical example, and that in reality it is not feasible: (1) to consolidate ev ery acetaldehyde and naphtha lene containing-stream

4 From Table 6 of the impacts memo, total annualized costs for a new steam stripper are $2,241,900/yr which includes $695,600 (annualized capital) + $1,036,800 (steam $/yr) + $200,000 (annual maintenance materials and labor) + $13,500 (operating labor) + $296,000 (property taxes, insurance, and administration).10 into a liquid stream a single stri pper could treat (considering diluted influent flows into kraft mill wastewater treatment plants are on the order of 20 million gallons per day), or (2) for a steam stripper to achieve 100 percent removal of HAP. No other technologi es other than steam stripping could substantially re duce the concentration of HAP entering biological wastewater

treatment systems.

C. Papermaking

Papermaking includes equipment used to convert pulp into paper, paperboard, or market pulp, including the stock storage a nd preparation systems, paper or paperboard machines, paper machine white water system, broke recovery sy stems, and the systems involved in calendering, drying, on-machine coating, slit ting, winding, and cutting.

During the original subpart S rule development, EPA evaluated two undemonstrated control measures that could pot entially reduce HAP emissions from papermaking: (1) removal of HAPs from the pulp stock and white water before the papermaking syst em (e.g., with a white water steam stripper); and (2) control of papermaking system vent streams through vent gas

collection and incineration. Anal ysis of these control options concluded that there are no demonstrated methods for removing HAPs from th e pulp stock or white water and that applying HAP control to the vent streams of papermaking systems is not cost-effective (Air Docket A–95– 31, IV– B–8 [ERG 1997a]). Technical challenges not ed with these two cont rol options included fiber clogging of the steam stripper columns a nd heat exchangers, and the extremely high air flow rates from paper machines to be treated with incineration controls.

The EPA also investigated the use of HAP-c ontaining additives in papermaking systems, the magnitude of HAP emissions resulting from the use of papermaking system additives, and the viability of a MACT standard based on additiv e substitution. It was concluded that additives did not contribute significantly to HAP emissions from the pape r industry, with only 20 percent of the HAP additive content emitted to air, while the remaining 80 percent remained in the paper product or white water. The industry-wide total annual HAP emissions attr ibutable to additives were estimated to be around 50 tons/yr, and were considered negligible in comparison to the industry pre-MACT baseline emissions of over 200,000 tons/yr of total HAPs. EPA also noted that papermaking chemical and additive supplie rs are continually work ing to reduce the HAP content of additives, but that it was not clear from available information that substitution options are technically feasible for all products. Ther efore, EPA concluded that a standard for papermaking systems based on low-HAP additive substitution was not warranted at the time of promulgation in 1998. (72 FR 18525-18526, April 15, 1998 and Air Docket A–95–31, Item IV– B–6 [ERG 1997b]).

As part of the current technology review, Pa rt I Information Collection Request (ICR) data along with best available control technology (BACT) determin ations for papermaking were

examined to determine if there have been deve lopments in practices, pr ocesses, or controls applicable to papermaking systems since s ubpart S promulgation in 1998. (RTI 2011b) The only available measures for reducing papermaking HA P emissions include proc ess changes or work practices (e.g., practices relating to volatile organic compounds in papermaking additives). Add-11 on controls for HAP emissions have not been put into practice and remain undemonstrated. (RTI 2011a)

Substantial HAP emissions reductions have been achieved through implementation of subpart S for pulping and bleaching vents and kraf t condensates. Though not as significant prior to MACT, as shown in Figure 1 above, papermaki ng is now estimated to be one of the largest sources of HAP emissions remaining in the pulp and paper produc tion sector following implementation of subpart S. The HAP emissions associated with papermaking are attributable to HAPs contained in the pulp stock and white water, and HAPs from additives and cleaners. Emissions have been shown to vary depending on whether the pulp stock is produced onsite (e.g., at an integrated pulp mill) or whether th e pulp stock is bleached or unbleached. Emissions may also vary depending on the type on paper m achine (e.g., Fourdrinier, twin wire, cylinder, tissue, etc) but little emissions data are availa ble to characterize the e ffects of paper machine design on HAP emissions potential. It is anticipated that paper machine emissions may be more a function of the mixture processed through the machine (the pulp stock, white water, and additives) than of speci fic paper machine design.

The only potentially feasible methods for reducing risk-driver HAP emissions from papermaking include: (a) work practices to re duce naphthalene and acetaldehyde amounts in papermaking additives; and (b) reducing the co ncentration of these HAP in the papermaking

stock. Incineration-based controls are a third measure that remains infeasible because of the extremely large volumes of exhaust to be coll ected through enclosure of the paper machine and incinerated. Incineration would be cost-prohi bitive and result in en ergy and secondary air emission impacts from fuel burning. No mills wi th papermaking incineration controls were

identified in the ICR.

Nationwide, emissions estimates of 935 tons/yr of acetaldehyde and 7.4 tons/yr naphthalene (for a total of 943 tons/yr of risk-d river HAP) were included in the risk modeling emissions inventory. Most of the paper machine em issions in the inventory were estimated using emission factors. Acetaldehyde emission factor s based largely on tests with detectable acetaldehyde emissions are available for several types of paper machines. Naphthalene emission factors are only available for certain types of paper machines. Notably, the available naphthalene

emission factors are based on a few tests with de tectable naphthalene. (NCASI 2010) We are uncertain regarding how much of the nationw ide acetaldehyde and naphthalene HAP emissions (943 tons/yr) in the inventory are attributable to papermaki ng additives versus HAP in the incoming papermaking stock. For the ample margin of safety analysis, we partitioned this quantity by subtracting out the a cetaldehyde and naphthalene cont ent of HAP additives reported in the ICR responses. As shown in Appendix D, a calculated nationwide to tal of 100 tons/yr of acetaldehyde and naphthalene could be included in HAP additives (e.g., papermaking chemicals, wire cleaners). However, we do not know the fr action of the 100 tons/yr that would emanate from the papermaking process as air emissions as opposed to exiting the process with the paper product. Additionally, without more information, we are uncertain whether there are non-HAP substitutes for these chemicals (given that there are hundreds of different papermaking additives).12 New Substance Review Work Practice . One means of reducing HAP associated with papermaking additives and chemicals would be fo r subpart S to require mills to implement a “new substance review” work pract ice standard. This work practi ce could apply to all types of paper machines and require mills to develop a nd implement a substance review program that:

 Includes a process for identifyi ng the HAP of concern in addi tives, cleaners, or other chemicals used on the paper machine;

 Seeks non-HAP or lower-HAP formulations for each additive, cleaner, or other chemical processed on the paper machine; and

 Requires the use of a non-HAP or lower-HAP fo rmulation for each additive, cleaner, or other chemical processed on the paper machine.

The average capital cost per mill is estimated to be about $10,023 in labor to establish the substance review program. The capital cost was based on an estimated 100 hours to develop the program.(G-P 2011) The labor ra te was based on the total comp ensation for civilian workers, professional and related, for December 2010 ($47.73) from the U.S. Department of Labor. (DOL 2012) An additional 110 percent was added to this to account for overhead, for a total labor rate of $100.23 per hour.

The average annual cost per mill is estimated to be about $12,468 per year, which includes the cost of annualized capit al to establish the program plus the annual cost to implement the program and replace current HAP additives. For purposes of this analysis, the cost to replace

current HAP additives with new lower-HAP or non- HAP additives is estimated to be minimal, based on the assumption that a low- or non-HAP a dditive substitute would have a similar cost. However, the true cost is uncer tain. The cost to establish th e substance review program was annualized over a 5-year period at an interest rate of 7 percent. The annual cost to implement the program was based on an estimated 40 substance re views per year, at 2.5 hours per review. (G-P 2011) The same labor rate ($100.23 per hour) used to estimate the one-time capital labor cost

was also used to estimate the annual labor co st. Table 2 presents the capital and annual cost estimates for the HAP additives work practice.13 Table 2. Cost of HAP A dditives Work Practice

Parameter Value Cost inputs 1. Labor rate, $/hr $100.23 2. Hours to develop substance review program (one-time) 100 3. Hours to implement substance review program (annually) (assume 2.5 hr/review * 40 reviews/yr) 100

4. Capital recovery factor (assu me 5 years, 7% interest) 0.24389 Capital cost, $ Develop program (assume mills will hire a contractor to develop the program) $10,023

Annual cost, $/yr 1. Implement program $10,023

2. Incremental cost of new additives (Uncertain: assume similar cost for substitute non-/low-HAP additive) $0

3. Annualized capital cost (assume 5 years, 7% interest) $2,445

4. Total annual cost $12,468

This work practice would apply for 156 m ills at a nationwide capital cost of $1,564,000 million and total annualized cost of $1,945,000. Assuming that 100 tons/yr of acetaldehyde and naphthalene could be reduced with this work practice (an over-assumption since some of the HAP would remain with the pape r product rather than being em itted), the cost effectiveness would be $19,450/ton. Looking closer at the 100 tons/y r contained in the HAP additives listed in the ICR responses, it is notable that 5 tons/yr of this total is acetaldehyde (compared to 935 tons/yr in the risk modeling inventory, 5/935=0.5 percent) and 95 tons/yr is naphthalene (more than the 7.4 tons/yr is reported in the risk m odeling emission inventory – which suggests that naphthalene-containing chemicals may remain in the paper product as opposed to being emitted to the air). In the case of naphthalene we assu me that 100 percent of the nationwide emissions from papermaking would be reduced through the new substance review work practice.

Numeric Emission Limits . Numeric emission limits for HAP emissions are another option beyond establishing a work practice for HAP additives and chemicals that could further reduce emissions of acetaldehyde and naphthalene. Numeric limits could take the form of a HAP concentration limit for the papermaking stock (p rovided the uncertainti es of correlating air emissions of acetaldehyde and naphthalene to emissions emanating into the air could be overcome), or an air emissions limit. Air emissi ons testing would be required to demonstrate compliance with a numeric emission limit.

The ICR responses indicated that there can be up to 32 vents (6 average) on paper machine wet ends, and up to 28 vents (5 averag e) on dry ends with flow rates averaging 184,000 and 217,000 actual cubic feet per minute (acfm) pe r machine, respectively. An average of 3 additional vents following the dryer was reporte d with average flows of 84,058 acfm. (ICR 2011) Performing three, 1-hour sample runs on this numbe r of vents is very labor -intensive and results in a large number of samples to be handled, an alyzed, and reported. Emi ssions testing costs for sampling of papermaking vents are expected to be extreme (compared to tests of other process14 equipment where one or only a few vents are tested ). Testing costs relate to the labor (e.g., time and travel) and number of samp les to be collected and analyz ed. Also of concern is the complexity of emissions test methods that would be employed to measure paper machine HAP emissions. It is expected that only a few testi ng contract firms have experience with the NCASI sampling methods (though this pool of contractors should have incr eased with implementation of the wood products MACT). Test contract firm ava ilability can also drive up testing costs due to demand should, for example, 156 mills all requir e this emissions testing around the same time. Based on EPA’s experience, testing costs can be expected to be on the order of $106,000 to $220,000 (based on $13,000 for sampling and analysis of the first vent, $7000 for sampling and analysis of each additional vent, and test crew travel cost assuming a system with 14 to 30 vents).

Using the lower-end of the testing cost ( $106,000), we estimated the emissions testing cost impact associated with setting a numerical air emissions standard for 156 paper mills would be $16,536,000. Annualized over 5 years at 7 percent in terest, the annualized cost for emissions testing at 156 paper machines would be $4,032,965/yr. 5

The testing cost would be in addition to the costs for any technologica l changes needed to reduce the concentration of HAP in the pape rmaking stock. A report by BE&K Engineering provides 2001 costs for a screw press system that could be installed to remove pulping liquid. (BE&K 2001) This report indicates that cap ital costs for a screw press system are $6,071,858 and annual costs are $453,590. Assuming that only 38 integrated unbleached paper mills would

need to further reduce the HAP concentration in their papermaking stock (since the bleaching process removes HAP-laden pulpi ng liquid traveling with the brownstock), estimated annual costs for reducing the HAP concentration in the paper stock would be $17,236,420/yr (in 2001 dollars).

Including emissions testing costs, the overa ll annualized cost for a numeric emission limit would be $21,269,385/yr. When compared to th e maximum theoretical HAP risk-driver reduction of 943 tons/yr (assuming - with consider able uncertainty - that 100 percent of the emissions from acetaldehyde and naphthalene coul d be mitigated), the cost-effectiveness is $22,560/ton. The screw press technol ogy is not expected to result in any secondary air emissions or energy impacts (beyond those associated with electric power use). However, the screw press technology (or other methods of incorporating ad ditional fresh water use into papermaking) would result in water usage impacts and in creased wastewater effluent volume.

Papermaking risk reductions . Of the 398 papermaking emission units with reported acetaldehyde emissions in the inventory, there we re 5 papermaking sources with acetaldehyde

cancer risk estimates above 1x10 -6 . The highest cancer risk estimate associated with acetaldehyde from papermaking is 3x10 -6 . If reduced by 0.5 percent through a new substance review work practices this risk estimate would be lowered neg ligibly to remain 3x10 -6 . The assumption presented above that risk could be lowered by 100 percent by reducing acetaldehyde in the papermaking stock was theoretical only (i.e ., actual reductions that could be achieved are site-specific and highly uncertain).

5 Capital recovery factor = 0.24389.15 Although naphthalene was identified as a risk driver for papermaking sources because of its contribution to the risk, none of naphtha lene cancer risk estimates exceeded 1x10 -6 for papermaking sources. The highest cancer risk es timate for a papermaking source associated with naphthalene was 5x10 -7 , which would be assumed to be reduced by 100 percent with the new substances review work practice.

V. Conclusions

The health risks associated with the fo llowing subpart S risk-driver pollutants and processes were reviewed:

 HCE from bleaching, and

 acetaldehyde and naphthalene from papermaking and wastewater.

These HAP and processes were the focus of the am ple margin of safety analysis because control measures applied to these processes offer the greatest potential for risk reduction. No other

control measures were identified that could provide additional m eaningful risk reductions. The following findings support an ample margin of safety determination for the final subpart S

residual risk review:

 Post-proposal inventory revisions for 81 mills would influence risk downward.

 98 percent of HCE emissions have been eliminated from the inventory.

 Post-proposal inventory revisions for 26 mills with estimated risks above 2x10 -6 would likely result in reduced chronic ca ncer risk to levels below 1x10 -6 . (Similar information

was not available to evaluate for mills between 1x10 -6 and 2x10 -6 .)

 Considering cost, environmental, and energy impacts and uncertainty no feasible options for increasing the ample margin of safety we re identified for kraft wastewater sources.

 No feasible options were identified for increasing the ample margin of safety for papermaking sources considering cost, poten tial water impacts, and uncertainty in

emissions and risk reductions that could be obtained.16 References

BE&K 2001 BE&K Engineering. Emission Control Study--Technology Cost Estimates

. Prepared for American Forest & Paper Association. September 2001.

DOL 2011 U.S. Department of Labor , Bureau of Labor Statistics. Economic News Release

. Table 2: Civilian workers, by occu pational and industry group, March 2012.

Website: http://www.bls.gov/news .release/ecec.t02.htm

. ERG 1997a Memorandum from C. Leatherwood, Ea stern Research Group (ERG), to P. Lassiter, U.S. EPA. September 10, 1997. Maximum Achievable Control Technology (MACT) Determina tion For Papermaking Systems. Air Docket A– 95–31, IV–B–8.

ERG 1997b Memorandum from C. Leatherw ood, ERG, to E. Manning, EPA. March 11,

1997. Analysis of Papermaking System Additives. Air Docket A–95–31, IV–B–6.

EPA 2011 U.S. EPA. Draft Residual Risk As sessment for Pulp and Paper Source Category.

December 2011

EPA 2012a U.S. EPA. Residual Risk Assessment for th e Pulp & Paper Source Category

. July 2012.

EPA 2012b U.S. EPA. National Emission Standards for Haza rdous Air Pollutants from the Pulp and Paper Industry (40 CFR Pa rt 63, Subpart S) Residual Risk and Technology Review, Final Amendments: Response to Public Comments on December 27, 2011 Proposal. July 2012

G-P 2011 E-mail from M. Curtis, Georgia-Paci fic Corp., to J. Bradfield, EPA. May 6,

2011. GP’s New Substance Review Program

. ICR 2011 Pulp and Paper ICR Data.

NCASI 2010 National Council for Air and Stream Improvement. Compilation of ‘Air Toxic’ and Total Hydrocarbon Emissions Data for Pulp and Paper Mill Sources – A Second Update. Technical Bulletin No. 973. February 2010.

RTI 2011a Memorandum from K. Hanks and T. Holloway, RTI, to J. Bradfield and B. Schrock, U.S. EPA. November 16, 2011. Section 112(d)(6) T echnology Review for Pulping and Papermaking Processes.

RTI 2011b Memorandum from V. Hanzel, RTI, to J. Bradfield and B Schrock, U.S. EPA. August 2, 2011. Papermaking Technology Review Information Received from

State Contacts.

RTI 2012 Memorandum from T. Holloway, K. Hanks , and C. Gooden, RTI, to J. Bradfield and B. Schrock, U.S. EPA. May 15, 2012. Costs, Environmental, and Energy Impacts for the Promulgated Subpar t S Risk and Technology Review.Appendix A

Cancer Risk by Emission Process GroupPulp & Paper - MIR by source type based on actual emissionsMaximum Overall PapermakingWastewater(Kraft)Bleaching:KraftKraft PulpStorage Paper Stock PrepMechanicalPulpingKraft Pulping:Digester LVHC Soda MiscKraft Pulping:WashingBleaching: SecFiberSemichemPulpingKraft Pulping:BL TanksHVLCCancer RiskMaximum (in 1 million)10 5 9 4 9 8 7 6 4 4 2 2 2Number of people>= 100 in 1 million 00 0 0 0 0 0 000000>= 10 in 1 million 400 0 0 0 0 0 000000>= 1 in 1 million 76,000 15,946 11,658 951 29 458 1,071 1,436 2,894 274 4,911 133 95Incidence0.01 0.005 0.003 0.001 0.0002 0.0002 0.0003 0.0003 0.0002 0.0004 0.0009 0.0001 0.0003Precent of Overall Incidence50% 26% 11%1.6% 1.9% 2.7% 3.3% 2.2% 3.7%8.8%1.3% 2.6%Sector MIR = 10 (in a million) Cancer Incidence Contribution:87%Papermaking + Wastewater (Kraft) + Bleaching:Kraft96%Papermaking + Wastewater (Kraft) + Bleaching:Kraft + Bleaching:Sec FiberCancer_Inc_Contribution1 of 2Pulp & Paper - MIR by sourceCancer RiskMaximum (in 1 million)Number of people>= 100 in 1 million>= 10 in 1 million>= 1 in 1 millionIncidencePrecent of Overall IncidenceSector MIR = 10 (in a million)Kraft Pulping:DeckerKraft Pulping:O2 Delig HVLCKraft Pulping:LVHC Paper MiscWastewater(Mechanical)Wastewater(General)Kraft Pulping:EvaporatorLVHCCausticizing:White LiquorKraft Pulping:IncineratorKraft StockWashingCausticizing:Misc24 OtherEmissionProcessGroups2 2 1 1 1 1 1 1 1 1 0.9<0.70 0 0 0 0 0 0 000 0 00 0 0 0 0 0 0 000 0 077 71 293 126 108 72 39 3 4 5 0 00.0001 0.00007 0.0002 0.00002 0.00007 0.00004 0.00001 0.00006 0.00006 0.00006 0.00009 0.000461.2% 0.7% 1.9% 0.2% 0.7% 0.4% 0.1% 0.6% 0.6% 0.6% 0.9% 4.6%Cancer_Inc_Contribution2 of 2SourceDescription%SourceIncidenceforbyEPGforFacilitieswithexcesscancerrisk>1inaMillionSourceIncidenceforfacilitieswithMIRrisks>orequalto1inamillionPapermaking 33.51 3.08E‐03Wastewater(Kraft) 28.52 2.62E‐03Bleaching 14.69 1.35E‐03Kraft 10.41 9.57E‐04SodaMisc 2.26 2.07E‐04MechanicalPulping1.62 1.49E‐04Total 0.0082025303540FigureA1.PercentCancerIncidencebyEmissionProcessGroupforFacilitieswithExcessCancerRisk>1inaMillion(Incidence=0.008)0510152025Papermaking Wastewater(Kraft) Bleaching Kraft SodaMisc MechanicalPulpingAppendix B

February 24, 2012 NCASI Letter Regarding

Hexachloroethane Emissions from Browns tock Washers and Bleach Plant Sources

# ncasi NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC.
SOUTHERN REGIONAL CENTER Mailing and Street Address:
402 SW 140 th Terrace, Newberry, FL 32669

Phone (352) 331-1745

FAX (352) 331-1766

February 24, 2012

TO: File

FROM: Zach Emerson

RE: Hexachloroethane Emissions from Brownstock Washers and
Bleach Plant Sources

Background

In EPA’s December 2011 risk-modeling, he xachloroethane (HCE) emerged as a riskdriving compound from brownstock washers and bleach plant sources. After an initial
review of available information on HCE em issions from these sources, NCASI has determined that reported em issions are based upon limited emissions data derived from

stack tests conducted in 1993.

Many facilities have used the information pr esented in the NCASI Air Toxics Emissions Database (NCASI 2012) to estimate emissions of HCE from their sources. Tables 1, 2 and 3 present summaries of stack test data that form the basis for the information presented in the database.

Table 1 presents the results of HCE testing at three vacuum drum brownstock washer systems at three facilities. In testing at two softwood and one hardwood pulp mills, HCE was not detected in any vacuum drum washer vent. Emission rates (calculated using the minimum analysis measurement level) ranged from less than 0.043 to less than 0.10 lb/ADTUBP. Note that, in such ca ses, NCASI does not calculate a recommended emission factor and instead provides the minimum and maximum observed values.

Table 1. Hexachloroethane Emissions from Brow nstock Washers – Vacuum Drum

Source Code Year Notes Emissions (lb/ADTUBP)

BSWIF 1993 Softwood – 5 Vents < 4.3 E-02

BSWIG1 1993 Softwood – 3 Hood Vents < 8.4 E-02

BSWIG2 1993 Hardwood – 3 Hood Vents < 1.0 E-01

Average not estimated when data set has all NDs; only min and max DLs provided

Table 2 presents the results of HCE testing at two diffusion washer systems. HCE was reported as detected at a hardw ood diffusion washer vent and in a foam breaker vent at a softwood diffusion washer system. Meas ured emissions ranged from 0.032 to 0.13lb/ADTUBP with a mean emission factor of 0.081 lb/ADTUBP. Each HCE result in this dataset was labeled as “suspicious data – needs confirmation” in the Air Toxics

Database. This will be discussed in more deta il below. In the Air Toxics Database, this dataset is representative of the “Brownstock Washer – Other” process unit group.

Table 2. Hexachloroethane Emissions from Brownstock Washers – “Other”

Source Code Year Notes Emissions (lb/ADTUBP)

BSWIC1* 1993 Hardwood – 1 Diffusion

Washer Vent 1.3 E-01

BSWIC2* 1993 Softwood – Diffusion Washer

1 Foam Breaker Vent 3.2 E-02

Mean = 8.1 E-02 lb/ADTUBP *data is labeled “suspicious data – needs c onfirmation” in NCASI Air Toxics Database

Table 3 presents the results of HCE testing at six non-ECF bleach plant vents and one ECF bleach plant vent. HCE was detected in the lone ECF bleach plant source at 0.025 lb/ADTUBP. HCE was not detected in any of the non-ECF bleach plant vents. Emission factors for the non-ECF vents ranged from less than 0.015 to less than 0.068
lb/ADTUBP.

Table 3. Hexachloroethane Emissions from Bleach Plant Vents

Source Code Year Notes Emissions (lb/ADTBP)

BPIC1a 1993 Non-ECF < 2.2 E-02

BPIC3 1993 ECF 2.5 E-02

BPIF2 1993 Non-ECF < 4.1 E-02
BPIG 1993 Non-ECF < 1.5 E-02

BPIJ1 1993 Non-ECF < 1.9 E-02

BPIJ2 1993 Non-ECF <3.8 E-02
BPIF1 1993 Non-ECF <6.8 E-02

The current data on HCE emissions from these sources (a) is based upon limited data from pre-MACT testing, (b ) is predominantly compris ed of non-detects and (c) is unconfirmed in many cases due to uncertainties associated with the analytical methodology. More details are provided in the following sections.

Discussion

HCE Emissions from Low-Flow Brownsto ck Washers and ECF Bleach Plant Vents

Of the relevant process units, hexachlor oethane emissions were detected at two diffusion washer system vents and in the lone ECF bleach plant vent. These emissions were labeled “suspect” in the emissions dat abase. NCASI Technical Bulletin No. 973 (2010) serves as the foundationa l document for the Air Toxics Database; it contains the following passage regarding HCE emissions from brownstock washer sources:Hexachloroethane (HCE) – This compound was not detected in all three VDW ( vacuum drum washer, ed. ) system vents tested, with DLs ranging from 0.043 to 0.10 lb/ADTUBP. However, HCE was detected in two low-flow (diffusion) washer system vents tested at Mill IC (one hardwood and one softwood line) at levels ranging from 0.032 to 0.13 lb/ADTUBP. Since washer vent emissions are generally related to the chemicals in the liquor trapped within the brownstock or the chemicals in the last stage wash water used, neither of which should contain this chlorinated compound, it appears hi ghly unlikely that this compound would be present. The identity of this compound was not confirmed using GC/MS. As discussed above in Section 4.1, HCE wa s also detected in the bleach plant

scrubber vent at the sa me mill (Mill IC).

Regarding bleach plant vents, Technical Bu lletin No. 973 also says the following:

Hexachloroethane (HCE) was not detected in all six non-ECF bleach plant vents tested. However, it was detected at 0.025 lb/ADTBP in the sole ECF bleach plant tested (not identified or c onfirmed by GC/MS)...The sole data point
for HCE emissions from ECF bleac h plants should be used with caution . More testing would be needed to confirm its presence.

Another important factor to consider is t he chemistry of hexachloroethane. It is well

known that hexachloroethane dechlorinates in a reduc ing environment (Curtis and Reinhard 1994). Thus, there is no potentia l for its formation during the kraft pulping process, and it would not be expected to be present in sources such as brownstock washers, which are associated with kraft pulping. Relative to HCE formation in an ECF bleach plant, it should be noted that HCE is manufactured through the chlorination of tetrachloroethylene in the pres ence of ferric chloride at el evated temperature. HCE is also a co-product in the production of te trachloroethylene by pyrolysis of carbon

tetrachloride at 800-900  ̊ C (U. S. Dept. of Health and Human Services 1997). ECF bleaching conditions do not provide conditions that are conducive to the generation of the precursors of HCE nor is there signific ant availability of free chlorine to further chlorinate the precursors , if they are present.

Based upon the above and our under standing that HCE is not expected to be present in pulping/bleaching additives, it is our view that there are significant uncertainties
associated with the HCE emissions data in NCASI’s database. NCASI is planning to conduct emissions testing studies at several fa cilities to evaluate this; such studies will take some time. The goal will be to test for HCE at two diffusion washer system vents and two bleach plant scrubber vents.Summary

Until new test results becom e available, HCE emission s from brownstock washer sources and bleach plant vents should be remo ved from EPA’s risk model inputs for the following reasons:

 HCE was not detected at three vacuum drum washer systems. In general, HAP
emissions from vacuum drum washer v ents are higher than diffusion washers. HCE was also not detected during (unquantified) screening studies at other washer system vents.

 HCE was not detected at six non-EC F bleach plant system vents.

 HCE is not expected to be present in the black liquor in the brownstock.

 HCE is unstable in highly reductive environments, such as black liquor.

 In stack tests at two diffusion washer systems and one ECF bleach plant scrubber, the suggested presence of HCE in vent gases was not confirmed on mass spectrometer.

References

Curtis, Gary P., and Reinhard, Martin . 1994. Reductive Dehalogenation of Hexachloroethane, Carbon Tetrachloride, and Bromoform by Anthrahydroquinone
Disulfonate and Humic Acid. Environmental Science and Technology , Vol. 28, No. 13, pp. 2393-2401.

National Council for Air & Stream Improvement, Inc. (NCASI). 2010. Compilation of “Air Toxic” and Total Hydrocarbon Emissions Data for Pulp and Paper Mill Sources – A Second Update . Technical Bulletin No. 973. Re search Triangle Park, NC: National Council of the Paper Industry for Ai r and Stream Improvement, Inc.

National Council for Air & Stream Improvement, Inc. (NCASI). 2012. NCASI Air Toxics

Emissions Database. 2012 update. Research Triangl e Park, NC: National Council of the Paper Industry for Air and Stream Improv ement, Inc.

U.S. Department of Health and Human Serv ices. 1997. Toxicological Profile for Hexachloroethane. September 1997. Atlanta, GA: Agency for Toxic Substances and Disease Registry, Division of Toxico logy/Toxicology Information Branch.Appendix C

NEI Data Revisions Expected to Reduce RiskAppendix C. NEI Data Revisions Expected to ReduceRiskIncreased release heightIncreased fugitivearea Reduced emissions Increased stack gas temperature Increased stack gas velocity or flow Deleted emission units Deleted HAPs Changed from fugitive to stackNEI32869A 109 0177 Domtar Paper Company LLC Hawesville KY HCE (80%) Kraft Pulp StorageReduced acetaldehyde, formaldehyde from papermachines, pulp dryerDeleted HCE from bleach plant,pulp storage1.21E-05 92% YesNEI18334 186 0197 Georgia-Pacific Corp. Pennington AL Acetaldehyde (18%),Formaldehyde (17%), Carbontetrachloride (14%),Naphthalene (13%)Kraft Pulping: Evaporator LVHC,Kraft Pulping: BL Tanks HVLC,Wastewater (Kraft), KraftPulping: Washing, Kraft Pulping:Decker, Bleaching: KraftIncreased stack height for SDT andmultiple subpart S units (50) whenchanged their release point typefrom fugitive to stackReduced naphthalene from WWTReduced acetaldehyde, carbon tetrachloride,chloroform, formaldehyde, methanol, naphthalene,phenol, other HAPs from deckerReduced acetaldehyde metals, methanol,naphthalene, 7 other HAPs from RFReduced chloroform, metals, 18 other HAPs fromSDTIncreased stack temperature for SDTand multiple subpart S units (46) whenchanged their release point type fromfugitive to stackIncreased stack velocity/flow for SDT andmultiple subpart S units (55) (56 if includejust stack flow of NCG incineration) whenchanged release point typeDeleted records for bleach plant, knotter, BSW,digester, screens (accounted for elsewhere) anddecker, causticizing misc, lime mud washer (nolonger in service) (includes acetaldehyde,chloroform, formaldehyde, methanol,naphthalene)Deleted HCE from bleach plantsDeleted HCl from RFChanged release point type for SDTand multiple subpart S units (56)from fugitive to stack1.04E-05 90% YesNEI40282 206 0174 Blue Ridge Paper ProductsInc.Canton NC Acetaldehyde (44%),Formaldehyde (32%)Papermaking, Kraft Pulping: O2delignification HVLCReduced acetaldehyde, formaldehyde from papermachinesReduced 1,2-dichloroethane from BSWDeleted 1,2-dichloroethane fromO2 delignification, LK, boiler8.98E-06 89% YesNEIWI7720116,NEI46739, &NEI42963154 0182 NewPage Corporation WisconsinRapidsWI Acetaldehyde (79%),Formaldehyde (12%)Wastewater (Kraft)NEIWI7720116:Reduced acetaldehyde, chloroform, formaldehyde,methanol, catechol, cresol, ethylene glycol, phenolNEI46739: Deleted carbontetrachloride and 1,1,2-trichloroethane from causticizing8.51E-06 88% YesAppears that inventoryrevisions may have alreadyreduced risk to 1x10-6Percent reduction inrisk needed to get to1x10-6Cancer riskNEI Revisions Which May Reduce RiskCancer risk driver (% of risk)(Source: AECOM5)Cancer risk driver (sourcegroup)(Source: AECOM5)Survey NEI RTI code Comment no. Company name Mill city Mill stateNEI42963methanol, catechol, cresol, ethylene glycol, phenolfrom WWTNEI46739: Reduced chloroform, formaldehyde, 7other HAPs from causticizing misctrichloroethane from causticizingmiscNEIME0250002 363 0205 Madison Paper Co. Madison ME Naphthalene (60%),Acetaldehyde (23%)Mechanical Pulping Increased stack height ofpressurized groundwood emissionunits when replaced them withstack equivalentsIncreased stack height of boilersIncreased stack temperature forpressurized groundwood emission unitswhen replaced them with stackequivalentsIncreased stack velocity/flow for pressurizedgroundwood emission units when replacedthem with stack equivalentsIncreased stack velocity/flow of boilersDeleted fugitive records for pressurizedgroundwood emission units (to be replaced withlower emission records for acetaldehyde,formaldehyde, methanol, phenol, naphthalene,etc.)Changed release point type forpressurized groundwood emissionunits from fugitive to stack7.58E-06 87% YesNEI42695 617 0180 Domtar Corporation Nekoosa WI Berylliumcompounds (84%) Kraft Pulping: Digester LVHCDeleted antimony, beryllium, andcadmium from digester7.42E-06 87% YesNEI41552 142 Packaging Corp. of America Counce TN Acetaldehyde (98%) Wastewater (Kraft)Reduced acetaldehyde from paper machines (91records) and ASB (1 record)Increased velocity and flow of BL tanks (4unique records)Deleted fugitive records for BL tanks (to bereplaced) (2 unique records)Deleted acetaldehyde from WWTprimary settling basinChanged release point type for BLtanks from fugitive to stack (3unique records)7.14E-06 86% YesNEI47091 606 Buckeye Technologies Inc. Perry FL HCE (78%) Kraft Pulping: Washing,Bleaching: KraftReduced metals, chloroform, 11 other HAPs fromRF, SDT, LKReduced metals from boilersDeleted HCE from bleach plant,BSW5.22E-06 81% YesNEI40600 188 0209 Georgia-Pacific Corp. Toledo OR Acetaldehyde (33%),Formaldehyde (12%), 1,1,2-Trichloroethane (11%),Tetrachloroethene (10%)Papermaking, Kraft Pulping: BLTanks HVLC, NSSC PulpingReduced acetaldehyde, formaldehyde, chloroform,methanol, 19 other HAPs from black liquor storagetanksDeleted fugitive records for paper machines (to bereplaced)4.94E-06 80% YesNEI13363 133 0147 Simpson Tacoma Kraft Co Tacoma WA Formaldehyde (71%),Acetaldehyde (18%)PapermakingReduced acetaldehyde, formaldehyde from WWT4.30E-06 77% YesNEI41314 166 0190 International Paper Co. Georgetown SC Acetaldehyde (39%), HCE (25%) Kraft Pulping: Decker,Bleaching:Kraft, Causticizing: Slaker,Deleted records for causticizing misc, lime slaker(includes acetaldehyde, chloroform, methanol,Deleted HCE from bleach plants4.25E-06 76% YesWastewater (Kraft), KraftPulping: LVHCnaphthalene) Deleted naphthalene fromcausticizing misc, LVHC, NCGincinerator, BLO unitDeleted 8 other HAPs from WWTNEI40686 100 0175 Domtar Corporation Johnsonburg PAHCE (50%), Acetaldehyde (22%),Formaldehyde (18%)Bleaching: Kraft, Causticizing:Misc & Lime MudDeleted HCE from bleach plantDeleted acetaldehyde, chloroform,formaldehyde, methanol, 18 otherHAPs from causticizingDeleted acetaldehyde, acrolein,chloroform, formaldehyde,methanol, naphthalene, 28 otherHAPs from SDT3.85E-06 74% YesNEI33135 & NEI706 145 NewPage Corporation Luke MD Acetaldehyde (29%), Carbontetrachloride (21%),Formaldehyde (14%)Kraft Pulping: Decker Increased stack heights for decker,knotter, pulp storage, black liquortanks, causticizing when changedrelease point typeReduced formaldehyde from white liquorprocessingIncreased stack temperature for decker,knotter, pulp storage, black liquortanks, causticizing when changedrelease point typeIncreased stack velocity/flow for decker,knotter, pulp storage, black liquor tanks,causticizing when changed release point typeDeleted records for BSW (emissions go to powerboilers) (includes acetaldehyde, formaldehyde,methanol, carbon tetrachloride)Changed release point type fordecker, knotter, pulp storage,black liquor tanks, causticizingfrom fugitive to stack3.77E-06 73% YesNEI41599 106 0185 Domtar Paper Company LLC Kingsport TN HCE (50%), Acetaldehyde (42%) Bleach Plant, WastewaterReduced acetaldehyde, methanol from WWTP1/2,formaldehyde from WWTP2Deleted HCE from bleach plantDeleted acetaldehyde, chloroform,formaldehyde, methanol,naphthalene, 21 other HAPs from3.62E-06 72% YescausticizingDeleted acetaldehyde, acrolein,chloroform, formaldehyde,methanol, naphthalene, 28 otherHAPs from SDTNEI8178 430 0206 Georgia-Pacific Corp. Rincon GA Acrylonitrile (66%),Acetaldehyde (21%)Papermaking, Wastewater:GeneralReduced acetaldehyde, formaldehyde, chloroform,methanol, toluene, benzene, MIBK, CS2 from WWT,deckerDeleted unconsolidated records for papermachines (to be replaced)Deleted naphthalene from WWTand acrylonitrile from papermachines3.34E-06 70% YesNEI8196 243 0210 Georgia-Pacific Corp. Brunswick GA Acetaldehyde (73%) Wastewater: Kraft Increased stack heights for limemud filter, lime slakerReduced acetaldehyde, naphthalene from WWT Increasedstack temperature for limemud filter when changed its releasepoint typeIncreased stack velocity/flow for lime mudfilter when changed release point typeDeleted toluene-2,4-diamine fromblack liquor storage tanksChanged release point type forlime mud filter from fugitive tostack3.27E-06 69% YesNEI6450 147 MeadWestvaco Evadale TX Acetaldehyde (47%),Formaldehyde (29%)PapermakingIncreased fugitivearea for WWT andpaper machinesReduced acetaldehyde, formaldehyde emissionsfrom paper machines3.25E-06 69% YesNEI42357 139 Port Townsend Paper Corp. Port Townsend WAAcetaldehyde (97%) Wastewater: KraftReduced acetaldehyde from ASBReduced acetaldehyde, metals, naphthalene fromLKReduced arsenic from SDTReduced metals from boilerIncreased release temperature for ASB Increased stack velocity for RFDeleted acrolein, formaldehyde,acetaldehyde, naphthalene,methanol, 5 other HAPs from SDT3.10E-06 68% YesC-1Increased release heightIncreased fugitivearea Reduced emissions Increased stack gas temperature Increased stack gas velocity or flow Deleted emission units Deleted HAPs Changed from fugitive to stackAppears that inventoryrevisions may have alreadyreduced risk to 1x10-6Percent reduction inrisk needed to get to1x10-6Cancer riskNEI Revisions Which May Reduce RiskCancer risk driver (% of risk)(Source: AECOM5)Cancer risk driver (sourcegroup)(Source: AECOM5)Survey NEI RTI code Comment no. Company name Mill city Mill stateNEI18660 196 0202 Domtar Industries Ashdown AR Formaldehyde (35%),Acetaldehyde (33%), HCE (30%)Kraft Pulping, Papermaking,BleachingReduced acetaldehyde from O2 delignificationDeleted HCE from bleach plant andformaldehyde from pulp dryer3.04E-06 67% YesNEI45182 105 0190 International Paper Co. Springfield ORFormaldehyde (75%),Acetaldehyde (16%)Kraft Pulping: Digester LVHCReduced acetaldehyde, formaldehyde, chloroform,methanol, and 16 other HAPs from digester chipbin and LVHC2.80E-06 64% YesNEI12407 229 0183 Verso Paper Corp. Sartell MN Cadmium (26%), Formaldehyde(20%), Nickel (13%),Acetaldehyde (13%), Arsenic(13%)Kraft Pulping: Incinerator,Mechanical Pulping,PapermakingDeleted records for NCG incinerator (includesmetals, formaldehyde, naphthalene)2.72E-06 63% YesNEI40247 174 0190 International Paper Co. Riegelwood NC Acetaldehyde (40%),Formaldehyde (38%), HCE(19%)Kraft Pulping: Washing,Bleaching: Kraft, Kraft Pulping:Digester LVHCReduced acetaldehyde, formaldehyde, chloroform,methanol, and 16 other HAPs from digester chipbinDeleted records for causticizing misc, lime slaker(includes acetaldehyde, chloroform, naphthalene,methanol)Deleted HCE from bleach plant2.69E-06 63% YesNEI42482 436 0169 Georgia-Pacific Corp. Green Bay WI Formaldehyde (87%) BleachingReduced formaldehyde from EU BLT12 (BleachTower 2)Deleted formaldehyde from EUBLT22 (Bleach Tower 2) (to bereplaced with much lower estimatefor EU BLT14)2.46E-06 59% YesNEI6261 610 0184 Verso Paper Corp. Jay ME Acetaldehyde (67%),Naphthalene (27%)Wastewater, Mechanicalpulping, PapermakingReduced acetaldehyde, naphthalene, CS2,propionaldehyde from WWT2.22E-06 55% YesNEI33883 155 0192 NewPage Corporation Escanaba MI Acetaldehyde (49%),Formaldehyde (27%),Naphthalene (14%)Wastewater treatmentReduced acetaldehyde, formaldehyde, naphthalenefrom WWT2.04E-06 51% YesNEI8186 531 0190 International Paper Co. Savannah GA Formaldehyde (72%),Acetaldehyde (13%)Kraft Pulping: LVHC, WastewaterReduced acetaldehyde, formaldehyde, chloroform,methanol from LVHCDeleted records for causticizing misc, lime slaker(includes acetaldehyde, chloroform, naphthalene)2.00E-06 50% YesNote: Highlighted cells link the risk drivers to the NEI data revisions expected to reduce risk.C-2Appendix D

Acetaldehyde and Naphthalene HAP Additiv es Calculations Based on ICR DataAppendix D. Documentation of HAP Amounts in Additives1,2NEISiteID Additive HAP_content AmountAmount_UnitsHAP_Amount3-5HAP_Amount_Units NEI_Emissions_tpyNEI_Emissions_lb/year SubstitutesSubstituteOthHAP HAPAdditivesComments RTINotesNEI18652 PVAC LatexAcetaldehyde - <0.095%3151687 lb/year2,994 lb/year8.3 16,600 UKUKNEI40488 DyeAcetaldehyde - <= 2%CBI lb/yearx lb/yearUKUKNEI40720 Vinyl Acrylic BinderAcetaldehyde- 0.15%756 lb/year1 lb/yearUKUKNEI41599 Biocide Napthalene - 1.1%, by weight 972 lb/year 11 lb/year No NA Biocide for the aluminum sulfate solution storage tank. Aluminumsulfate is metered into the pulp on the paper machine and incorporatedinto thepaperproduct.NEI42329 Release Agent Naphthalene - 0-3% 555 gal/yr 81 lb/year UK UK No other additives containing HAPs greater than OSHA thresolds wereused at NPI in 2009NEI42730 Screen Wash Naphthalene - 10% 360 lb/year 36 lb/year no Other chemicals have been tried; however, small amounts of this are stillusedAlready has substance review program, sono impactsNEI46814 Felt wash Napthalene <5% 271 lb/day 1,250 lb/year 0.6 1,250 UK UKCalculated value > NEI, so substituted NEIvalueNEI6057 Desizer/rewetterNapthalene - 1%46000 lb/year460 lb/year0.3 585 UKUKNEI8560 MicrobiocideNaphthalene - 1.1%7240 lb/year80 lb/yearUKUKNEICT3102 EmulsifierAcetaldehyde <900ppm7,952,100 lb/year7,157 lb/yearlbs NoNEIGAT$3911 Felt CleanerNapthalene-80%234011 lb/year187,209 lb/year1. CBI = confidential business information (from Pulp and Paper ICR responses).100 total tpy2. UK = unknown (from Pulp and Paper ICR responses).5 tpy acetladehyde3. Calculations:95 tpy naphthalenelb/year emitted = (lb/year additive) * (% HAP/100)lb/year emitted = (lb/day additive) * (% HAP/100) * (365 days/year)lb/year emitted = (gal/year additive) * (% HAP/100) * (lb/gal)4. Conversion factors:Naphthalene1.16 g/ml0.002204623 lb/g3785.412 ml/gal9.680671377 lb/gal5. Where the HAP calculated from the additive exceeded the NEI emissions estimate, used the NEI emissions estimate as the HAP amount from additives.