UNITED STATES ENVIRONMENTAL 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 determine if the final pulp and 

papermaking (40 CFR part 63, Subpart S) standard following our risk and technology review 

provides an ample margin of safety to protect public 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 significant form of residual risk remaining after 

implementation of maximum achievable control technology (MACT) in the category. The final 

risk assessment1

 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 impacts the subpart S source category were less 

than the target organ specific hazard index threshold of concern (TOSHI of 1). 

We analyzed the potential for emissions reductions at the emission process groups responsible 

for most of the residual risk within the source category by evaluating available control 

technologies and their capabilities for further reductions of the residual 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 reductions for these pollutants and 

processes would result in the most appreciable reductions in risk. We identified technologies 

that could potentially reduce cancer risk associated with kraft wastewater 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 resulting risk reduction benefits are highly uncertain. 

With respect to the risk from hexachloroethane 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 conclude that the risk originally assessed from that 

emission group is not present. See Attachment 1 for details. 

Next we evaluated the potential costs, environmental 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 effectiveness 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 potential for emissions reductions and could 

meaningfully reduce risk. Considering the cost, environmental, and energy impacts of the only 

current means of further reducing risk associated with kraft wastewater acetaldehyde and 

naphthalene emissions (incremental condensate treatment efficiency improvement, or steam 

stripping), it is our conclusion that currently there are no feasible options for increasing the 

margin of safety under CAA section 112(f)(2) from the kraft wastewater emissions process 

group. For papermaking, two options were evaluated for the further reduction of residual risk: 

(1) a new substance review work practice, and (2) numerical emission 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 for 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 usage and wastewater impacts at mills needing to install a screw 

press to remove liquid from the papermaking stock. Although not cost-effective under a section 

112(f) analysis, the EPA intends to evaluate papermaking in a future sector rule proposed under 

section CAA 112(d)(2) and (3) authority, and that evaluation could reach different conclusions. 

Based on this analysis, we conclude that the current standard protects public health with an 

ample margin of safety. 
Attachment 1 

Ample Margin of Safety Analysis for Pulping and Papermaking Emission Process Groups 
Date: 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 Protection 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 accordance with section 112(f)(2) of the Clean Air Act 

(CAA). The EPA proposed the subpart S residual 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 standards 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 which the standards are set (unless a more stringent 

standard is required to prevent, taking into consideration costs, energy, safety and other relevant 

factors, an adverse environmental effect). In the ample margin of safety decision process, the 

agency again considers all of the health risks and other health information considered in the 

acceptability determination. Beyond that information, additional factors relating to the 

appropriate level of control are also considered, including costs and economic impacts of 

controls, technological feasibility, uncertainties and any other relevant 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 determination at proposal, the EPA referred to the 

conclusions from the technology review performed for CAA section 112(d)(6) that no 

technologies (beyond those already in place) were identified for reducing HAP emissions from 
5

pulp and paper production processes other than for kraft condensates. The EPA proposed 

amendments to the kraft condensate standards under section 112(d)(6) that would have achieved 

incremental emissions reductions. The incremental risk reductions associated with the HAP 

reductions proposed for kraft condensates were not specifically quantified. The EPA concluded 

that the current subpart S standard (regardless of the amendments to the kraft condensate 

standards proposed under 112(d)(6)) protects public health with an ample margin of safety. (76 

FR 81344). 

This memorandum provides additional details relevant 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 storage, wastewater and bleaching as the drivers 

for chronic cancer risks. Although not listed in the risk report as a driver for chronic cancer risks, 

acetaldehyde is of importance for chronic cancer risk and was listed as the predominant HAP 

driver for chronic and acute non-cancer risks. Out of the 45,000 tons/yr of HAP in the inventory 

for subpart S (of which 86 percent is methanol), the risk report noted 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, tons/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 cancer risk by emission process group. As shown 

in Appendix A, the vast majority of the cancer 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 with 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 the cancer incidence. The subpart S inventory was 

queried to cross-check which processes emit the three risk-driver HAP shown in Table 1. The 

majority of HCE emissions were associated with kraft bleaching processes. Papermaking and 
6

kraft wastewater were responsible for approximately 70 percent of the acetaldehyde and 

naphthalene emissions. Thus, any significant 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 category prior to MACT implementation were 

230,000 tpy. As shown in Figure 1 below, papermaking and wastewater emissions are significant 

in terms of their post-MACT total mass of emissions of all pollutants. Kraft pulping emissions 

are already well-controlled, and therefore, significant reductions in emissions or risk would not 

be achieved through additional controls 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 technology review (RTR). 

A separate memorandum provides mill-by-mill details on the inventory changes requested. The 

inventory revisions were reviewed and it was concluded that the net effect of the inventory 

revisions would influence risk in the downward direction. Risks were not remodeled for the 

subpart S source category since EPA had previously concluded that risks from the subpart S 

0

2000

4000

6000

8000

10000

12000

14000

16000

18000

Total HAP, tpy

Figure 1.  Nationwide HAP Emissions by Subpart S Process

Total = 45,000 tpy
7

source category were acceptable and the inventory revisions would only serve to reduce risk. For 

the ample margin of safety determination 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 discussed in the response-to-comments document. 

(EPA 2012b) 

(2) A more-detailed review of the risk driver pollutants and processes (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-trichloroethane, carbon tetrachloride) by 99 percent 

or greater. Nationwide chlorinated HAP emissions from bleaching (other than chloroform) are 

the residual emissions remaining after implementation 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 hypochlorite to chlorine dioxide (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 the 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 processes. 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 addition, nearly all HCE emissions have been eliminated from the 

modeling inventory. It is expected 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 measures for reducing HAP emissions from kraft 

wastewater processes: (1) incremental improvement in condensate treatment efficiency, and (2) 

steam stripping of wastewater streams. 

Incremental Improvement in Condensate Treatment Efficiency. Emissions from kraft 

wastewater operations are limited 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 kraft 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 kraft condensates are steam stripping and biological 

treatment. Mills using biological treatment systems designed for wastewater treatment (e.g., 

aerated stabilization basins or activated sludge treatment) are required to discharge condensate 

below the liquid surface of a biological treatment system. 

The costs, environmental, and energy impacts of more stringent 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 efficiency from 92 to 94 percent would reduce 

nationwide acetaldehyde emissions by approximately 23 tons/yr. The baseline emissions 

estimates for acetaldehyde and naphthalene from 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 naphthalene 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 already a post-control value.2

 Thus risk associated with naphthalene from 

wastewater could be reduced by 1.7/6.6 = 26 percent through an incremental increase in 

condensate treatment to 94 percent. The cost associated with these risk reductions is documented 

in the cost impacts memo, and is $423 million capital cost and $85.1 million per year annualized 

cost. The cost effectiveness of this incremental increase is $37,000/ton of HAP reduced 

considering all HAP (including methanol). However, 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 technology 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 usage would increase by 113,685 million British thermal 

units per year (MMBtu/yr) and steam energy use 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 SO2

 1,402,084 tons/yr CO2eq for GHG 

These costs, environmental, and energy impacts were considered in EPA’s decision to 

abandon the proposed incremental increase in condensate control 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 section 112(f) ample margin of 

safety analysis, the costs ($3.4 million/ton), environmental, and energy impacts are compared to 

the 23 tons/yr reduction in acetaldehyde emissions (and associated 5 percent reduction in risk) 

and 1.7 tons/yr reduction in naphthalene emissions (and associated 26 percent reduction in risk 

from naphthalene) for kraft 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 highest 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 wastewater sources, no 

naphthalene cancer risk estimates exceeded 1x10-6 for kraft wastewater sources. The highest 

cancer risk estimate for a kraft wastewater source was 6x10-7, which if reduced by 26 percent 

would drop to 4x10-7. 

Other Technological Improvements. We are unaware of any feasible technological 

improvements beyond incrementally improving the kraft condensate treatment efficiency. 

Pollutants entering the wastewater treatment system come from 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 liquids 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 prevention (with the possible exception of eliminating 

these HAP from papermaking additives, as discussed below). As noted in public comments, kraft 

mills have already undertaken a substantial engineering effort to collect the kraft condensate 

streams containing the highest HAP concentrations and consolidate HAP in the condensate 

streams for treatment under §63.446(e)(2). Concentrating and minimizing the volume of HAPladen streams to be treated is particularly important if a steam stripper is the treatment method 

because of the boiler steam demand needed to power the stripper. Generation of steam in boilers 

is an energy impact of steam stripping and results 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 systems by consolidating the liquid streams containing these HAP 

into a single stream a new steam stripper could 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 (capital) and $2,241,900/yr (annualized).4

 Using these costs, the 

nationwide annualized cost for the 73 kraft mills 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 percent of the risk associated 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 every acetaldehyde and naphthalene 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 stripper 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 technologies other than steam 

stripping could substantially reduce 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 and preparation systems, paper or paperboard machines, paper 

machine white water system, broke recovery systems, and the systems involved in calendering, 

drying, on-machine coating, slitting, winding, and cutting. 

During the original subpart S rule development, EPA evaluated two undemonstrated 

control measures that could potentially reduce HAP emissions from papermaking: (1) removal of 

HAPs from the pulp stock and white water before the papermaking system (e.g., with a white 

water steam stripper); and (2) control of papermaking system vent streams through vent gas 

collection and incineration. Analysis of these control options concluded that there are no 

demonstrated methods for removing HAPs from the 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 noted with these two control options included 

fiber clogging of the steam stripper columns and 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-containing 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 additive substitution. It was concluded that additives 

did not contribute significantly to HAP emissions from the paper 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 attributable 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 suppliers are continually working 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. Therefore, 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, Part I Information Collection Request (ICR) 

data along with best available control technology (BACT) determinations for papermaking were 

examined to determine if there have been developments in practices, processes, or controls 

applicable to papermaking systems since subpart S promulgation in 1998. (RTI 2011b) The only 

available measures for reducing papermaking HAP emissions include process 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 kraft condensates. Though not as significant prior 

to MACT, as shown in Figure 1 above, papermaking is now estimated to be one of the largest 

sources of HAP emissions remaining in the pulp and paper production 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 the pulp stock is bleached or unbleached. Emissions 

may also vary depending on the type on paper machine (e.g., Fourdrinier, twin wire, cylinder, 

tissue, etc) but little emissions data are available to characterize the effects 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 specific paper machine design. 

The only potentially feasible methods for reducing risk-driver HAP emissions from 

papermaking include: (a) work practices to reduce naphthalene and acetaldehyde amounts in 

papermaking additives; and (b) reducing the concentration 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 collected through enclosure of the paper machine and 

incinerated. Incineration would be cost-prohibitive and result in energy and secondary air 

emission impacts from fuel burning. No mills with 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-driver HAP) were included in the risk modeling 

emissions inventory. Most of the paper machine emissions in the inventory were estimated using 

emission factors. Acetaldehyde emission factors 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 detectable naphthalene. (NCASI 2010) We are 

uncertain regarding how much of the nationwide acetaldehyde and naphthalene HAP emissions 

(943 tons/yr) in the inventory are attributable to papermaking additives versus HAP in the 

incoming papermaking stock. For the ample margin of safety analysis, we partitioned this 

quantity by subtracting out the acetaldehyde and naphthalene content of HAP additives reported 

in the ICR responses. As shown in Appendix D, a calculated nationwide total 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 fraction 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 for subpart S to require mills to implement a 

“new substance review” work practice standard. This work practice could apply to all types of 

paper machines and require mills to develop and implement a substance review program that: 

 Includes a process for identifying the HAP of concern in additives, 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 formulation 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 rate was based on the total compensation 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 capital 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 additive substitute would have a similar cost. 

However, the true cost is uncertain. The cost to establish the 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 reviews 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 cost. Table 2 presents the capital and annual cost 

estimates for the HAP additives work practice. 

 
13

Table 2. Cost of HAP Additives 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 (assume 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 mills 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 paper product rather than being emitted), the cost effectiveness 

would be $19,450/ton. Looking closer at the 100 tons/yr 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 modeling 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 assume 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 (provided the uncertainties of correlating air 

emissions of acetaldehyde and naphthalene to emissions emanating into the air could be 

overcome), or an air emissions limit. Air emissions 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 average) on dry ends with flow rates averaging 184,000 

and 217,000 actual cubic feet per minute (acfm) per machine, respectively. An average of 3 

additional vents following the dryer was reported with average flows of 84,058 acfm. (ICR 2011) 

Performing three, 1-hour sample runs on this number of vents is very labor-intensive and results 

in a large number of samples to be handled, analyzed, and reported. Emissions testing costs for 

sampling of papermaking vents are expected to be extreme (compared to tests of other process 
14

equipment where one or only a few vents are tested). Testing costs relate to the labor (e.g., time 

and travel) and number of samples to be collected and analyzed. 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 testing contract firms have experience with the NCASI 

sampling methods (though this pool of contractors should have increased with implementation of 

the wood products MACT). Test contract firm availability can also drive up testing costs due to 

demand should, for example, 156 mills all require 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 interest, 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 technological changes needed to 

reduce the concentration of HAP in the papermaking 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 capital 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 pulping 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 overall annualized cost for a numeric emission limit 

would be $21,269,385/yr. When compared to the maximum theoretical HAP risk-driver 

reduction of 943 tons/yr (assuming - with considerable uncertainty - that 100 percent of the 

emissions from acetaldehyde and naphthalene could be mitigated), the cost-effectiveness is 

$22,560/ton. The screw press technology 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 additional fresh water use into papermaking) 

would result in water usage impacts and increased wastewater effluent volume. 

Papermaking risk reductions. Of the 398 papermaking emission units with reported 

acetaldehyde emissions in the inventory, there were 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 negligibly 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 naphthalene cancer risk estimates exceeded 1x10-6 for 

papermaking sources. The highest cancer risk estimate 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 following 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 ample 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 meaningful 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 cancer 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 were identified for kraft wastewater sources. 

 No feasible options were identified for increasing the ample margin of safety for 

papermaking sources considering cost, potential 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 occupational and industry group, March 2012. 

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

ERG 1997a Memorandum from C. Leatherwood, Eastern Research Group (ERG), to P. 

Lassiter, U.S. EPA. September 10, 1997. Maximum Achievable Control 

Technology (MACT) Determination For Papermaking Systems. Air Docket A–

95–31, IV–B–8. 

ERG 1997b Memorandum from C. Leatherwood, 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 Assessment for Pulp and Paper Source Category. 

December 2011 

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

July 2012. 

EPA 2012b U.S. EPA. National Emission Standards for Hazardous Air Pollutants from the 

Pulp and Paper Industry (40 CFR Part 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-Pacific 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) Technology 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 Subpart S Risk and Technology Review. 
Appendix A 

Cancer Risk by Emission Process Group 

 
Pulp & Paper - MIR by source type based on actual emissions

Maximum Overall Papermaking

Wastewater 

(Kraft)

Bleaching: 

Kraft

Kraft Pulp 

Storage Paper Stock Prep

Mechanical 

Pulping

Kraft Pulping: 

Digester LVHC Soda Misc

Kraft Pulping: 

Washing

Cancer RiskMaximum (in 1 million) 10 5 9 4 9 8 7 6 4 4 Number of people

>= 100 in 1 million 0 0 0 0 0 0 0 000

>= 10 in 1 million 40 0 0 0 0 0 0 000

>= 1 in 1 million 76,000 15,946 11,658 951 29 458 1,071 1,436 2,894 274 

Incidence 0.01 0.005 0.003 0.001 0.0002 0.0002 0.0003 0.0003 0.0002 0.0004 

 Precent of Overall Incidence 50% 26% 11% 1.6% 1.9% 2.7% 3.3% 2.2% 3.7% 

Sector MIR = 10 (in a million) Cancer Incidence Contribution:

87% Papermaking + Wastewater (Kraft) + Bleaching:Kraft

96% Papermaking + Wastewater (Kraft) + Bleaching:Kraft + Bleaching:Sec Fiber

Cancer_Inc_Contribution 
Pulp & Paper - MIR by source 

Cancer RiskMaximum (in 1 million)Number of people

>= 100 in 1 million

>= 10 in 1 million

>= 1 in 1 million

Incidence Precent of Overall IncidenceSector MIR = 10 (in a million)

Kraft Pulping: 

Decker

Kraft Pulping: 

O2 Delig HVLC

Kraft Pulping: 

LVHC Paper Misc

Wastewater 

(Mechanical)

Wastewater 

(General)

Kraft Pulping: 

Evaporator 

LVHC

Causticizing: 

White Liquor

Kraft Pulping: 

Incinerator

Kraft Stock 

Washing

Causticizi

Misc

2 2 1 1 1 1 1 1 1 1 0.9 

0 0 0 0 0 0 0 000 0 0 0 0 0 0 0 0 000 0 

77 71 293 126 108 72 39 3 4 5 0 

0.0001 0.00007 0.0002 0.00002 0.00007 0.00004 0.00001 0.00006 0.00006 0.00006 0.00009 

1.2% 0.7% 1.9% 0.2% 0.7% 0.4% 0.1% 0.6% 0.6% 0.6% 0.9% 

Cancer_Inc_Contribution 
Source Description

% Source Incidence for by

EPG for Facilities with

excess cancer risk > 1 in a

Million

Source Incidence for facilities with

MIR risks > or equal to 1 in a million

Papermaking 33.51 3.08E‐03Wastewater (Kraft) 28.52 2.62E‐03Bleaching 14.69 1.35E‐03Kraft 10.41 9.57E‐04Soda Misc 2.26 2.07E‐04Mechanical Pulping 1.62 1.49E‐04

Total 0.008

2025303540

Figure A1. Percent Cancer Incidence by Emission Process Group for Facilities with Excess Cancer 

>1 in a Million (Incidence = 0.008)

05

101520

25

Papermaking Wastewater (Kraft) Bleaching Kraft Soda Misc Mechanical Pulp
Appendix B 

February 24, 2012 NCASI Letter Regarding 

Hexachloroethane Emissions from Brownstock Washers and Bleach Plant Sources 

 
ncasi NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC. 

SOUTHERN REGIONAL CENTER 

Mailing and Street Address: 

402 SW 140th 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, hexachloroethane (HCE) emerged as a riskdriving compound from brownstock washers and bleach plant sources. After an initial 

review of available information on HCE emissions from these sources, NCASI has 

determined that reported emissions are based upon limited emissions data derived from 

stack tests conducted in 1993. 

Many facilities have used the information presented 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 cases, NCASI does not calculate a recommended 

emission factor and instead provides the minimum and maximum observed values. 

Table 1. Hexachloroethane Emissions from Brownstock 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 hardwood diffusion washer vent and in a foam breaker vent at 

a softwood diffusion washer system. Measured emissions ranged from 0.032 to 0.13 

B-1
lb/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 detail 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 confirmation” 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 comprised 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 Brownstock Washers and ECF Bleach Plant Vents 

Of the relevant process units, hexachloroethane 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 database. NCASI Technical Bulletin No. 973 

(2010) serves as the foundational document for the Air Toxics Database; it contains the 

following passage regarding HCE emissions from brownstock washer sources: 

B-2
 

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 highly 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 was also detected in the bleach plant 

scrubber vent at the same mill (Mill IC). 

Regarding bleach plant vents, Technical Bulletin 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 confirmed by GC/MS)...The sole data point 

for HCE emissions from ECF bleach plants should be used with caution. More 

testing would be needed to confirm its presence. 

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

known that hexachloroethane dechlorinates in a reducing environment (Curtis and 

Reinhard 1994). Thus, there is no potential 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 presence of ferric chloride at elevated temperature. HCE is 

also a co-product in the production of tetrachloroethylene 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 significant availability of free chlorine to further 

chlorinate the precursors, if they are present. 

Based upon the above and our understanding 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 facilities 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. 

 

B-3
Summary 

Until new test results become available, HCE emissions from brownstock washer 

sources and bleach plant vents should be removed 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 vents 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-ECF 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. Research Triangle Park, NC: National 

Council of the Paper Industry for Air and Stream Improvement, Inc. 

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

Emissions Database. 2012 update. Research Triangle Park, NC: National Council 

of the Paper Industry for Air and Stream Improvement, Inc. 

U.S. Department of Health and Human Services. 1997. Toxicological Profile for 

Hexachloroethane. September 1997. Atlanta, GA: Agency for Toxic Substances 

and Disease Registry, Division of Toxicology/Toxicology Information Branch. 

B-4
Appendix C 

NEI Data Revisions Expected to Reduce Risk 
Appendix C. NEI Data Revisions Expected to Reduce Risk

Increased release height

Increased fugitive 

area Reduced emissions Increased stack gas temperature Increased stack gas velocity or flow 

NEI32869A 109 0177 Domtar Paper Company LLC Hawesville KY HCE (80%) Kraft Pulp Storage Reduced acetaldehyde, formaldehyde from paper 

machines, pulp dryer

NEI18334 186 0197 Georgia-Pacific Corp. Pennington AL Acetaldehyde (18%), 

Formaldehyde (17%), Carbon tetrachloride (14%), Naphthalene (13%)

Kraft Pulping: Evaporator LVHC, Kraft Pulping: BL Tanks HVLC, Wastewater (Kraft), Kraft Pulping: Washing, Kraft Pulping: Decker, Bleaching: Kraft

Increased stack height for SDT and multiple subpart S units (50) when changed their release point type from fugitive to stack

Reduced 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 from SDT

Increased stack temperature for SDT and multiple subpart S units (46) when changed their release point type from fugitive to stack

Increased stack velocity/flow for SDT and multiple subpart S units (55) (56 if include 

just stack flow of NCG incineration) when 

changed release point type

Deleted recodigester, scredecker, caustlonger in servchloroform, fnaphthalene

NEI40282 206 0174 Blue Ridge Paper Products 

Inc.

Canton NC Acetaldehyde (44%), 

Formaldehyde (32%)

Papermaking, Kraft Pulping: O2 delignification HVLC

Reduced acetaldehyde, formaldehyde from paper machinesReduced 1,2-dichloroethane from BSW

NEIWI7720116, 

NEI46739, & 

NEI42963

154 0182 NewPage Corporation Wisconsin 

Rapids

WI Acetaldehyde (79%), 

Formaldehyde (12%)

Wastewater (Kraft) NEIWI7720116: 

Reduced acetaldehyde, chloroform, formaldehyde, 

methanol, catechol, cresol, ethylene glycol, phenol

NEI Revisions Which May Reduce Risk

Cancer risk driver (% of risk)

(Source: AECOM5)

Cancer risk driver (source 

group)

(Source: AECOM5 Survey NEI RTI code Comment no. Company name Mill city Mill state )

NEI42963 methanol, catechol, cresol, ethylene glycol, phenol

from WWTNEI46739: Reduced chloroform, formaldehyde, 7 other HAPs from causticizing misc

NEIME0250002 363 0205 Madison Paper Co. Madison ME Naphthalene (60%), 

Acetaldehyde (23%)

Mechanical Pulping Increased stack height of 

pressurized groundwood emission units when replaced them with stack equivalentsIncreased stack height of boilers

Increased stack temperature for pressurized groundwood emission units when replaced them with stack equivalents

Increased stack velocity/flow for pressurized groundwood emission units when replaced them with stack equivalentsIncreased stack velocity/flow of boilers

Deleted fugitgroundwood lower emissioformaldehydetc.)

NEI42695 617 0180 Domtar Corporation Nekoosa WI Beryllium compounds (84%) Kraft Pulping: Digester LVHC 

NEI41552 142 Packaging Corp. of America Counce TN Acetaldehyde (98%) Wastewater (Kraft) Reduced acetaldehyde from paper machines (91 

records) and ASB (1 record)

Increased velocity and flow of BL tanks (4 unique records)

Deleted fugitreplaced) (2 u

NEI47091 606 Buckeye Technologies Inc. Perry FL HCE (78%) Kraft Pulping: Washing, 

Bleaching: Kraft

Reduced metals, chloroform, 11 other HAPs from RF, SDT, LK

Reduced metals from boilers

NEI40600 188 0209 Georgia-Pacific Corp. Toledo OR Acetaldehyde (33%), 

Formaldehyde (12%), 1,1,2-Trichloroethane (11%), 

Tetrachloroethene (10%)

Papermaking, Kraft Pulping: BL Tanks HVLC, NSSC Pulping

Reduced acetaldehyde, formaldehyde, chloroform, methanol, 19 other HAPs from black liquor storage tanks

Deleted fugitreplaced)

NEI13363 133 0147 Simpson Tacoma Kraft Co Tacoma WA Formaldehyde (71%), 

Acetaldehyde (18%)

Papermaking Reduced acetaldehyde, formaldehyde from WWT 

NEI41314 166 0190 International Paper Co. Georgetown SC Acetaldehyde (39%), HCE (25%) Kraft Pulping: Decker, Bleaching: 

Kraft, Causticizing: Slaker, 

Deleted reco(includes ace

Wastewater (Kraft), Kraft Pulping: LVHC

naphthalene

NEI40686 100 0175 Domtar Corporation Johnsonburg PA HCE (50%), Acetaldehyde (22%), 

Formaldehyde (18%)

Bleaching: Kraft, Causticizing: Misc & Lime Mud

NEI33135 & NEI706 145 NewPage Corporation Luke MD Acetaldehyde (29%), Carbon 

tetrachloride (21%), Formaldehyde (14%)

Kraft Pulping: Decker Increased stack heights for decker, 

knotter, pulp storage, black liquor tanks, causticizing when changed release point type

Reduced formaldehyde from white liquor processing

Increased stack temperature for decker, knotter, pulp storage, black liquor tanks, causticizing when changed release point type

Increased stack velocity/flow for decker, knotter, pulp storage, black liquor tanks, causticizing when changed release point type

Deleted recoboilers) (inclumethanol, ca

NEI41599 106 0185 Domtar Paper Company LLC Kingsport TN HCE (50%), Acetaldehyde (42%) Bleach Plant, Wastewater Reduced acetaldehyde, methanol from WWTP1/2, 

formaldehyde from WWTP2

NEI8178 430 0206 Georgia-Pacific Corp. Rincon GA Acrylonitrile (66%), 

Acetaldehyde (21%)

Papermaking, Wastewater: General

Reduced acetaldehyde, formaldehyde, chloroform, methanol, toluene, benzene, MIBK, CS2 from WWT, 

decker

Deleted uncomachines (to 

NEI8196 243 0210 Georgia-Pacific Corp. Brunswick GA Acetaldehyde (73%) Wastewater: Kraft Increased stack heights for lime 

mud filter, lime slaker

Reduced acetaldehyde, naphthalene from WWT Increased stack temperature for lime 

mud filter when changed its release 

point type

Increased stack velocity/flow for lime mud filter when changed release point type

NEI6450 147 MeadWestvaco Evadale TX Acetaldehyde (47%), 

Formaldehyde (29%)

Papermaking Increased fugitive 

area for WWT and paper machines

Reduced acetaldehyde, formaldehyde emissions from paper machines

NEI42357 139 Port Townsend Paper Corp. Port Townsend WA Acetaldehyde (97%) Wastewater: Kraft Reduced acetaldehyde from ASB

Reduced acetaldehyde, metals, naphthalene from LKReduced arsenic from SDT

Reduced metals from boiler

Increased release temperature for ASB Increased stack velocity for RF 

C-1
Increased release height

Increased fugitive 

area Reduced emissions Increased stack gas temperature Increased stack gas velocity or flow 

NEI Revisions Which May Reduce Risk

Cancer risk driver (% of risk)

(Source: AECOM5)

Cancer risk driver (source 

group)

(Source: AECOM5 Survey NEI RTI code Comment no. Company name Mill city Mill state )

NEI18660 196 0202 Domtar Industries Ashdown AR Formaldehyde (35%), 

Acetaldehyde (33%), HCE (30%)

Kraft Pulping, Papermaking, Bleaching

Reduced acetaldehyde from O2 delignification 

NEI45182 105 0190 International Paper Co. Springfield OR Formaldehyde (75%), 

Acetaldehyde (16%)

Kraft Pulping: Digester LVHC Reduced acetaldehyde, formaldehyde, chloroform, 

methanol, and 16 other HAPs from digester chip 

bin and LVHC

NEI12407 229 0183 Verso Paper Corp. Sartell MN Cadmium (26%), Formaldehyde 

(20%), Nickel (13%), Acetaldehyde (13%), Arsenic 

(13%)

Kraft Pulping: Incinerator, Mechanical Pulping, Papermaking

Deleted recometals, form

NEI40247 174 0190 International Paper Co. Riegelwood NC Acetaldehyde (40%), 

Formaldehyde (38%), HCE (19%)

Kraft Pulping: Washing, Bleaching: Kraft, Kraft Pulping: Digester LVHC

Reduced acetaldehyde, formaldehyde, chloroform, methanol, and 16 other HAPs from digester chip bin

Deleted reco(includes acemethanol)

NEI42482 436 0169 Georgia-Pacific Corp. Green Bay WI Formaldehyde (87%) Bleaching Reduced form

Tower 2)

NEI6261 610 0184 Verso Paper Corp. Jay ME Acetaldehyde (67%), 

Naphthalene (27%)

Wastewater, Mechanical pulping, Papermaking

Reduced acetaldehyde, naphthalene, CS2, propionaldehyde from WWT

NEI33883 155 0192 NewPage Corporation Escanaba MI Acetaldehyde (49%), 

Formaldehyde (27%), 

Naphthalene (14%)

Wastewater treatment Reduced acetaldehyde, formaldehyde, naphthalene 

from WWT

NEI8186 531 0190 International Paper Co. Savannah GA Formaldehyde (72%), 

Acetaldehyde (13%)

Kraft Pulping: LVHC, Wastewater Reduced acetaldehyde, formaldehyde, chloroform, 

methanol from LVHC

Deleted reco(includes ace

Note: Highlighted cells link the risk drivers to the NEI data revisions expected to reduce risk.

C-2
Appendix D 

Acetaldehyde and Naphthalene HAP Additives Calculations Based on ICR Data 
Appendix D. Documentation of HAP Amounts in Additives1,2

NEISiteID Additive HAP_content Amount

Amount_

Units

HAP_ 

Amount3-5

HAP_Amount_

Units NEI_Emissions_tpy

NEI_Emissions_

lb/year Substitutes

Substitute 

OthHAP HAPAdditivesCommen

NEI18652 PVAC Latex Acetaldehyde - <0.095% 3151687 lb/year 2,994 lb/year 8.3 16,600 UK UK

NEI40488 Dye Acetaldehyde - <= 2% CBI lb/year x lb/year UK UKNEI40720 Vinyl Acrylic Binder Acetaldehyde- 0.15% 756 lb/year 1 lb/year UK UKNEI41599 Biocide Napthalene - 1.1%, by weight 972 lb/year 11 lb/year No NA Biocide for the aluminum sulfate solution storag

sulfate is metered into the pulp on the paper macinto the paper product.

NEI42329 Release Agent Naphthalene - 0-3% 555 gal/yr 81 lb/year UK UK No other additives containing HAPs greater than 

used at NPI in 2009

NEI42730 Screen Wash Naphthalene - 10% 360 lb/year 36 lb/year no Other chemicals have been tried; however, smal

used

NEI46814 Felt wash Napthalene <5% 271 lb/day 1,250 lb/year 0.6 1,250 UK UK NEI6057 Desizer/rewetter Napthalene - 1% 46000 lb/year 460 lb/year 0.3 585 UK UKNEI8560 Microbiocide Naphthalene - 1.1% 7240 lb/year 80 lb/year UK UKNEICT3102 Emulsifier Acetaldehyde <900 ppm 7,952,100 lb/year 7,157 lb/year lbs No

NEIGAT$3911 Felt Cleaner Napthalene-80% 234011 lb/year 187,209 lb/year

1. 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:Naphthalene

1.16 g/ml

0.002204623 lb/g

3785.412 ml/gal

9.680671377 lb/gal

5. Where the HAP calculated from the additive exceeded the NEI emissions estimate, used the NEI emissions estimate as the HAP amount from additives.