Survey Overview Document Form Approved 02/17 / 2011

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### 1 

## Pulp and Paper Sector Survey

Overview

Survey c overage

. The pulp and paper sector survey is a three

- part information request that a pplies for pulp and/or pap er/paperboard mills that are a major source or synthetic area source of hazardous air pollutant (H AP) emissions that: (a) Perform chemical wood pulping (kraft, sulfite, soda, or semi

- chemical), or (b) Perform mechanical, groundwood (e.g., thermomechanical pulping (TMP), refiner mechanical pulping (RMP)), secondary fiber, and non

- wood pulping, or (c) Pe rform bleaching, or (d) Manufacture paper or paperboard products.

As defined in 40 CFR Part 63, subpart A,

“ Major source ” means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or h as the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants, unless the Administrator establishes a lesser quantity, or in the case of radionuclides, different criteria from those specified in this

sentence.

A “ synthetic area source” is a stationary source which is subject to federally

- enforceable conditions that limit its potential to emit to below major source thresholds

.

Mills exempt from the pulp and paper sector survey

. If your mill is not a major source or synthetic area source of HAP emissions, then you should complete the form in Attachment 1 and email (or fax) it to
Bill Schrock of the U.S. Environmental Protecti on Agency (EPA) at schrock.bill@epa.gov

. If your mill

is a true area source
, then your operating permit should reflect that your mill is not subject to either of the pulp and paper national emissions standards for hazardous air pollutants ( NESHAP ) (40 CFR P art 63, subpart S or MM). You are not required to complete any part of the pulp and paper sector survey if you

submit valid documentation of true area source status.

If your mill is a major source or synthet ic area source, but was not operational in 2009 (and remains closed) or does not produce pulp, perform bleaching, or manufacture paper or paperboard products, then you should complete the form in Attachment 1 and email (or fax) it to Bill Schrock of EPA at schrock.bill@epa.gov explaining the status of your mill. You are not required to complete any part of the pulp and paper sector survey.

Survey structure and due dates

. T he pulp and paper sector survey is to be completed in a series of

Microsoft Excel s preadsheet files that are divided into several worksheets (“tabs” within each spreadsheet). You must complete certain portions of the survey

, depending on the type of mill you

operat e. Part I applies for all mills, except true area source and non

- operati onal mills, as noted above. Part II requests an NEI update for all emissions units and applies for all major source mills. Synthetic area

source mills are not required to complete Part II. Part III applies for major and synthetic area source mills

operat ing chemical recovery combustion sources. Parts I and III request process data for the emissions

units listed in Attachment 1 of the instructions for each p art. Additional spreadsheets are provided for submittal of continuous emissions monitoring system (CEMS) data or control measure cost information (for Part I and Part III).Survey Overview Document Form Approved 02/17 / 2011

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### 2 The pulp and paper sect or survey is divided into three parts, each with different due dates as specified in

Table 1 below.

Table 1. Components of the Three

- Part Pulp and Paper Survey

Part Short Description Deadline 1 Contents of Data Submittal

I Mill Overview and Subpart S Dat a

a. Notification of true area source

, non

- operational , or

non

- applicable status 20 day s

- Attachment 1 of survey overview

b. Completion of Part I da ta submittal 30 days 2

- P&P survey_PI.xls

- P&P CEMS _PI.xls 3

- P&P costs OPTIONAL_PI.xls

- Flow diagrams

- Test reports 3

- Water modeling

II NEI Update [Part II is not required for synthetic area sources.] 10 0 days

- P&P NEI update.xls

or

- P &P NEI blank.xls

III Chemical Recovery Combustion Sources 180 days

- P&P CEMS _PIII.xls

- P&P costs OPTIONAL_PIII.xls

- P&P survey_PIII.xls

- Test reports

- PM bubble calculations

1 The deadlines indicated are in terms of calendar days following the date stam ped on the Section 114 letter accompanying this survey. Specific dates are specified in the letter.

2 An additional 15 days is provided for up to 40 percent of the mills owned by pulp and paper companies operating multiple (more than two) mills. For exam ple, for a company owning 10 pulp and paper mills, the Part I survey response deadline for 4 of these mills may be extended until 45 days following the date stamped on the Section 114

letter

. 3 Mills required to complete Part III may postpone until the dea dline for Part III submittal of emissions test data and CEMS data required for the emission units listed in Part I Attachment 1 for the following pollutants: PM, PM 2.5 , TRS, NOx, SO 2 , and CO.



### P lease complete the survey for the facility listed in the Sec tion 114 letter you received in the mail. If you received more than one Section 114 letter for multiple facilities, you must create a separate survey response for each facility. If you have not already received or downloaded a copy of the survey spreadsh eets, they can be downloaded here: https://icr2010.rti.org/Industries/PulpPaper.aspx

Base year for survey data. Use the 2009 calendar year as the base year for all survey responses (e.g., 2009 emissions inventory, 2009 capacity, 2009 equipment configurations, etc

. ), unless another year is specified in the instructions (e.g., for emissions test data).

Definitions

. For reference, Attachment 2 to this overview contains the regulatory def initions from the kraft pulp mill new source performance standards (NSPS) (40 CFR Part 60, subpart BB), chemical recovery combustion source NESHAP (40 CFR Part 63, subpart MM), and pulp and paper production NESHAP (40 CFR Part 63, subpart S) , and selected definitions from the NSPS and NESHAP General

Provisions

.

Acronyms/abbreviations

. Attachment 3 to this overview contains acronyms and abbreviations used throughout the survey instruction documents and associated spreadsheets.Survey Overview Document Form Approved 02/17 / 2011

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### 3 Certification form

. Attac hment 4 to this overview contains a certification form that you must complete, sign, date, and submit separately with each completed part of the survey, certifying that the statements and information provided in your responses to Part I, Part II, and Part III of the survey are (to the best of your knowledge) true, accurate, and complete.

Who do I contact with questions?

Should you have a question while completing the pulp and paper survey that you believe is not addressed in the survey instructions, you have some options:

1. (Preferred) Email your question to: ppsurvey@ rti.org

2. Contact the pulp and paper survey ho tline: 1

- 877

- 834

- 7065 (Hotline is staffed by RTI during normal business hours, Eastern Standard Time)

3. Contact Bill Schrock of EPA at schrock.bill@epa.gov (919

- 541

- 5032).

Under options 1 and 2, RT I staff assisting EPA with the pulp and paper survey will consult with EPA as needed to obtain a response for your question. Frequently asked questions (FAQs) will be posted on the survey webpage: https://icr2010.rti.org/Industries/PulpPaper.aspxSurvey Overview Document Form Approved 02/17 / 2011

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### 4 ATTACHMENT 1

DOCUMENTATION OF TRUE AREA SOURCE

, NON

- OPERATIONAL , OR

NON

- APPLICABLE STATUS

Facility Name on the

L etter from EPA :

Corrected Facility Name (if appli cable):

Address:



### Check an explanation below :


# □ I certify that the facility listed above is not a major source or synthetic area source of hazardous air pollutant emissions (HAP) emissions. The facility is a true area source of

HAP emissions. Documentation (such as a valid operating permit) confirm ing the true

area source status is attached.



# □ I certify that that facility listed above was not operational in 2009 (the base year for the pulp and paper sector survey), and that the facility remains non

- operational (closed). A brief explanation is p rovided in the area below:



# □ I certify that the facility listed above does not produce pulp, perform bleaching, or manufacture paper or paperboard products. A brief explanation is provided in the area

below:

Signature :

____________________________________________ Printed name : _________________________________________

Email and/or fax completed form to: Bill Schrock (USEPA) schrock.bill@epa.gov Fax: (919) 541

- 3470Survey Overview Document Form Approved 02/17 / 2011

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### 5 ATTACHMENT 2

NSPS and NESHAP Definitions

NSPS Subpart BB Definitions (40 CFR P art 60, § 60.281 ) :

(a) Kraft pulp mill means any stationary source which produces pulp from wood by cooking (digesting) wood chips

in a water solution of sodium hydroxide and sodium sulfide (white liquor) at high temperature and pressure. Regeneration of the cooking chemicals through a recovery process is also considered part of the kraft pulp mill.

(b) Neutral sulfite semichemical pulping operation means any operation in which pulp is produced from wood by cooking (digesting) wood chips in a solution of sodium sulfite and sodium bicarbonate, followed by mechanical defibrating (grinding).

(c) Total reduced sulfur (TRS) means the sum of the sulfur compounds hydrogen sulfide, methyl mercaptan, dimethyl sulfide, and dimethyl disulfide, that are released dur ing the kraft pulping operation and measured by

Method 16.

(d) Digester system means each continuous digester or each batch digester used for the cooking of wood in white liquor, and associated flash tank(s), blow tank(s), chip steamer(s), and condenser(s ).

(e) Brown stock washer system means brown stock washers and associated knotters, vacuum pumps, and filtrate tanks used to wash the pulp following the digester system. Diffusion washers are excluded from this definition.

(f) Multiple

- effect evaporator system means the multiple

- effect evaporators and associated condenser(s) and hotwell(s) used to concentrate the spent cooking liquid that is separated from the pulp (black liquor).

(g) Black liquor oxidation system means the vessels used to oxidize, with air or oxygen, the black liquor, and associated storage tank(s).

(h) Recovery furnace means either a straight kraft recovery furnace or a cross recovery furnace, and includes the

direct

- c ontact evaporator for a direct

- contact furnace.

(i) Straight kraft recovery furnace means a furnace used to recover chemicals consisting primarily of sodium and sulfur compounds by burning black liquor which on a quarterly basis contains 7 weight percent or less of the total pulp solids from the neutral sulfite semichemic al process or has green liquor sulfidity of 28 percent or less.

(j) Cross recovery furnace means a furnace used to recover chemicals consisting primarily of sodium and sulfur compounds by burning black liquor which on a quarterly basis contains more than 7 weight percent of the total pulp solids from the neutral sulfite semichemical process and has a green liquor sulfidity of more than 28 percent.

(k) Black liquor solids means the dry weight of the solids which enter the recovery furnace in the black liqu or.

(l) Green liquor sulfidity means the sulfidity of the liquor which leaves the smelt dissolving tank.

(m) Smelt dissolving tank means a vessel used for dissolving the smelt collected from the recovery furnace.

(n) Lime kiln means a unit used to calcin e lime mud, which consists primarily of calcium carbonate, into quicklime,

which is calcium oxide.

(o) Condensate stripper system means a column, and associated condensers, used to strip, with air or steam, TRS compounds from condensate streams from vario us processes within a kraft pulp mill.Survey Overview Document Form Approved 02/17 / 2011

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### 6 NESHAP Subpart MM Definitions (40 CFR Part 63, § 63.861) :

Bag leak detection system means an instrument that is capable of monitoring PM loadings in the exhaust of a fabric filter in order to detect bag failures. A bag leak detection system includes, but is not limited to, an instrument that operates on triboelectric, light scattering, light transmittance, or other principle to monitor relative PM loadings.

Black liquor means spent cooking liquor that has been sepa rated from the pulp produced by the kraft, soda, or semichemical pulping process.

Black liquor gasification means the thermochemical conversion of black liquor into a combustible gaseous product.

Black liquor oxidation (BLO) system means the vessels used to oxidize the black liquor, with air or oxygen, and the associated storage tank(s).

Black liquor solids (BLS) means the dry weight of the solids in the black liquor that enters the recovery furnace or

semichemical combustion unit.

Black liquor solids f iring rate means the rate at which black liquor solids are fed to the recovery furnace or the

semichemical combustion unit.

Chemical recovery combustion source means any source in the chemical recovery area of a kraft, soda, sulfite or

stand

- alone semiche mical pulp mill that is an NDCE recovery furnace, a DCE recovery furnace system, a smelt dissolving tank, a lime kiln, a sulfite combustion unit, or a semichemical combustion unit.

Chemical recovery system means all existing DCE and NDCE recovery furnaces , smelt dissolving tanks, and lime kilns at a kraft or soda pulp mill. Each existing recovery furnace, smelt dissolving tank, or lime kiln is considered a process unit within a chemical recovery system.

Direct contact evaporator (DCE) recovery furnace mea ns a kraft or soda recovery furnace equipped with a direct contact evaporator that concentrates strong black liquor by direct contact between the hot recovery furnace exhaust gases and the strong black liquor.

Direct contact evaporator (DCE) recovery furn ace system means a direct contact evaporator recovery furnace and any black liquor oxidation system, if present, at the pulp mill.

Dry electrostatic precipitator (ESP) system means an electrostatic precipitator with a dry bottom (i.e., no black liquor, wa ter, or other fluid is used in the ESP bottom) and a dry particulate matter return system (i.e., no black liquor, water, or other fluid is used to transport the collected PM to the mix tank).

Fabric filter means an air pollution control device used to cap ture PM by filtering a gas stream through filter media; also known as a baghouse.

Hazardous air pollutants (HAP) metals means the sum of all emissions of antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and seleni um as measured by EPA Method 29 (40 CFR part 60, appendix A) and with all nondetect data treated as one

- half of the method detection limit.

Hog fuel dryer means the equipment that combusts fine particles of wood waste (hog fuel) in a fluidized bed and

dir ects the heated exhaust stream to a rotary dryer containing wet hog fuel to be dried prior to combustion in the hog fuel boiler at Weyerhaeuser Paper Company’s Cosmopolis, Washington facility. The hog fuel dryer at Weyerhaeuser Paper Company’s Cosmopolis, Washington facility is Emission Unit no. HD

– 14.

Kraft pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a solution of sodium hydroxide and sodium sulfide. The recovery process used to regenerate cookin g chemicals is also considered part of the kraft pulp mill.

Kraft recovery furnace means a recovery furnace that is used to burn black liquor produced by the kraft pulping process, as well as any recovery furnace that burns black liquor produced from both the kraft and semichemical pulping processes, and includes the direct contact evaporator, if applicable. Includes black liquor gasification.

Lime kiln means the combustion unit (e.g., rotary lime kiln or fluidized

- bed calciner) used at a kraft or soda pu lp mill to calcine lime mud, which consists primarily of calcium carbonate, into quicklime, which is calcium oxide (CaO).Survey Overview Document Form Approved 02/17 / 2011

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### 7 Lime production rate means the rate at which dry lime, measured as CaO, is produced in the lime kiln.

Method detection limit means t he minimum concentration of an analyte that can be determined with 99 percent confidence that the true value is greater than zero.

Modification means, for the purposes of § 63.862(a)(1)(ii)(E)(1), any physical change (excluding any routine part replacemen t or maintenance) or operational change (excluding any operational change that occurs during a start

up, shutdown, or malfunction) that is made to the air pollution control device that could result in an increase in

PM emissions.

Nondetect data means, for the purposes of this subpart, any value that is below the method detection limit.

Nondirect contact evaporator (NDCE) recovery furnace means a kraft or soda recovery furnace that burns black liquor that has been concentrated by indirect contact with stea m.

Particulate matter (PM) means total particulate matter as measured by EPA Method 5, EPA Method 17 (§ 63.865(b)(1)), or EPA Method 29 (40 CFR part 60, appendix A).

Process unit means an existing DCE or NDCE recovery furnace, smelt dissolving tank, or l ime kiln in a chemical recovery system at a kraft or soda mill.

Recovery furnace means an enclosed combustion device where concentrated black liquor produced by the kraft or soda pulping process is burned to recover pulping chemicals and produce steam. In cludes black liquor gasification.

Regenerative thermal oxidizer (RTO) means a thermal oxidizer that transfers heat from the exhaust gas stream to the inlet gas stream by passing the exhaust stream through a bed of ceramic stoneware or other heat

- absorbing medium before releasing it to the atmosphere, then reversing the gas flow so the inlet gas stream passes through the heated bed, raising the temperature of the inlet stream close to or at its ignition temperature.

Semichemical combustion unit means any e quipment used to combust or pyrolyze black liquor at stand

- alone semichemical pulp mills for the purpose of chemical recovery. Includes black liquor gasification.

Similar process units means all existing DCE and NDCE recovery furnaces, smelt dissolving ta nks, or lime kilns at a kraft or soda pulp mill.

Smelt dissolving tanks (SDT) means vessels used for dissolving the smelt collected from a kraft or soda recovery

furnace.

Soda pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a sodium hydroxide solution. The recovery process used to regenerate cooking chemicals is also considered part of the soda pulp mill.

Soda recovery furnace means a recovery furnace used to burn black liquor produced by the soda p ulping process and includes the direct contact evaporator, if applicable. Includes black liquor gasification.

Stand

- alone semichemical pulp mill means any stationary source that produces pulp from wood by partially digesting wood chips in a chemical solut ion followed by mechanical defibrating (grinding), and has an onsite chemical recovery process that is not integrated with a kraft pulp mill.

Startup means, for the chemical recovery system employing black liquor gasification at Georgia

- Pacific’s facility in Big Island, Virginia only, the end of the gasification system commissioning phase. Commissioning is that period of time in which each part of the new gasification system will be checked and operated on its own to make sure it

is installed and functions properly. Commissioning will conclude with the successful completion of the gasification technology supplier’s performance warranty demonstration, which proves the technology and equipment are performing to warranted levels and the system is ready to be p laced in active service. For all other affected sources under this subpart, startup has the meaning given in § 63.2.

Sulfite combustion unit means a combustion device, such as a recovery furnace or fluidized

- bed reactor, where spent liquor from the sulfit e pulping process (i.e., red liquor) is burned to recover pulping chemicals.Survey Overview Document Form Approved 02/17 / 2011

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### 8 Sulfite pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a solution of sulfurous acid and bisulfite ions. The recovery proc ess used to regenerate cooking chemicals is also considered part of the sulfite pulp mill.

Total hydrocarbons (THC) means the sum of organic compounds measured as carbon using EPA Method 25A (40 CFR part 60, appendix A).Survey Overview Document Form Approved 02/17 / 2011

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### 9 NESHAP Subpart S Definitions (40 CFR Part 63, § 63.441 ):

Acid condensate storage tank means any storage tank containing cooking acid following the sulfur dioxide gas fortification process.

Black liquor means spent cooking liquor that has been separated from the pulp produced by the kr aft, soda, or semi

chemical pulping process.

Bleaching means brightening of pulp by the addition of oxidizing chemicals or reducing chemicals.

Bleaching line means a group of bleaching stages arranged in series such that bleaching of the pulp progresses as the pulp moves from one stage to the next.

Bleaching stage means all process equipment associated with a discrete step of chemical application and removal in the bleaching process including chemical and steam mixers, bleaching towers, washers, seal (fi ltrate) tanks, vacuum pumps, and any other equipment serving the same function as those previously listed.

Bleaching system means all process equipment after high

- density pulp storage prior to the first application of oxidizing chemicals or reducing chemi cals following the pulping system, up to and including the final bleaching

stage.

Boiler means any enclosed combustion device that extracts useful energy in the form of steam. A boiler is not

considered a thermal oxidizer.

Chip steamer means a vessel use d for the purpose of preheating or pretreating wood chips prior to the digester, using flash steam from the digester or live steam.

Closed

- vent system means a system that is not open to the atmosphere and is composed of piping, ductwork, connections, and, if necessary, flow

- inducing devices that transport gas or vapor from an emission point to a

control device.

Combustion device means an individual unit of equipment, including but not limited to, a thermal oxidizer, lime kiln, recovery furnace, process he ater, or boiler, used for the thermal oxidation of organic hazardous air pollutant

vapors.

Decker system means all equipment used to thicken the pulp slurry or reduce its liquid content after the pulp washing system and prior to high

- density pulp storage. The decker system includes decker vents, filtrate tanks, associated vacuum pumps, and any other equipment serving the same function as those previously listed.

Digester system means each continuous digester or each batch digester used for the chemical tr eatment of wood or

non

- wood fibers. The digester system equipment includes associated flash tank(s), blow tank(s), chip steamer( s) not using fresh steam, blow heat recovery accumulator(s), relief gas condenser(s), prehydrolysis unit(s) preceding the pulp washing system, and any other equipment serving the same function as those previously listed. The digester system includes any of the liquid streams or condensates associated with batch or continuous digester relief, blow, or flash steam processes.

Emissi on point means any part of a stationary source that emits hazardous air pollutants regulated under this subpart, including emissions from individual process vents, stacks, open pieces of process equipment, equipment leaks,

wastewater and condensate collect ion and treatment system units, and those emissions that could reasonably be conveyed through a stack, chimney, or duct where such emissions first reach the environment.

Evaporator system means all equipment associated with increasing the solids content a nd/or concentrating spent cooking liquor from the pulp washing system including pre

- evaporators, multi

- effect evaporators, concentrators, and vacuum systems, as well as associated condensers, hotwells, and condensate streams, and any other equipment servin g the same function as those previously listed.

Flow indicator means any device that indicates gas or liquid flow in an enclosed system.

HAP means a hazardous air pollutant as defined in § 63.2 of subpart A of this part.

High volume, low concentration o r HVLC collection system means the gas collection and transport system used to convey gases from the HVLC system to a control device.Survey Overview Document Form Approved 02/17 / 2011

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### 10 High volume, low concentration or HVLC system means the collection of equipment including the pulp washing, knotter, scre en, decker, and oxygen delignification systems, weak liquor storage tanks, and any other equipment serving the same function as those previously listed.

Knotter system means equipment where knots, oversized material, or pieces of uncooked wood are removed from the pulp slurry after the digester system and prior to the pulp washing system. The knotter system equipment includes the knotter, knot drainer tanks, ancillary tanks, and any other equipment serving the same function as those previously listed.

Kra ft pulping means a chemical pulping process that uses a mixture of sodium hydroxide and sodium sulfide as the cooking liquor.

Lime kiln means an enclosed combustion device used to calcine lime mud, which consists primarily of calcium carbonate, into calci um oxide.

Low volume, high concentration or LVHC collection system means the gas collection and transport system used to convey gases from the LVHC system to a control device.

Low volume, high concentration or LVHC system means the collection of equipment including the digester, turpentine recovery, evaporator, steam stripper systems, and any other equipment serving the same function as those previously listed.

Mechanical pulping means a pulping process that only uses mechanical and thermo

- mechanical proc esses to reduce wood to a fibrous mass. The mechanical pulping processes include, but are not limited to, stone groundwood, pressurized groundwood, refiner mechanical, thermal refiner mechanical, thermo

- mechanical, and tandem

thermomechanical.

Non

- wood pu lping means the production of pulp from fiber sources other than trees. The non

- wood fiber sources include, but are not limited to, bagasse, cereal straw, cotton, flax straw, hemp, jute, kenaf, and leaf fibers.

Oven

- dried pulp or ODP means a pulp sample a t zero percent moisture content by weight. Pulp samples for applicability or compliance determinations for both the pulping and bleaching systems shall be unbleached pulp. For purposes of complying with mass emission limits in this subpart, megagram of ODP shall be measured to represent the amount of pulp entering and processed by the equipment system under the specified mass limit. For equipment that does not process pulp, megagram of ODP shall be measured to represent the amount of pulp that was processed to produce the gas and liquid streams.

Oxygen delignification system means the equipment that uses oxygen to remove lignin from pulp after high

- density stock storage and prior to the bleaching system. The oxygen delignification system equipment includes the blow tank, washers, filtrate tanks, any interstage pulp storage tanks, and any other equipment serving the same function as those previously listed.

Primary fuel means the fuel that provides the principal heat input to the combustion device. To be con sidered primary, the fuel must be able to sustain operation of the combustion de without the addition of other fuels.

Process wastewater treatment system means a collection of equipment, a process, or specific technique that removes or destroys the HAPs i n a process wastewater stream. Examples include, but are not limited to, a steam stripping unit, wastewater thermal oxidizer, or biological treatment unit.

Pulp washing system means all equipment used to wash pulp and separate spent cooking chemicals foll owing the digester system and prior to the bleaching system, oxygen delignification system, or paper machine system (at unbleached mills). The pulp washing system equipment includes vacuum drum washers, diffusion washers, rotary pressure washers, horizonta l belt filters, intermediate stock chests, and their associated vacuum pumps, filtrate tanks, foam breakers or tanks, and any other equipment serving the same function as those previously listed. The pulp washing system does not include deckers, screens, k notters, stock chests, or pulp storage tanks following the last stage of pulp washing.

Pulping line means a group of equipment arranged in series such that the wood chips are digested and the resulting pulp progresses through a sequence of steps that may include knotting, refining, washing, thickening, blending, storing, oxygen delignification, and any other equipment serving the same function as those previously listed.Survey Overview Document Form Approved 02/17 / 2011

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### 11 Pulping process condensates means any HAP

- containing liquid that results from contact of water with organic compounds in the pulping process. Examples of process condensates include digester system condensates, turpentine recovery system condensates, evaporator system condensates, LVHC system condensates, HVLC system condensates, and any o ther condensates from equipment serving the same function as those previously listed. Liquid streams that are intended for byproduct recovery are not considered process condensate streams.

Pulping system means all process equipment, beginning with the dig ester system, and up to and including the last piece of pulp conditioning equipment prior to the bleaching system, including treatment with ozone, oxygen, or peroxide before the first application of a chemical bleaching agent intended to brighten pulp. The pulping system includes pulping process condensates and can include multiple pulping lines.

Recovery furnace means an enclosed combustion device where concentrated spent liquor is burned to recover sodium and sulfur, produce steam, and dispose of unwante d dissolved wood components in the liquor.

Screen system means equipment in which oversized particles are removed from the pulp slurry prior to the bleaching or papermaking system washed stock storage.

Secondary fiber pulping means a pulping process that converts a fibrous material, that has previously undergone a manufacturing process, into pulp stock through the addition of water and mechanical energy. The mill then uses that pulp as the raw material in another manufactured product. These mills may also utilize chemical, heat, and mechanical processes to remove ink particles from the fiber stock.

Semi

- chemical pulping means a pulping process that combines both chemical and mechanical pulping processes.

The semi

- chemical pulping process produces intermed iate yields ranging from 55 to 90 percent.

Soda pulping means a chemical pulping process that uses sodium hydroxide as the active chemical in the cooking liquor.

Spent liquor means process liquid generated from the separation of cooking liquor from pulp by the pulp washing system containing dissolved organic wood materials and residual cooking compounds.

Steam stripper system means a column (including associated stripper feed tanks, condensers, or heat exchangers) used to remove compounds from wastewater or condensates using steam. The steam stripper system also contains all equipment associated with a methanol rectification process including rectifiers, condensers, decanters, storage tanks, and any other equipment serving the same function as those previ ously listed.

Strong liquor storage tanks means all storage tanks containing liquor that has been concentrated in preparation for combustion or oxidation in the recovery process.

Sulfite pulping means a chemical pulping process that uses a mixture of sulf urous acid and bisulfite ion as the cooking liquor.

Temperature monitoring device means a piece of equipment used to monitor temperature and having an accuracy of ±1.0 percent of the temperature being monitored expressed in degrees Celsius or ±0.5 degrees Celsius (C), whichever is greater.

Thermal oxidizer means an enclosed device that destroys organic compounds by thermal oxidation.

Turpentine recovery system means all equipment associated with recovering turpentine from digester system gases including condensers, decanters, storage tanks, and any other equipment serving the same function as those previously listed. The turpentine recovery system includes any liquid streams associated with the turpentine recovery process such as turpentine decanter under flow. Liquid streams that are intended for byproduct recovery are not considered turpentine recovery system condensate streams.

Weak liquor storage tank means any storage tank except washer filtrate tanks containing spent liquor recovered from the pulping process and prior to the evaporator system.Survey Overview Document Form Approved 02/17 / 2011

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### 12 Selected definitions from 40 CFR Part 60 subpart A (NSPS General Provisions) :

Commenced means, with respect to the definition of new source in section 111(a)(2) of the Act, that an owner or operator has und ertaken a continuous program of construction or modification or that an owner or operator has entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of construction or modification. [§60.2]

Construc tion means fabrication, erection, or installation of an affected facility. [§60.2]

Modification means any physical change in, or change in the method of operation of, an existing facility which increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by that facility or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not previously emitted. [§60.2]

Reconstruction means the replacement of components of an existing facility to such an extent that: (1) The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility, and (2) It is technologically and economically feasible to meet the applicable standards set forth in this part. [§60.15(b)]

Selected definitions from 40 CFR Part 63 subpart A (NESHAP General Provisions) :

Commenced means, with respect to construction or reconstruction of an affected source, that an owner or operator has undertaken a continuous program of construction or reconstruction or that an owner or operator has entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of

construction or reconstructio n. [§ 63 .2]

Construction means the on

- site fabrication, erection, or installation of an affected source. Construction does not include the removal of all equipment comprising an affected source from an existing location and reinstallation of such equipment at a new location. The owner or operator of an existing affected source that is relocated may elect not to reinstall minor ancillary equipment including, but not limited to, piping, ductwork, and valves. However,

removal and reinstallation of an affected s ource will be construed as reconstruction if it satisfies the criteria for reconstruction as defined in this section. The costs of replacing minor ancillary equipment must be considered in determining whether the existing affected source is reconstructed. [§ 63 .2]

Major source means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazard ous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants, unless the Administrator establishes a lesser quantity, or in the case of radionuclides, different criteria from those specified in this sentence. [§ 63 .2]

Reconst ruction, unless otherwise defined in a relevant standard, means the replacement of components of an affected or a previously nonaffected source to such an extent that: (1) The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable new source; and (2) It is technologically and economically feasible for the reconstructed source to meet the relevant standard(s) established by the Administrator (or a State) pursuant to section 112 o f the Act. Upon reconstruction, an affected source, or a stationary source that becomes an affected source, is subject to relevant standards for new sources, including compliance dates, irrespective of any change in emissions of hazardous air pollutants fr om that

source. [§ 63 .2]Survey Overview Document Form Approved 02/17 / 2011

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### 13 ATTACHMENT 3 Acronyms and Abbreviations

acfm actual cubic foot (feet) per minute

ADT ash dissolving tank(s)

ADTBP air

- dried ton(s) of bleached pulp

ADTFP air

- dried ton(s) of finished paper

ADTP air

- dried ton(s) of pulp

APCD ai r pollution control device(s)

As arsenic

AS activated sludge

ASB aerated stabilization basin(s)

atm atmosphere(s)

Be beryllium

BLDG building

BLO black liquor oxidation

BLS black liquor solids

BOD biochemical oxygen demand

BOD 5 5

- day BOD

Btu British therma l unit(s)

°C degrees Celsius

Ca calcium

CAA Clean Air Act

CaO calcium oxide (lime)

CAP criteria air pollutant(s)

CBI confidential business information

CCA Clean Condensate Alternative

Cd cadmium

CD c ompact d isc

CDD chlorinated dibenzo

- p

- dioxin

CDF chlorin ated dibenzofuran

CEMS continuous emissions monitoring system(s) CERCLA Comprehensive Environmental Response, Compensation, & Liability Act

cfm cubic feet per minute

CFR Code of Federal Regulations

Cl 2 chlorine

ClO 2 chlorine dioxide

Co cobalt

CO carbon m onoxide

CO 2 carbon dioxide

COMS continuous opacity monitoring system(s)

Cr chromium

CTMP chemi

- thermomechanical pulp

cu ft cubic foot (feet) cu yd cubic yard (s)

CY calendar year

d day(s)

DAS data acquisition system (s)

DCE direct contact evaporator

DI dry injection

dscf dry standard cubic foot (feet)

dscfm dry standard cubic feet per minute

DVD digital versatile disc

ECF elemental chlorine free EIS Emissions Inventory System

EPA U.S. Environmental Protection Agency

ESP electrostatic precipitator(s)

EU emiss ion unit

EVAP evaporator

°F degrees Fahrenheit

FF fabric filter

ft foot (feet)

ft 2 square foot (feet)

FTP file transfer protocol

g gram(s) gal gallon(s)

gpm gallon(s) per minute

gr grain(s)

GW groundwood

H 2 O water

H 2 O 2 hydrogen peroxide

H 2 S hydrogen sulfid e HAP hazardous air pollutant(s)

HCl hydrochloric acid

HF hydrogen fluoride Hg mercury
HHV higher heating value

hr hour(s)

HVLC high

- volume low

- concentration

HW hardwood

ICR information collection request

ID identification

in. inch(es)

ISIS Industrial Sec tor Integrated Solutions kg kilogram(s)

KMNO 4 potassium permanganate

KOH potassi u m hydroxide

k

W kilowatt

kWh kilowatt

- hour(s)

l liter(s)

lb pound(s)

LK lime kiln(s)

LVHC low

- volume high

- concentration

MACT maximum achievable control technology

MDL method de tection limit

MEE multiple

- effect evaporator(s)

MEK methyl ethyl ketone

MeOH methanol

mg milligram(s) Mg megagram(s); magnesium

MLVSS mixed liquor volatile suspended solids

MMBtu million Btu

mmscf million standard cubic feet

Mn manganese MSDS material safe ty data sheet(s)

NA N ot ApplicableSurvey Overview Document Form Approved 02/17 / 2011

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### 14 Na 2 S 2 O 4 sodium hydrosulfite

NaClO sodium hypochlorite

NAD North American Dictum

NAICS North American Industry Classification System

NaOH sodium hydroxide

NATA National

- Scale Air Toxics Assessment

NCASI National Council of the Paper Industry for Air and Stream Improvement

NCG noncondensable gas(es)

NDCE nondirect contact evaporator

NEC Not Elsewhere Classified

NEI National Emissions Inventory NESHAP National emissions standard(s) for hazardous air pollutants

NH 3 ammonia

Ni nickel

No. number

NO 2 nitrogen dioxide

NO X nitrogen oxides

NSPS new source performance standard(s)

NSSC neutral sulfite semichemical

NV n ot vented

O 2 oxygen O 3 ozone OCC Old Corrugated Container

ODP oven

- dried pulp

ODT oven dried ton(s)

OMB Office of Ma nagement and Budget

ONP Old News Print

OSHA Occupational Safety and Health

Administration

OTM Other Test Method

P & P p ulp and p aper PAH polycyclic aromatic hydrocarbons

Pb lead

PCC precipitated calcium carbonate

PCF processed chlorine free

PGW pressurized groundwoood

PLC programmable logic controller

PM particulate matter

PM 10 PM with an aerodynamic diameter of up to 10 μm

PM 2.5 PM with an aerodynamic diameter of up to 2.5 μm

POM polycyclic organic matter

POTW publicly owned treatment works

ppm part(s) per million ppmdv part(s) per million dry volume ppmdw part(s) per million dry weight

ppmv part(s) per million by volume

ppmw part(s) per million by weight

PTFE p olytetrafluoroethylene

RF recovery furnace(s)

RMP refiner mechanical pulping RTO regenerative the rmal oxidizer(s)

RTR residual risk and technology review

Sb antimony

SBT s tock b lend t ank (s)

SCA specific collecting area

SCC Source Classification Code

scf standard cubic foot (feet)

scfm standard cubic feet per minute

SCR selective catalytic reduction

SD T smelt dissolving tank(s)

Se selenium

sec second(s)

SGW stone groundwood

SIC Standard Industrial Classification

SNCR selective noncatalytic reduction

SO 2 sulfur dioxide

SOG stripper offgas(es)

SSM startup, shutdown, and malfunction

st short ton(s)

SVT sa ve

- all tank (s)

SW softwood

TBD To Be Determined

TCF totally chlorine free

TCDD tetrachlorodibenzo

- p

- dioxin

TCI total capital investment TEQ 2,3,7,8

- TCDD toxic equivalent

THC total hydrocarbon

TMP thermomechanical pulping

TO thermal oxidizer

ton ton(s) tph ton(s) per hour

tpy ton(s) per year

TRI Toxics Release Inventory

TRS total reduced sulfur

UK Unknown

UNOX oxygen activated sludge treatment

U.S. United States

VOC volatile organic compound

WESP wet ESP (s)

WS wet scrubber (s)

Wt% weight

- percent

WW wast ewater

WWT wastewater treatment

WWTP wastewater treatment plant

Y/N yes/no

yr year (s)

μ g microgram ( s )

μm micrometer(s)Survey Overview Document Form Approved 02/17 / 2011

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### 15 ATTACHMENT 4

SIGNED CERTIFICATION FORM



### Instructions : Submit a hard (or electronic) copy of this completed form with each part of

you r survey response (Part I, Part II, and Part III).

Check the appropriate cer ti fication statement below for the part of the survey being

submitted :


# □ Based on information and belief formed after reasonable inquiry, I certify that the statements and information provided in my response to Part I of th is survey are (to the best of my knowledge) true, accurate, and complete

.



# □ Based on information a nd belief formed after reasonable inquiry, I certify that the statements and information provided in my response to Part II of this survey are (to the best of my knowledge) true, accurate, and complete

.



# □ Based on information and belief formed after re asonable inquiry, I certify that the statements and information provided in my response to Part III of this survey are (to the best of my knowledge) true, accurate, and complete

.

Signature :

____________________________________________ Printed name : ___

______________________________________ Title: _________________________________________________

Company: _____________________________________________

Date signed : ___________________________________________

Note that the information submitted by a facility is not intended for a compliance assessment. If actual data is not available, the facility should provide the best engineering estimates where appropriate. In addition, it is not the

intent of the EPA to use this data to confirm data/information submitted in the facility’s Toxic Release Inventory (TRI) or other regulatory required reports. It is understood that data submitted in this survey could vary due to the nature of the questions.