March 28, 2012

MEMORANDUM

SUBJECT: Meeting notes for the March 28, 2012 meeting with AF&PA

FROM: John Bradfield

TO: Docket EPA-HQ-OAR-2007-0544

This memorandum summarizes the meeting between The American Forest and Paper Association 

(AF&PA) and the EPA on March 28, 2012. This meeting was requested in response to the Risk and 

Technology Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) 

for the pulp and paper industry.

Meeting Attendees:

Bill Schrock-EPA Brittany Robinson-URS

Ashok Jain-NCASI Jeff Shumaker-IP

Guy Martin-Domtar Mark Aguilar-GP

Tim Hunt-AF&PA Vipin Varma-NCASI

Jim Taylor-MWV John Pinkerton-NCASI

Rich Garber-Boise Inc. Nick Swanson-EPA

Kelley Spence-EPA John Bradfield-EPA

Corey Gooden-RTI Tom Holloway-RTI

Katie Hanks-RTI Ann Crapo-NCASI (via phone)

Zach Emerson-NCASI (via phone) Paul Noe-AF&PA (via phone)

Robin Dunkins-EPA (via phone)
Discussion Points:

• Discussions followed the slides in Attachment 1.

• Points made by industry representatives during the meeting that may not be reflected on the slides are 

as follows:

o The cost to install activated sludge treatment systems is on the order of $30 to 40 million.

o Hard pipes to route condensates to wastewater treatment are made of stainless steel and 

can be over a mile long.

o Mills keep track of time associated with the excess emissions allowances and are not 

measuring emission. However, emissions are typically estimated applying NCASI 

emission factors and a variety of site-specific considerations (e.g., location of vents; 

estimates of apportioned emissions for the various vents in the system). Such emission 

estimates are often included in annual emissions inventories, and were included in the 

Part II survey responses.

o Some States agencies have time limits after which reporting of venting episodes are 

required (e.g., events adding up to over 5 minutes of time) 

• Three additional presentations were provided by AF&PA prior to the meeting but were not discussed. 

These include:

o Hexachloroethane Emissions from Brownstock Washers and Bleach Plant Scrubbers 

(Attachment 2)

o Pre- and Post-MACT Paper Machine HAP Emission Tests for Residual Risk Assessment 

Review (Attachment 3)

o Wastewater Treatment System HAP Emissions (Attachment 4)

• Further discussions. If EPA has additional technical clarifications, tentative plans were made for a 

follow up meeting May 2nd 2012
Attachment 1

AF&PA Meeting Material Discussed on March 28
Pulp & Paper Residual Risk and Technology Review 

Proposal

Industry Meeting with OAQPS

Research Triangle Park, NC

March 28, 2012
Agenda

Cost analyses

Excess Emission Allowances

Start-up & Shutdown

Other issues – if time

Next Steps/Wrap-up

2
Cost Estimates for Proposed Increased 

Treatment Standards
Cost Considerations

What do facilities need to do to achieve 94% 

treatment efficiency 

Treatment System Upgrades

Assumed all facilities will need to upgrade their 

wastewater treatment systems to achieve 94%

Will CAA Mills be able to utilize this option or will the 

demonstration fall apart?

For conservatism, cost estimates assumed CCA mills will 

still be able to demonstrate compliance with 94% 

(AF&PA Methodology)

4
Facility Treatment Options & 

Upgrade Assumptions

5

Treatment Option Number of 

Units

Upgrade Assumptions

Stripper Only 43 • Mills under 96% treatment efficiency will need to 

upgrade their units. 

• All mills will need to increase O&M Cost

Biological Treatment 

Only

39 • All mills will need to increase surface or diffused 

aeration and have nutrient addition [26 ASBs, 12 other 

(UNOX, AST), 1 Anaerobic]

Biological Treatment 

& Stripping

9 • 1/2 the mills that have treatment efficiency under 96% 

will need to upgrade their units (assume upgrade is to 

the stripper). All strippers will need to increase O&M 

costs.

Recycle 5 • Assume no upgrades required

Thermal Oxidizer 1 • Assume no upgrades required

TOTAL 97 • Assume that 91 mills are affected (less recycle & 

thermal oxidizer)

NOTE: Assumed that mills can still utilize the CCA option, but will need to upgrade their control systems and 

redemonstrate compliance with CCA via an IPT. This is a conservative assumption as it is expected that 

several CCA Mills will not be able to utilize this option under this methodology
Cost Estimate to treat to 94% : Assumptions

(AF&PA Methodology: 10.4/6.8 lb/ODTP)

Stripper Assumptions

More energy, trays, and steam contact area

Need compliance margin – units with < 96%

20% are integrated with evaporators

Assume 10% downtime remains - no backup

Wastewater Treatment System Assumptions

Increase in aeration and nutrient addition would be sufficient

Added nutrients may impact water quality standards

All systems impacted

6
Cost Estimate to treat to 94% : Strippers

(AF&PA Methodology: 10.4/6.8 lb/ODTP)

EPA Estimate

8 stripper upgrades

$2.7 M/each

AF&PA Estimate

27 strippers (96% and 

below)

23 Strippers (only 

treatment device)

4 Strippers for facilities 

with dual treatment (1/2 of 

these units)

$2.9 M/each for nonintegrated units

$5.8 M/each for integrated 

units

7
Cost Estimate to treat to 94% : Biological Treatment

(AF&PA Methodology: 10.4/6.8 lb/ODTP)

EPA Estimate

7 systems (at or below 

94%)

Capital costs range from 

$1 – 4 M/each

AF&PA Estimate

39 systems (all with 

biological treatment)

26 ASBs

12 UNOX, AST, etc. will 

also need increased 

aeration

1 Anaerobic System –

Will need an upgrade –

Assumed similar cost to 

other systems

Capital cost of $6M/each 

8
Cost Estimate to treat to 94% : O&M Costs

(AF&PA Methodology: 10.4/6.8 lb/ODTP)

Strippers

Increased energy : 12 MMBtu/hr x 8390 hr/yr x 

$3/MMBtu

Increased maintenance to maintain efficiency: one 

additional outage per year at $100K

Biological Treatment Systems – all affected

Increased energy: $2.3 M/year/facility 

Maintenance costs for aerators: $220K/year/facility

Cost for chemicals only (nutrient): $60K/year/facility

9
Cost Estimate to treat to 94% : Biological Treatment

(AF&PA Methodology: 10.4/6.8 lb/ODTP)

10

Cost Range 

($M)

Average Cost

($M)

Aeration Installation Costs (Capital) $1.5 – $12.5 $6

Annual Power Cost Increase $0.6 – $5 $2.3

Annual Maintenance Cost Increase $0.06 - $0.5 $0.22
Cost Estimate to treat to 94%

(AF&PA Methodology: 10.4/6.8 lb/ODTP)

11

Number 

of Units

Affected

Capital 

Costs ($M)

Annual 

Energy 

Costs ($M)

Annual

O&M Costs 

($M)

Stripper 

Upgrade

27 $94 $8 $3

Current 

Strippers

25 -- $8 $3

Aeration 39 $230 $90 $9

Nutrient 

Addition

39 -- -- $2

TOTAL -- $324 $106 $17
Cost Estimate to treat to 94% : Comparison

(AF&PA Methodology: 10.4/6.8 lb/ODTP)

12

EPA 

Estimate

AF&PA 

Estimate

Number of Facilities Affected 15 91

Capital Cost ($M) $36 $324

Annualized Capital Cost ($M) $4.1 $30.4

Annual O&M Costs ($M) $0.15 $123

Annualized Cost ($M) $4.25 154

Cost /Ton (Using 4092 

tons/yr)

$1,000 $38,000
Excess Emission Allowances
Excess Emission Allowances

Necessary due to Inherent Process Variability, 

Design, and Technology Reasons – Not SSM

Generally not due to equipment breakdown/repair

Process variability and safety interlocks cause release

Part of the “MACT Floor” - best performing units 

could not meet the standards at all times

Technology and operations have not changed to 

allow for safe operations without these provisions

14
Excess Emission Allowances: 

LVHC & HVLC Systems

Gases are potentially explosive and cannot be burned 

safely without supplemental fuel

Flame safety system will not permit the gases to be admitted 

until the burner is operating on supplemental fuel and ignition 

is proven (criteria for safe operation, known as “permissives,” 

must be met)

Generally 9 – 15 interlocks

Safety interlocks are required by both Factory Mutual Insurance 

and the National Fire Protection Association for burning of 

these non-condensable gases. 

When these gases are burned in a recovery furnace, there are 

safety guidelines issued by the Black Liquor Recovery Advisory 

Committee. 

15
Excess Emission Provisions: 

LVHC & HVLC Systems

Example Events

Loss of Flame or Burner Permissive

Typically short in duration and quickly resolved

Example: Temporarily loss of permissive due to cleaning oil gun(s)

Process Variation

Variation causes a “domino effect” in the mill

Example: Paper Machine Trip causes a swing in steam header 

pressure and vent at digester system

Loss of Permissive and Back-up Control Device Not Readily 

Available (LVHC systems)

Backup control device undergoing maintenance or not a “hot” backup

Note: Emergency Shutdowns can actually result in increased 

emissions rather than allowing the permissive to resolve

16
Excess Emission Allowance: Emission Estimates 

LVHC & HVLC Systems

Not possible to quantify emissions on a site- or event- specific basis

Not aware of any successful measurements of releases from vents 

during these circumstances

Limited data available from collection systems prior to control devices during 

normal operations

Emissions will vary based on the cause, location, and source

Vary between facilities and within facility at similar source

Vary based on the circumstances of the release

Sampling these events is not feasible 

Events cannot be anticipated

Generally short duration so difficult to respond to sample

Generally unsafe to sample these events

Some vents are not accessible

17
Excess Emission Allowances: Vent-less Transfer

LVHC & HVLC Systems

Some units cannot be designed for vent-less transfer

Systems with recovery furnaces

Systems that have different types of boilers as the 

Primary and Back-up Control Devices (i.e., one 

boiler is under positive pressure and the other 

boiler is under negative pressure)

Systems such as oxidizers that were installed as 

Back-up Control Only (these units are typically not 

maintained in a “hot” state)

18
Excess Emission Allowances: 

Steam Strippers

Almost all facilities do not have backup strippers

Downtime needed for

Stripper tray damage or plugging

Efficiency losses in the stripper due to contamination 

of condensate with fiber or black liquor 

Steam supply downtime

Combustion control device downtime

Stripper maintenance

19
Excess Emission Allowances: 

HVLC/LVHC Cost Estimate Assumptions

HVLC Control Devices

Assume all facilities have one control device and elimination of 

excess emission allowance will require routing gases to a backup control device.

Assumes that the facility has an available back-up option

This is not the cost in previous estimates for CCA mills to 

install the piping for collection and treatment of HVLC gases 

to a single control device.

LVHC Control Devices

All systems have a primary and backup control device – no 

routing to an additional control device necessary

LVHC/HVLC Collection Systems

Systems collect gases from equipment in the pulping process 

areas. Assume a backup collection system (piping) will be 

necessary to collect any “vents” from equipment

20
Excess Emission Allowances: 

Stripper Cost Estimate Assumptions

Back-up Stripper will be required to accommodate stripper 

downtime due to maintenance

Without back-up systems, mills will need to shutdown the pulping 

process equipment during stripper downtime

Based on the proposed regulations, EPA wants to require higher 

treatment standards which will require additional maintenance on 

control systems and increased downtime

Installation of a Collection Tank for Long-Term Storage is Not 

a Solution

Tanks are suitable for short-term downtime periods (trips, etc.) –

not maintenance outages

Volume generated by strippers is such that long-term storage is not 

realistic

Systems are maxed out on volume (flow)

Storage of condensates during long-term downtime events 

would require an increase in flow (throughput) to compensate 

for the condensates being generated and treatment of stored 

condensates

21
Excess Emission Allowances:

Capital Cost Estimates

• Assumes all 97 Mills subject to the collection requirements will need to install 

ductwork to route HVLC to a backup control device (and a backup control device is 

available) and ductwork for redundant LVHC/HVLC collection systems.

• Assumes all 52 mills with strippers will need to install a backup stripper.

NOTE: Even with these systems, facilities cannot guarantee 100% compliance due to 

process variability and safety considerations.

22

AF&PA Estimate 

($M)

HVLC Redundant Control Costs $500

Redundant LVHC/HVLC Collection Systems $700

Backup Strippers $400

TOTAL $1,600
Targeted Excess Emissions and SSM 

Survey is being Planned

Survey will attempt to provide more details on the following

Circumstances for excess emissions 

Whether they qualify as SSM events AND if not, why not

General categorization of excess emissions events (and causes)

Differentiating between excess emissions events and SSM events

Frequency and duration of occurrences to reflect an overall industry 

snapshot (would be difficult to estimate or quantify emissions, given 

the challenges described earlier)

Compilation of prevalent monitoring procedures and work practices

Lastly, why excess emission periods are needed for 

technology or operational reasons AND how all events cannot 

be avoided (e.g., permissive and interlock events)

23
Startup & Shutdown
Startup & Shutdown

EPA assumed operations (and emissions) are not

different during startup & shutdown vs. normal operation

Nothing in the record to support 

No known data available for emissions during SS events

Regulations prohibit using data for compliance purposes 

collected during SS events

25
Startup & Shutdown

Examples where emissions could be different:

Control device may be less efficient:

Until it reaches operating temperature

When the pollutant concentrations are lower than during 

steady-state operation

Until a process reaches steady-state operation, that process may 

generate substantially higher emissions, either on a total mass 

basis or on a mass per unit of production basis

Venting of LVHC/HVLC systems due to system “permissives” not 

being met

Legal issues covered in comments

26
Other Topics of Concern
Other Topics of Concern

Concentration limit for Bleached Mills should be 258 ppmv

Proposed rule states 210 ppmv which is inconsistent with the docket

Electronic Reporting is unreasonable

Subpart S Performance Tests are unlike Stack Tests 

Compliance Deadline should be 3 years for all changes to 

the rules

Including electronic reporting and affirmative defense

EPA’s proposed requirement that the Administrator specify 

test conditions is unreasonable

Test under normal conditions

28
Cost Estimates IF Over-collection with 

Pound per Ton Option
Cost Estimate to treat to 94%: Assumptions

(EPA Methodology: 12.8/8.3 lb/ODTP)

Assumptions

The lb/ODTP treatment option not viable

The Clean Condensate Alternative not viable 

Need to treat additional condensates will 

negate current compliance demonstrations

Install collection system at $15M/facility

Assumes that 4% HVLC allowance remains in 

place

30
Cost Estimate to treat to 94%

(EPA Methodology: 12.8/8.3 lb/ODTP)

31

Number 

of Units

Affected

Capital 

Costs 

($M)

Annual 

Energy 

Costs ($M)

Annual

O&M 

Costs 

($M)

Stripper Upgrade 27 $94 $8 $3

Current Strippers 25 -- $8 $3

Aeration 39 $230 $90 $9

Nutrient Addition 39 -- -- $2

HVLC to Single 

Treatment 

Device

34 $510 -- --

TOTAL -- $834 $106 $17
Cost Estimate to treat to 94% : Comparison

(AF&PA vs. EPA Methodology)

32

EPA 

Estimate

AF&PA 

Estimate

Number of Facilities 

Affected

15 91

Capital Cost ($M) $36 $834

Annualized Capital Cost 

($M)

$4.1 $48 + 30 = 78

Annual O&M Costs ($M) $0.15 $123

Annualized Cost ($M) $4.25 $202
Clean Condensate Alternative
Compliance Approaches used by CCA Mills 

Facilities with cleaner condensates on Brownstock Washer showers 

either

Over-collect condensates for treatment in Steam Strippers OR 

Route additional condensates to the ASB for treatment

Emission reductions are

Incremental reductions achieved from a “baseline” that reflects MACT I 

Phase 1 compliance

From the use of cleaner condensates on HVLC sources

Due to improved treatment in wastewater treatment systems realized 

through voluntary upgrades

For CCA mills, collection and treatment levels reported in the 2011 

ICR reflect ongoing compliance with MACT I Phase 1 and CCA

34
CCA strategies as grouped by EPA in their 

October 21, 2011 memo

35

CCA Technology Number 

of Units

Affected

Upgrade Assumptions

Steam Stripper,

Biological Treatment, &

Collect Additional Condensates

21 • These mills collect additional condensates and 

send to the steam stripper or biological 

treatment systems for treatment

Clean Shower Water,

Clean Condensates, & 

Substitution

7 • These mills collect additional condensates and 

send to the steam stripper or biological 

treatment systems for treatment

Wastewater Treatment System 

Upgrades Only

6 • Assumed these facilities would need the 

upgrades to achieve the 94% treatment 

efficiency and could not use credits for CCA.

Other Alternatives 4 • Assumed these facilities could still utilize the CCA 

option as we do not have information for these 

sites.
Compliance Approaches used by CCA Mills using overcollection and additional treatment 

Over-collect and over-treat condensates in Steam Strippers to clean 

up HVLC source condensates for emission reductions 

Eight unbleached mills

Three bleached mills

WWTP area emission reductions

Eleven mills – over-collection and additional treatment in ASB through 

voluntary upgrades | sewer diversion credits

Three mills - no over-collection but voluntary upgrades that result in 

additional treatment | sewer diversion credits

Three mills – additional treatment not significant

Six mills confirmed as adopting other “equivalency” projects

Four mills – more detailed info being sought (non-member 

companies)

36
37

HVLC 

Sources

Contaminated 

Condensate

Clean 

Condensate

HVLCCCA

HVLCBase

Fbio

MACT 1 Phase 1

Wastewater (WW1)

Baseline Emissions = (WW1 + P1) x (1 – Fbio)

Phase 1 Condensates (P1)

Phase 1 Compliance: P1 ≥ 11.1 and (P1 x Fbio) ≥ 10.2

Additional Condensates

in Hard Pipe (P2)

Additional 

Treatment

Higher Fbio Wastewater (WWCCA)

Phase 1 Condensates (P1)

CCA Emissions = (WWCCA + P1 + P2) x (1 – Fbio, CCA)

 = baseline

 = CCA

Facility hardpiping additional condensates and operating biotreatment system at Higher Fbio in 

order to use the CCA option

Higher Fbio achieved through voluntary treatment system upgrades

Example Bleached Mill with CCA 

– Compliance Approach
HVLC Source emissions = 1.4 lb/ODTP

Wastewater Treatment system loadings

Baseline: WW1 = 10 lb/ODTP; P1 = 12.2 lb/ODTP

CCA: WWCCA = 7 lb/ODTP; P1 = 12.2 lb/ODTP; P2 = 3 lb/ODTP

MACT I Phase 1 Fbio = 92% (baseline) 

Fbio, CCA = 95% 

38

Baseline HAP,

lb/ton

CCA Emissions,

lb/ton

HVLC Sources 1.40 0.50

Wastewater Treatment

System

(10 + 12.2) x 0.08 = 

1.78

(7 + 12.2 + 3) x 0.05 =

1.11

Total 3.18 1.66

Required Control from HVLC Sources = 0.98 x 1.4 = 1.37

Emission Reductions from CCA = 3.18 – 1.66 = 1.52 || 1.52 > 1.37

Example Bleached Mill with CCA 

– Compliance Calculations
HVLC Source emissions = 1.4 lb/ODTP

Wastewater Treatment system loadings

Baseline: WW1 = 10 lb/ODTP; P1 = 12.2 lb/ODTP

CCA: WWCCA = 7 lb/ODTP; P1 = 12.2 lb/ODTP; P2 = 3 lb/ODTP

MACT I Phase 1 Fbio = 94% (baseline) 

Fbio, CCA = 95% 

39

Baseline HAP,

lb/ton

CCA Emissions,

lb/ton

HVLC Sources 1.40 0.50

Wastewater Treatment

System

(10 + 12.2) x 0.06 = 

1.33

(7 + 12.2 + 3) x 0.05 =

1.11

Total 2.73 1.66

Required Control from HVLC Sources = 0.98 x 1.4 = 1.37

Emission Reductions from CCA = 2.73 – 1.66 = 1.07 || 1.07 < 1.37

CCA BREAKS DOWN

Example Bleached Mill with CCA 

– Compliance Calculations with Proposed 94% Standard
PHASE 1

Demonstrate that P1 is ≥ 11.1 lb/ODTP

Over-collection is sometimes built into the permit language as a 

requirement for Phase 1

Demonstrate that P1 x MACT I Phase 1 Fbio (baseline) ≥ 10.2 lb/ODTP

PHASE 2 through CCA

Demonstrate that (P1+P2) is ≥ (11.1+3) = 14.1 lb/ODTP

Over-collection and averaging times also needed here to increase 

compliance probability

Measure Fbio, CCA

Demonstrate that Emission Reductions at Fbio, CCA ≥ (0.98 x 1.4) lb/ODTP

40

Example Bleached Mill with CCA 

– Compliance Elements
Example Bleached Mill with CCA 

– Biotreatment Performance is a Requirement under CCA

Takeaways

Higher Fbio under CCA required for Phase 2 compliance

For CCA mills, the ICR data on biotreatment performance 

reflects the Higher Fbio

The calculated lb/ODTP treated also cannot be compared 

against Phase 1 requirements

Performance data from CCA mills therefore cannot be compared 

against Phase 1 requirements 

41
Proposed Increase in Treatment Efficiency 

from 92% to 94%

1. Historical compliance data does not support 

sustained over-performance 

2. The proposed increase is more than a marginal 

improvement and presents achievability and 

compliance issues
Historical Compliance Data does not reflect 

sustained over-performance

Only a limited number of mills with performance data reflective of 

MACT I Phase 1 compliance

Cannot be the basis for concluding over-performance and revising 

standards 

Higher levels of collection and treatment are for compliance 

margins and driven by the need to maximize compliance probability

Not indicative of over-performance

Increasing the treatment requirement would dramatically reduce this 

compliance probability

Current treatment device performance needed to ensure 

compliance at the current 92% standard

Design factors are integral in Steam strippers

Actual Fbio, methanol in ASBs already at 94% - when considering 

operational variability, current data is not indicative of over-performance

43
Biotreatment Systems – 92% to 94% is more than a 

marginal improvement

Proposed increase in biotreatment efficiency (Fbio,adj) 

from 92% to 94% would mean

An increase in actual Fbio, methanol to 96%

Facilities would need major treatment system upgrades to achieve 

sustainable and ongoing treatment of 96%

Upgrades would be prohibitively expensive in many cases

Given Fbio variability, sustained operation at 96% 

would be infeasible

Would result in additional compliance demonstration 

issues

44
Steam Strippers – 92% to 94% is more than a 

marginal improvement

The need to preserve compliance margins and 

compensate for fouling etc. would mean upgrades 

and (in some cases) rebuilds

More energy, trays, and steam contact area

All units operating @ < 96% expected to need upgrades

45
Attachment 2

Hexachloroethane Emissions from Brownstock Washers and Bleach Plant Scrubbers
Hexachloroethane Emissions 

from Brownstock Washers and 

Bleach Plant Scrubbers

Ashok Jain and Dr. Zach Emerson

NCASI

March 28, 2012
Hexachloroethane Emissions

• Hexachloroethane (HCE) emissions were 

a significant contributor to Subpart S risk 

for a few facilities

– Brownstock Washers

– Bleach Plant Scrubbers

• Most of these facilities appear to have 

used emissions data in the NCASI Air 

Toxics Database to estimate their 

emissions
HCE Emission Factors 

BSW – Vacuum Drum

Source Code Year Notes Emissions 

(lb/ADTUBP)

BSWIF 1993 Softwood

5 Hood 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

Data taken from NCASI Air Toxics Database, 2011 Revision
HCE Emission Factors 

BSW – “Other”

Source Code Year Notes Emissions 

(lb/ADTUBP)

BSWIC1 1993 Hardwood 

1 Diffusion Washer Vent 1.3 E-01

BSWIG1 1993 Softwood

1 Diffusion Foam Tank Vent 3.2 E-02

Mean = 8.0 E-02 lb/ADTUBP

Data taken from NCASI Air Toxics Database, 2011 Revision
HCE Emission Factors 

Bleach Plant Scrubber

Source Code Year Notes Emissions 

(lb/ADTBP)

BPIC1a 1993 Non-ECF < 2.2 E-02

BPIC31 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

Non-ECF

< 1.5 E-02 to <6.8 E-02

ECF

2.5 E-02

Data taken from NCASI Air Toxics Database, 2011 Revision
HCE Emission Factors

• BSW

– Vacuum Drum (all non-detect, 11 total vents)

– “Other” (2 detects at 2 diffusion washer vents at 

the same facility)

• Bleach Plant Scrubber – Non-ECF 

(6 non-detects)
HCE Emission Factors

• Available data are pre-MACT (1993)

• Testing Issues

– Method 18 (GC-FID in the field)

– Short column times, co-elution of other 

compounds, results not confirmed 

on MS

• BSW – “Other” and Bleach Plant Scrubber 

– ECF Emission factors labeled “suspect” in 

database and in TB 973 (2010)
HCE Emissions Studies

• Modified BHA Method

– Added hexane to impinger 

solution prior to sampling

• Lab Trials of Method 

Performance

– Demonstrated ~100% HCE 

recovery

– Achieved 10 ppbvd 

detection levels

“Low” Spike 

Recovery

(%)

“High” Spike 

Recovery

(%)

Spiked

Concentration 0.95 ppm 5.2 ppm

Run 1 106 90

Run 2 97 100

Run 3 115 106

Run 4 104 107

Run 5 98 107

Average 

Recovery 104 102
HCE Emissions Studies

Mill D

• Field Testing at Mill D

– Bleached Mill

– 2 Pulp Lines

• No. 1 Pulp Line

– Bleach Plant Scrubber

• No. 2 Pulp Line

– Vacuum Drum Brownstock Washer

– Pressure Diffusion Washer
Mill D Results

No. 2 Line Vacuum Drum Washer

Run No.

Production 

Rate 

(ADTUBP/day)

Vent Flow 

Rate (DSCFM)

Vent 

Concentration 

(ppbvd)

Emission 

Factor 

(lb/ADTUBP)

1 1035.6 1166 15.1 1.47 E-05

2 1043.5 1178 12.1 1.19 E-05

3-A1

1035.6 1166

16.0 1.56 E-05

3-B1 10.9 1.06 E-05

1Runs 3-A and 3-B were collected simultaneously in dual sample trains
Mill D Results

No. 2 Line Diffusion Washer

Run No.

Production 

Rate 

(ADTUBP/day)

Vent Flow 

Rate (DSCFM)

Vent 

Concentration 

(ppbvd)

Emission 

Factor 

(lb/ADTUBP)

1

1035.6 380 <10.3 <3.26 E-06

2

1043.5 363 <12.4 <3.71 E-06

3-A1

1035.6 415

<9.7 <3.36 E-06

3-B1

<10.2 <3.55 E-06

1Runs 3-A and 3-B were collected simultaneously in dual sample trains
Mill D Results

No. 1 Bleach Plant Scrubber

Run No.

Production 

Rate 

(ADTBP/day)

Vent Flow 

Rate (DSCFM)

Vent 

Concentration 

(ppbvd)

Emission 

Factor 

(lb/ADTBP)

1

658.9 8584 < 9.6 < 1.09 E-4

2

657.1 8584 < 11.3 < 1.28 E-4

3-A1

655.2 8617

< 9.8 < 1.11 E-4

3-B1

< 9.7 < 1.11 E-4

1Runs 3-A and 3-B were collected simultaneously in dual sample trains
HCE Emissions Studies

Mill D

• HCE not detected at the Diffusion Washer or at the 

Bleach Plant Scrubber

• HCE detected at very low level at the Vacuum Washer

Mill D

Source

Source 

Category

Mill D Result NCASI Database

Emission 

Factor # of Sources Emission Factor

No. 2 Line 

Vacuum 

Washer

BSW –

Vacuum Drum 

Type

1.32 E-05 3 <4.3 E-01

No. 2 Line 

Diffusion 

Washer

BSW – Other <3.48 E-06 2 8.1 E-02

No. 1. Line 

Bleach Plant 

Scrubber 

Bleach Plant -

ECF <1.16 E-04 1 2.5 E-02
HCE Emissions

• Hexachloroethane emissions from 1 facility are 

much lower than pre-MACT testing

• Where detected, HCE levels are extremely low

– Unlikely to be present due to pulping

– HCE source may be process water chlorination, in 

the process of examining process water practices at 

Mill D

• If warranted, can pursue further testing at other 

facilities to develop post-MACT emission 

factors
Attachment 3

Pre- and Post-MACT Paper Machine HAP Emission Tests for Residual Risk Assessment Review
Pre- and Post-MACT Paper 

Machine HAP Emission Tests for 

Residual Risk Assessment Review

Ashok Jain and Rob Crawford, NCASI

March 28, 2012
BHA Method

• Analytes: Acetaldehyde, Acrolein, 

Formaldehyde, Proprionaldehyde

• NCASI Method ISS/FP-A105.01 (BHA 

Method) Previously Developed for Solid 

Wood Products Manufacturing Sources

• NCASI Methods Manual

2
3

BHA Method (Cont’d)

• Chilled Aqueous Impinger Sampling

• Aqueous Impinger Solution Contains 

o-benzylhydroxylamine (BHA)

• BHA Reacts with Aldehydes to form Aldehyde 

Oximes

• Aldehyde Oximes are Extracted with Hexane

• Analysis with GC/NPD (NitrogenPhosphorous Detector)
BHA Method for 

Paper Machine Sources

• Method Modifications

– Increased Sampling Flow Rate from 0.5 L/min 

to 2 L/min

– Decreased Hexane Extraction Volume from 

30 mL to 15 mL

– Source Gas Quantitation Limits: 0.01 to 0.03 

ppmv as Compared to ~0.2 ppm

4
Duplicate, Unspiked Sampling 

Train Results for Acetaldehyde

5

0.00

0.05

0.10

0.15

0.20

0.25

VSE VPE HBE TWE FC2 DE1 DE3 AS1 FOE WE6 VE2 DV1 DV2 DV3

Acetaldehyde Emissions, ppmv

Paper Machine Emission Source

Sample Train 1

Sample Train 2
Duplicate, Unspiked Sampling 

Train Results for Formaldehyde

6

0.00

0.02

0.04

0.06

0.08

0.10

0.12

VSE VPE HBE TWE FC2 DE1 DE3 AS1 WE6 VE2 DV1 DV2 DV3

Formaldehyde Emissions, ppmv

Paper Machine Emission Source

Sample Train 1

Sample Train 2
Duplicate, Unspiked Sampling 

Train Results for Acrolein

7

0.00

0.01

0.02

0.03

0.04

0.05

0.06

0.07

0.08

0.09

0.10

WE6 VE2

Acrolein Emissions, ppmv

Paper Machine Emission Source

Sample Train 1

Sample Train 2
Run Spike Concentration Ranges

8

Compound

Concentration Range, ppmv

Low High

Acetaldehyde 0.6 – 0.9 7.9 – 9.1

Acrolein 0.02 – 0.05 0.2 – 0.3

Propionaldehyde 0.06 – 0.09 0.4 – 0.5

Formaldehyde 0.09 – 0.13 0.9 – 1.0
Run Spike Results

Compound

Low Spike High Spike

No. of Spiked 

Source Tests* Avg. Rec., %

No. of Spiked 

Source Tests* Avg. Rec., %

Acetaldehyde 15 85 16 93

Acrolein 0 NA 15 95

Propionaldehyde 7 92 16 90

Formaldehyde 14 80 16 88

9

*only includes samples with spike concentrations ≥ the source concentration
Integrated Kraft Mill

Sources Tested

Unbleached Mills B and H

• Linerboard Machines

• Clean Condensate and Fresh Water on Final BSW 

Stage Showers

• Mill H Tested in Original MACT I Study

Bleached Mills C and D

• Bleached Uncoated Paper Machine Tested at Mill C

• Bleached Pulp Dryer Tested at Mill D

10
Pre- and Post-MACT Paper 

Machine Acetaldehyde Emissions

11

0.0E+00

2.0E-02

4.0E-02

6.0E-02

8.0E-02

1.0E-01

1.2E-01

TB 858 B H C D

Emissions, lb/ADTFP

Unbleached

Bleached

Pre-MACT

Averages

Post-MACT Paper Machines
Pre- and Post-MACT Paper 

Machine Formaldehyde Emissions

12

0.0E+00

5.0E-03

1.0E-02

1.5E-02

2.0E-02

2.5E-02

TB 858 B H C D

Emissions, lb/ADTFP

Unbleached

Bleached

Pre-MACT

Averages

Post-MACT Paper Machines
Methanol Emissions from all MACT I 

Study and Post-MACT Study Machines

13

y = 0.0049x + 0.056

R2 = 0.9689

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

0 50 100 150 200 250 300 350

Emissions, lb/ADTFP

White Water Concentration, mg/L

MACT I Study

Post-MACT, Unbleached

Post-MACT, Bleached
Methanol Emissions from all MACT I Study 

and Post-MACT Study Machines with White 

Water Methanol Concentrations <50 mg/L

14

y = 0.0059x + 0.0153

R2 = 0.9475

0

0.05

0.1

0.15

0.2

0.25

0.3

0.35

0 5 10 15 20 25 30 35 40 45 50

Emissions, lb/ADTFP

White Water Concentration, mg/L

MACT I Study, Unbleached

Post-MACT Study, Unbleached

Post-MACT Study, Bleached

MACT I Study, Bleached

Mill D Pulp Dryer

Mill C Paper Machine
Total Machine Acetaldehyde and Formaldehyde 

Emissions vs White Water Concentrations for the 

Post-MACT Study Machines

15

y = 0.0069x + 0.0035

R2 = 0.886

0.0E+00

2.0E-03

4.0E-03

6.0E-03

8.0E-03

1.0E-02

0 0.5 1 1.5 2

Emissions, lb/ADTFP

White Water Concentration, mg/L

Acetaldehyde

Formaldehyde
Summary

• Post-MACT Tests at Two Unbleached and 

Two Bleached Machines

• Acetaldehyde Emissions from Post-MACT 

Unbleached and Bleached Machines were 7% and 

12% of Pre-MACT Averages, Respectively

• Formaldehyde Emissions from Post-MACT 

Unbleached and Bleached Machines were 8% and 

36% of Pre-MACT Averages, Respectively

• Acrolein Emissions were Essentially Unchanged for 

Both the Unbleached and Bleached Machines

16
Attachment 4

Wastewater Treatment System HAP Emissions
Wastewater Treatment System 

HAP Emissions

Dr. Zach Emerson, Ashok Jain

NCASI

March 28, 2012
Refining Wastewater Treatment Plant 

Emission Estimates

• Develop/modify methods for measuring 

acetaldehyde, formaldehyde, acrolein and 

naphthalene content of effluents

• Conduct site-specific modeling of selected 

treatment systems with new effluent 

concentration data

2
Emissions Estimates from WWTP

• Often estimated using procedures used in 

NCASI SARA Handbook

• Calculations for emissions from a WWT unit 

take the form: E = Load · Fair

Load

Emissions Emissions

Load
Emissions Estimates from WWTP

HAP Loads from SARA Handbook (2010 Revision)

Acetaldehyde

Pulp Mill Sewer *Based upon Condensate

Handling Practices

Bleach Plant (n=10) 0.5 – 12.3

Mean = 1.86 mg/L

Formaldehyde

HW Bleach Plant (n=1) 0.21 – 0.32

Mean = 0.25 mg/L

SW Bleach Plant (n=1) 1.5 – 1.8

Mean = 1.65 mg/L

Naphthalene

Bleached Pulp Mill (n=3) ND (5) – 67.3

Mean = 24.3 μg/L

Unbleached Pulp Mill (n=3) ND (5 μg/L)

Acrolein Pulp Mill Sewer ND (1 mg/L)
Emissions Estimates from WWTP

• Emissions estimates are model-based

– Presented as fraction of inlet load that is volatilized

SARA Handbook:

WATER9

3-Basin ASB

fAir

AST

fAir

Methanol 5.0 %* < 0.1 %

Acetaldehyde 23.9 % 8.6 %

Formaldehyde 0.3 % < 0.1 %

Naphthalene 17.8 % 7.4 %
Analytical Method 

Development Studies

• Developed procedures for acetaldehyde, 

formaldehyde, acrolein and naphthalene 

appropriate for wastewater

• Achieved lower aqueous detection levels

• Demonstrated analyte recovery and stability

6
Method Development

• Sample Collection: 

– Based upon NCASI Method DI/MEOH-94.03 

• “Methanol in Process Liquids and Wastewaters by GC/FID”

• Sample Analysis: 

– Acetaldehyde, Formaldehyde & Acrolein: NCASI 

Method ISS-FP-A105.1

• “Derivatization method for Aldehydes, Ketones and Select 

Polar Compounds”

– Naphthalene: MS

7
Method Development

• Aqueous Detection Levels

– * Current detection levels are sample-specific

• Spike Recovery and Precision Trials

8

Previous Work Current*

Acetaldehyde 1 ppm 0.02 – 0.1 ppm

Formaldehyde 1 ppm 0.03 – 0.1 ppm

Acrolein 0.1 ppm 0.1 – 0.2 ppm

Naphthalene 5 ppb 0.3 – 1.8 ppb

Spike Recovery in 

Wastewater Precision

Acetaldehyde 80 - 103% 5.4 – 8.7%

Formaldehyde 97 – 136 % 7.6 – 9.8%

Acrolein 79 – 97 % N/A

Naphthalene 108 % N/A
NCASI Wastewater Study Focus

• Assist Facilities with Inventory Update

– Correct emissions locations, conditions and 

parameters

– Update WWTS emissions calculations

• Where appropriate, update loads to WWT 

• Create site-specific multi-zone emissions models

9
NCASI Wastewater Study Features

• Multi-facility Study

– 24 US kraft mills, 9 bleached and 15 unbleached 

(1 combined)

– Sample collection by mill staff, analysis by SRC

• Multi-scale

– 13 Mills - Samples collected from throughout 

treatment system

– 11 Mills - Inlets to primary and/or secondary 

treatment

10
NCASI Wastewater Study Results

• Effluent Concentrations

– Updated Post-MACT HAP concentrations 

– Primary effluent, bleach plant sewer

• Site-Specific Emissions Modeling

– Appendix C – Profile based model

– WATER9 – Influent based model

11
Effluent Concentrations 

Acetaldehyde SARA 313 Winter 2010 Study

Pulp Mill Effluent - Bleached N/A < 0.03 – 6.45

Mean = 0.19 mg/L

Pulp Mill Effluent - Unbleached N/A < 0.03 – 0.44

Mean = 0.19 mg/L

Bleach Plant Sewer 0.5 – 12.3

Mean = 1.86 mg/L

0.01 – 0.38 

Mean = 0.15 mg/L

Formaldehyde SARA 313 Winter 2010 Study

Pulp Mill Effluent - Bleached N/A < 0.03 – 0.44

Mean = 0.15 mg/L

Pulp Mill Effluent - Unbleached N/A < 0.03 – 0.32

Mean = 0.14 mg/L

Bleach Plant Sewer 0.21 – 0.32

Mean = 0.25 mg/L 0.03 – 0.42 

Mean = 0.19 mg/L Bleach Plant Sewer 1.5 – 1.8

Mean = 1.65 mg/L
Effluent Concentrations 

Naphthalene SARA 313 Winter 2010 Study

Pulp Mill Effluent – Bleached ND (5) – 67.10

Mean = 24.3 μg/L 0.38 – 3.91

Mean = 0.683 μg/L Pulp Mill Effluent – Unbleached ND (5) μg/L

Acrolein* SARA 313 Winter 2010 Study

Pulp Mill Effluent N/A ND [0.09 mg/L]

Bleach Plant Sewer N/A ND [0.05 mg/L]

*Acrolein was not detected in any wastewater sample
Site-Specific Emissions Modeling

• Appendix C: Form XIII Approach

– Based upon in-pond HAP concentrations

– Site specific system specs

– Similar to hard-pipe compliance calculations

• WATER9

– Site specific or industry typical inlet HAP concentrations

– Site specific system specs

– Similar to hard-pipe compliance calculations

• Examples

14
Emissions Estimates from WWTP

• HAP Loading

– May be based upon facility-generated data

– Some effluent concentrations presented in NCASI SARA Handbook

• Fair

– Estimated using emissions models (i.e. Water9) or pond-profile data

– Factors presented in SARA Handbook for a “typical” mill

Load

Emissions

Emissions

Load
Appendix C: Form XIII Approach

Zone Emissions Model

(CHAP)Measured

KGL

Emissions

from Zone 1

Appendix C approach uses in-pond measurements to calculate

flux at the surface. 

(CHAP)Measured

KGL

Emissions 

from Zone 2
WATER9 Approach

• Model tool that simulates emissions and 

biological destruction of HAPs for given load 

and system specs

17

HAP

Load

HAP 

Emissions
Appendix C Example: Mill A

18

Clarifier Emissions

Acet = 0.17 TPY

Form = 0.0 TPY

Naph = 0.0 TPY

ASB Emissions

Acet = 3.84 TPY

Form = 0.01 TPY

Naph = 0.0 TPY

Effluent

Load Concentration

Acet = 0.33 ppm

Form = 0.03 ppm

Naph = < 2.0 ppb

Pond Concentration

Acet = 0.06 ppm

Form = 0.04 ppm

Naph = < 2.0 ppb
 Appendix C Model built from site-specific 

dimensions, aeration, etc. 

 HAP concentrations from 3-days of sampling (8 

sample locations)

 Naphthalene not detected in any sample

Appendix C Example: Mill A

Comparison

Site – Specific Emission 

Rate

2010 RTR Database 

Value

Acetaldehyde 3.84 TPY 5.97 TPY

Formaldehyde 0.01 TPY 0.042 TPY

Naphthalene 0.0 TPY N/A

19
WATER9 Example: Mill D

20

Primary 

Clarifier Emissions

Acet = 0.01 TPY

Form = 0.0 TPY

UNOX Emissions

Acet = 0.1 TPY

Form = 0.01 TPY

Effluent

Measured

Load Concentration

Acet = < 0.024 ppm

Form = < 0.024 ppm

Secondary 

Clarifier Emissions

Acet = 0.0 TPY

Form = 0.0 TPY
 WATER9 Model built from site-specific 

dimensions, aeration, etc. 

 Inlet HAP concentrations from 3-days of 

sampling

Appendix C Example: Mill D

Comparison

Site – Specific Emission 

Rate

2010 RTR Database 

Value

Acetaldehyde 0.11 TPY 3.03 TPY

Formaldehyde 0.003 TPY N/A

21
Revised Modeling

Example Results

Estimation 

Approach

Concentration

Data

Estimated Emission 

Rates

(TPY)

2010 RTR Database 

Values

(TPY)

Mill A App C Full Profile

Acet = 3.84

Form = 0.01

Naph =0.0

Acet = 5.97

Form = 0.042

Naph = N/A

Mill B App C Full Profile

Acet = 1.45

Form = 0.02

Naph = 0.0

Acet = 5.74

Form = 0.054

Naph = N/A

Mill C App C Full Profile

Acet = 2.64

Form = 0.11

Naph = 0.0

Acet = 0.91

Form = 0.24

Naph = 0.732

22
Revised Modeling

Example Results

Estimation 

Approach

Concentration

Data

Estimated Emission 

Rates

(TPY)

2010 RTR Database 

Values

(TPY)

Mill D WATER9 Inlet Data

Acet = 0.11

Form = 0.003

Naph = N/A

Acet = 3.03

Form = N/A

Naph = N/A

Mill E WATER9 Inlet Data Acet = 7.7

Form = 0.007

Naph = 0.009

Acet = 15.2

Form = N/A

Naph = 0.225

Mill F WATER9 “Industry 

Typical”

Acet = 1.8

Form = 0.01

Naph = 0.006

Acet = 11.0

Form = 0.09

Naph = 0.25

23
Site-Specific Emissions Modeling

• Site-Specific Emissions Models for 32 facilities

– 17 Detailed Appendix-C type models

– 15 WATER9 models

– Updated inlet concentrations (without modeling) 

for 9 other facilities

• Emissions Results

– Acetaldehyde generally lower, sometimes higher

– Formaldehyde & Naphthalene always lower 24
Wastewater HAP Study

• Wastewater treatment system influent 

concentrations of formaldehyde, 

acetaldehyde and naphthalene were lower 

than previous studies

• Acrolein was not detected in any wastewater 

sample

• Successfully modeled many facilities 

– In most cases, new estimated emission rates were 

lower than those in EPA’s initial risk modeling

25