EPA

Office of Air Quality

Pla nnin g a nd S ta nd a rds

C Air

lean

United States Office of Air Quality EPA-456/R-01-002

Environmental Protection Planning and Standards September 2001

Agency Research Triangle Park, NC 27711 www.epa.gov/ttn/atw/pulp/pulppg.html

Pulping and Bleaching System NESHAP

for the Pulp and Paper Industry:

A Plain English Description
ii

Disclaimer

The Office of Air Quality Planning and Standards of the U.S. Environmental Protection Agency

has approved this document for publication. 

When using this document, remember that it is not legally binding and does not replace the

National Emission Standard for Hazardous Air Pollutants (NESHAP) for Source Category: 

Pulp and Paper Production (April 15, 1998, 63 FR 18504) for purposes of application of the rule

to any specific mill.

This document is not intended, nor can it be relied upon, to create any rights enforceable by any

party in litigation with the United States. The EPA may change this document at any time

without public notice.

Amendments to the Cluster Rule have been promulgated and are posted on the Technology

Transfer Network (TTN) at www.epa.gov/ttn/atw/pulp/pulppg.html. You should periodically

check this website for amendments and/or other relevant information.
iii

Chapter 1 - 

Introduction

Chapter 2 - 

Description of

the Pulping and

Bleaching

Processes

Contents

Page

1.1 What does this document do? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.2 Why do I need this document? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

1.3 How should I use this document? ................................ 3

1.4 What are the Pulp and Paper “Cluster Rules”? . . . . . . . . . . . . . . . . . . . . . . 4

Figure 1. Types of Mills Covered Under the Cluster

Rules . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Figure 2. Comparison of the Revised Final

Subcategories with Previous Subcategories . . . 7

1.5 What is the purpose of the Pulp and Paper NESHAP? . . . . . . . . . . . . . . . . 8

Figure 3. Highest Emitted Hazardous Air Pollutants

from Pulp and Paper Mills ................. 8

1.6 How many sources does the NESHAP affect? . . . . . . . . . . . . . . . . . . . . . 10

Figure 4. Location of Pulp and Paper Mills . . . . . . . . . . . . 10

1.7 What if I have questions? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

1.8 How do I get additional copies of this document? . . . . . . . . . . . . . . . . . . 11

1.9 Where can I find additional information about this NESHAP? . . . . . . . . 12

1.10 Where can I find additional information on the pulp and paper industry? 14

2.1 What distinguishes the types of mills that manufacture pulp and paper? . 15

Figure 5. Chemical Pulping Process Differences . . . . . . . . 16

2.2 What is the kraft pulping process? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Kraft digesting process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Figure 6. Example Overview of a Kraft Pulping Mill with

a Papermaking System . . . . . . . . . . . . . . . . . . . 18
Contents (Continued)

Page

iv

Kraft pulp processing steps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Figure 7. Brown Stock Washing System (Rotary Vacuum) 20

Evaporator system . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Oxygen delignification system . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Gas collection systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Figure 8. Typical Oxygen Delignification System

(Medium Consistency) . . . . . . . . . . . . . . . . . . . 23

Condensate stripping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2.3 What is bleaching? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Figure 9. Example Bleaching Line . . . . . . . . . . . . . . . . . . . 26

Bleaching chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Bleaching mixers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Bleaching retention towers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Bleached pulp washers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

What is pulp preparation and papermaking? . . . . . . . . . . . . . . . . . . . . . . . 29

2.4 Soda mills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

2.5 Sulfite mills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Figure 10. Example Sulfite Pulping System . . . . . . . . . . . . 32

2.6 Semi-chemical mills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Figure 11. Example Semi-chemical Pulping System . . . . . 34

2.7 Mechanical, secondary fiber, and non-wood fiber pulp mills . . . . . . . . . . 35

Mechanical pulping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Secondary fiber pulping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Non-wood fiber pulping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

2.8 References for Chapter 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
Contents (Continued)

Page

v

Chapter 3 - 

Overview of the

Pulp and Paper

NESHAP

Chapter 4 - 

NESHAP

Requirements

for Kraft Mills

3.1 Which mills are subject to the NESHAP? . . . . . . . . . . . . . . . . . . . . . . . . . 38

3.2 What processes and equipment systems must be controlled? . . . . . . . . . . 39

Figure 12. Equipment Systems Covered by the

Pulping Vent Standards . . . . . . . . . . . . . . . . . . 40

3.3 What are the emission control requirements? . . . . . . . . . . . . . . . . . . . . . . 41

Figure 13. Alternative Emission Limits . . . . . . . . . . . . . . . 42

3.4 What control systems will mills typically use to meet the emission

limits? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

3.5 How do mills demonstrate initial and continuous compliance? . . . . . . . . 44

Figure 14. What Pollutants or Surrogates Must

Be Measured? . . . . . . . . . . . . . . . . . . . . . . . . . 46

3.6 When must mills comply? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

3.7 What additional requirements apply to new sources? . . . . . . . . . . . . . . . . 48

3.8 What is a new source? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

4.1 Standards for kraft pulping system vents . . . . . . . . . . . . . . . . . . . . . . . . . 52

What kraft pulping system vents must be controlled? . . . . . . . . . . . . . . . . 52

What are the emission limits for kraft pulping system vents? . . . . . . . . . 53

What does the NESHAP require for enclosures and closed-vent systems? 54

When must mills comply with the kraft pulping vent standards? . . . . . . . 55

How does a mill demonstrate initial compliance with the kraft

pulping system vent standards? . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

Figure 15. How Does a Mill Demonstrate Initial

Compliance with the Kraft Pulping

System Vent Emission Limits? . . . . . . . . . . . . 56

How does a mill demonstrate continuous compliance with the

kraft pulping system vent standards? . . . . . . . . . . . . . . . . . . . . . . . 57
Contents (Continued)

Page

vi

Figure 16. How Does a Mill Demonstrate Initial and

Continuous Compliance with the

Closed-Vent Systems Standard? . . . . . . . . . . . 57

Figure 17. How Does a Mill Demonstrate Continuous

Compliance with the Kraft Pulping

System Vent Emission Limits? . . . . . . . . . . . . 58

Must a mill comply at all times? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

4.2 Standards for kraft pulping process condensates . . . . . . . . . . . . . . . . . . . 60

What is a condensate and why control it? . . . . . . . . . . . . . . . . . . . . . . . . . 60

What kraft pulping condensates must be controlled? . . . . . . . . . . . . . . . . 60

Does the mill have to collect all those streams? . . . . . . . . . . . . . . . . . . . . 61

What are the control requirements? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

What does the NESHAP require for condensate closed

collection systems? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

When must a mill be in compliance? . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

How does a mill demonstrate initial compliance for kraft pulping process

condensate standards? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Figure 18. How Does a Mill Demonstrate Initial

Compliance with Kraft Pulping Condensate

Emission Limits? . . . . . . . . . . . . . . . . . . . . . . . 65

How does a mill demonstrate continuous compliance with

pulping process condensate standards? . . . . . . . . . . . . . . . . . . . . . . 65

Figure 19. How Does a Mill Demonstrate Continuous

Compliance with Kraft Pulping Process

Condensate Emission Limits? . . . . . . . . . . . . . 66

Must a mill comply at all times? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

4.3 Standards for the kraft bleaching system vents . . . . . . . . . . . . . . . . . . . . . 68

What bleaching emission points must be controlled? . . . . . . . . . . . . . . . . 68

Are there any exemptions to the bleaching requirements? . . . . . . . . . . . . 68

What are the control requirements for chlorinated HAPs? . . . . . . . . . . . . 69

What are the control requirements for chloroform? . . . . . . . . . . . . . . . . . 69

When must bleaching systems comply? . . . . . . . . . . . . . . . . . . . . . . . . . . 70

How does a mill demonstrate initial compliance with the

bleaching standards? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71
Contents (Continued)

Page

vii

Chapter 5 - 

NESHAP

Requirements

for SemiChemical and

Soda Mills

How does a kraft mill demonstrate continuous compliance with

the bleaching standards? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Figure 20. How Does a Kraft Mill Demonstrate

Continuous Compliance with Emission

Limits for Chlorinated HAPs? . . . . . . . . . . . . . 73

4.4 Clean condensate alternative for HVLC vents . . . . . . . . . . . . . . . . . . . . . 75

Which equipment systems can be used to generate the emission reductions?76

What emission reductions are creditable? . . . . . . . . . . . . . . . . . . . . . . . . . 76

Can a mill use the CCA for only part of the emission reduction requirement

for the HVLC system? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76

How does a mill use the CCA? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77

How does a mill demonstrate initial compliance? . . . . . . . . . . . . . . . . . . . 78

How does a mill demonstrate continuous compliance? . . . . . . . . . . . . . . 78

What approvals are required to use the CCA? . . . . . . . . . . . . . . . . . . . . . 78

4.5 How do the requirements for the NSPS and the NESHAP compare? . . . . 79

Figure 21. Comparison of NESHAP and NSPS Alternative

Emission Limit(s) Requirements . . . . . . . . . . . 80

5.1 Standards for semi-chemical and soda pulping system vent standards . . . 82

What pulping system vents must be controlled? . . . . . . . . . . . . . . . . . . . . 82

What are the emission limits for semi-chemical and soda pulping system

vents? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83

What does the NESHAP require for enclosures and closed-vent systems at

semi-chemical and soda mills? . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84

When must mills comply with the semi-chemical and soda pulping process

standards? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

How does a mill demonstrate initial and continuous compliance with the

pulping system vent standards? . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

Must a mill comply at all times? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

5.2 Standards for bleaching system vents at semi-chemical and soda mills . . 86

Semi-chemical mills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

Soda mills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86
Contents (Continued)

Page

viii

Chapter 6 - 

NESHAP

Requirements

for Sulfite Mills

Chapter 7 - 

NESHAP

Requirements

for Mechanical,

Secondary

Fiber, and Nonwood Fiber Pulp

Mills

6.1 Standards for sulfite pulping system vents . . . . . . . . . . . . . . . . . . . . . . . . 88

What sulfite pulping system vents must be controlled? . . . . . . . . . . . . . . 88

What are the emission limits for sulfite pulping system vents? . . . . . . . . 89

What does the NESHAP require for enclosures and closed-vent systems? 90

When must mills comply with the sulfite pulping process requirements? 91

How does a mill demonstrate initial compliance with the sulfite pulping

system vent standards? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91

How does a mill demonstrate continuous compliance with the

sulfite pulping system vent standards? . . . . . . . . . . . . . . . . . . . . . . 92

Figure 23. How Does a Mill Demonstrate Initial and

Continuous Compliance with

the Closed-Vent Systems Standard? . . . . . . . . 92

Figure 24. How Does a Mill Demonstrate Continuous

Compliance with the Sulfite Pulping System

Vent Standards? . . . . . . . . . . . . . . . . . . . . . . . . 93

6.2 Standards for sulfite bleaching system vents . . . . . . . . . . . . . . . . . . . . . . 94

When must sulfite bleaching systems comply? . . . . . . . . . . . . . . . . . . . . . 94

7.1 Standards for bleaching system vents . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

What mechanical, secondary fiber, and non-wood fiber bleaching system

emission points must be controlled? . . . . . . . . . . . . . . . . . . . . . . . . 95

Are there any exemptions to the bleaching requirements? . . . . . . . . . . . . 96

What are the control requirements for chlorinated HAPs? . . . . . . . . . . . . 96

When must mechanical, secondary fiber, and non-wood fiber bleaching

systems comply? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

How does a mill demonstrate initial compliance with the

bleaching standards? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97

How does a mill demonstrate continuous compliance with the bleaching

standards? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

Figure 25. How Does a Kraft Mill Demonstrate

Continuous Compliance with Emission

Limits for Chlorinated HAPs? . . . . . . . . . . . . . 99
Contents (Continued)

Page

ix

Chapter 8 - 

Other Federal

Regulations

Affecting Pulp

and Paper Mills

Appendices

8.1 What other Federal air regulations affect the pulp and paper industry? . 101

8.2 What other Federal water regulations affect the pulp and paper industry?103

Figure 26. A Guide to the Acronyms for

Technology-Based Water Standards . . . . . . . 105

Figure 27. Applicability of Technology-Based

Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106

8.3 What Federal hazardous wastes regulations affect the pulp and paper

industry? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107

8.4 What upcoming regulations will affect pulp and paper mills? . . . . . . . . 109

A: List of U.S. Pulp and Paper Mills

B: NESHAP for Source Category: Pulp and Paper Production

C: Flowchart Summary of the NESHAP

D: List of EPA Region Office Contacts

E: Equipment Diagrams for Pulp and Paper Mills

F: List of Equipment Affected by the NESHAP

G: Pulp and Paper NESHAP Control Requirements

H: Compliance Milestones Timeline for Existing Sources

I: Summary of Effluent Limitations Guidelines for Bleached

Papergrade Kraft Mills

J: Inspection Checklists
1

Subpart MM

establishes emission

limits for gaseous

organic and metal

HAP for chemical

recovery processes

that involve the

combustion of spent

pulping liquor at

kraft, soda, sulfite,

and semi-chemical

pulp mills. 

This document does

NOT replace the

NESHAP for purposes

of making legal

interpretations!

Chapter 1 - Introduction

The U.S. Environmental Protection Agency (EPA) has published two

National Emission Standards for Hazardous Air Pollutants (NESHAP) for

the Pulp and Paper Industry:

• 40 CFR 63, Subpart S was published on April 15, 1998, and

applies to the pulping and bleaching systems at all chemical

pulping mills and bleaching systems at mechanical pulping,

non-wood fiber, and secondary fiber mills.

• 40 CFR 63, Subpart MM was published on January 12, 2001

and applies to chemical recovery processes that involve the

combustion of spent pulping liquor.

These NESHAP require affected sources to control hazardous air pollutant

(HAP) emissions using the maximum achievable control technology

(MACT).

Subpart S was published as part of the Pulp and Paper Cluster Rules and

affects the pulping and bleaching systems at major sources that chemically

and nonchemically pulp wood and non-wood fibers for pulp and paper

production. The Cluster Rules also revised the effluent limitations

guidelines and standards under the Clean Water Act for pulp mills that

make bleached papergrade products. 

1.1 What does this document do?

This document focuses on the pulping and bleaching system NESHAP

(Subpart S) and describes:

 the pulping and bleaching processes

 the requirements of the NESHAP

 the scope of effluent limitations guidelines and standards

revisions

 additional references and sources of information about pulp

and paper mills
Chapter 1 - Introduction

2

1.2 Why do I need this document?

You need this document because it will help you understand the NESHAP.

Implementation of the pulp and paper NESHAP is complex for both

affected mills and regulators because:

 There is a tremendous amount of variability in the pulp and

paper industry with respect to processes, equipment, and

products. For example, the task of turning wood into pulp is

performed by different processes using different equipment

and different chemicals at kraft mills, sulfite mills, and

mechanical pulping mills. As a result, different emission

points must be controlled at each type of mill.

 The NESHAP allows for a significant amount of flexibility

in the control strategies used to reach compliance.

 The timelines for compliance vary for different parts of the

mill.

 More stringent control requirements apply to some new

sources.

 Technical requirements for some of the available control

strategies will be specified on a mill-by-mill basis by the

implementing agency.
Chapter 1 - Introduction

3

1.3 How should I use this document?

If you are familiar with the pulping and bleaching processes, there is no

need to read Chapter 2. You should skip ahead to Chapter 3. Everyone

should read Chapter 3 as it provides the overview of the NESHAP. After

reading Chapter 3, you should decide what other sections of the document

you need.

If You Need the Following Information... Then Read...

A description of the Cluster Rules Chapter 1

A description of pulping and bleaching processes Chapter 2

An overview of the NESHAP Chapter 3

A description of how new source requirements

apply

Chapter 3

NESHAP requirements for kraft mills Chapter 4

NESHAP requirements for soda and semichemical millsChapter 5

NESHAP requirements for sulfite mills Chapter 6

NESHAP requirements for mechanical, secondary

fiber, and non-wood fiber pulp mills

Chapter 7

A description of other existing and upcoming

Federal regulations affecting pulp and paper mills

Chapter 8

A list of pulp and paper mills Appendix A

A copy of the NESHAP Appendix B

Flowchart summary of the NESHAP Appendix C

A list of EPA Regional Office contacts Appendix D

Equipment diagrams Appendix E

A list of equipment affected by the NESHAP Appendix F

A summary of the NESHAP control requirements Appendix G

A timeline of compliance milestones Appendix H

Summary of effluent limitations guidelines and

standards for bleached papergrade kraft mills

Appendix I
Chapter 1 - Introduction

4

Stay informed about

new or revised

requirements by

visiting "What’s New"

pages of the OECA

and Air Toxics

Websites:

http://es.epa.gov/

oeca/wn2.html

and

http://www.epa.gov/

ttn/atw/atwnew.html

1.4 What are the Pulp and Paper “Cluster Rules”?

The Cluster Rules are a simultaneous publication of Federal air and water

pollution control regulations. They are an example of the EPA’s efforts to

simplify compliance by coordinating the regulation of multimedia industrial

pollution and will reduce both air and water pollutant discharges. You can

get an electronic copy of the Cluster Rules from the Federal Register

website at http://www.access.gpo.gov/su_docs/aces/aces140.html or the

EPA Air Toxics website at http://www.epa.gov/ttn/atw on the Rules and

Implementation Page.

The goals of this coordinated regulatory approach are to:

 provide greater protection of human health and the

environment

 reduce the overall cost of complying with wastewater

regulations and air emissions controls

 promote and facilitate coordinated compliance planning by

the industry

 promote and facilitate pollution prevention

 emphasize the multimedia nature of pollution control

Figure 1 identifies the mill types covered under the Cluster Rules. 

Appendix A lists the mills potentially affected by the Cluster Rules by

facility name and location.

Figure 1.

Types of Mills Covered Under the Cluster Rules

Then it is Subject to These Parts of the Cluster Rules...

If the Mill is this Type... NESHAP

Revised Effluent Limitations

Guidelines and Standards

Kraft X Bleached Papergrade only

Soda X Bleached Papergrade only

Sulfite X Papergrade only

Semi-Chemical X

Mechanical X

Non-Wood Fiber X

Secondary Fiber X
Chapter 1 - Introduction

5

The features of the

NESHAP are:

 Alternative emission

 limits

 Varying compliance

 periods (3-8 years)

 New and existing

 source controls

 Flexibility for

 evolving

 technologies

 Compliance dates

 coordinated with

 effluent limitations

 guidelines and

 standards

The Cluster Rules consist of the following two components:

(1) National Emission Standards for Hazardous Air Pollutants

(NESHAP) from the Pulp and Paper Industry

(40 CFR 63, Subpart S). The pulp and paper NESHAP specifies

emission standards for pulping and bleaching systems at all chemical

pulping mills and bleaching systems at mechanical pulping, nonwood fiber, and secondary fiber mills.

The air emissions control standards require mills to reduce

hazardous air pollutant emissions through the use of thermal

oxidizers, boilers, lime kilns, recovery furnaces, caustic scrubbers,

or other control devices, or process modifications. In general, the

NESHAP requires mills to:

 collect and incinerate pulping process vent emissions

 collect and control bleaching process vent emissions

with a caustic scrubber

 eliminate the use of certain bleaching chemicals

 collect and treat process condensate streams to

remove HAPs (kraft mills only)

The NESHAP is written to encourage pollution prevention

techniques. See Appendix B for a copy of the NESHAP and

Appendix C for a flowchart summary of the NESHAP.

This NESHAP does NOT address emissions from chemical recovery

process combustion sources. Emissions from these sources are

covered by 40 CFR 63, Subpart MM, which was promulgated on

January 12, 2001 (66 FR 3180).
Chapter 1 - Introduction

6

Stay informed

about new or

revised

requirements by

visiting the EPA

Office of Water’s

Pulp and Paper

Website:

http://www.epa.

gov/ost/pulppaper/

(2) Effluent Limitations Guidelines and Standards, Pretreatment

Standards, and New Source Performance Standards for the Pulp,

Paper, and Paperboard Category (40 CFR 430, Subparts A-L). 

These regulations control discharge of pollutants in wastewaters

generated at pulp and paper mills. The pretreatment standards apply

to mills that discharge wastewater to a municipal wastewater

treatment facility (i.e., Publicly Owned Treatment Works or POTW). 

The effluent limitations guidelines and standards are applied to the

mills that directly discharge into receiving water via the National

Pollution Discharge Elimination System (NPDES) permit program. 

In addition, the effluent limitations guidelines and standards portion

of the Cluster Rules:

 Includes best management practices (BMP)

regulations for a portion of the pulp, paper, and

paperboard industry. The BMP rules are designed to

prevent or contain leaks and spills of pulping liquor,

soap, and turpentine, and to control any intentional

diversions of these substances.

 Specifies new analytical methods for twelve

chlorinated phenolic pollutants and for adsorbable

organic halides (AOX).

 Revises the subcategorization scheme for existing

effluent limitations guidelines and standards for the

pulp and paper industry (shown in Figure 2) and

revises the effluent limitations guidelines and

standards for Bleached Papergrade Kraft and Soda

subcategory (Subpart B) and the Papergrade Sulfite

subcategory (Subpart E). The EPA revised the

subcategorization scheme to better define the

processes typically found in U.S. mills.

 Includes the Voluntary Advanced Technology

Incentives Program which is designed to encourage

direct discharging bleached papergrade kraft mills to

install more pollution prevention technology than

required by the regulations.
Chapter 1 - Introduction

7

Figure 2.

Comparison of the Revised Final

Subcategories with Previous Subcategories

Final

Codified

Subpart

Final 

Subcategorization

Scheme

Previous Subcategorization

 Scheme with Previous 

40 CFR 430 Subparts Noted in Parentheses

A Dissolving Kraft Dissolving Kraft (F)

Ba Bleached Papergrade Kraft and Soda Market Bleached Kraft (G)

BCT Bleached Kraft (H)

Fine Bleached Kraft (I)

Soda (P)

C Unbleached Kraft Unbleached Kraft (A)

- Linerboard

- Bag and Other Products

Unbleached Kraft and Semi-Chemical (D, V)

D Dissolving Sulfite Dissolving Sulfite (K)

- Nitration

- Viscose

- Cellophane

- Acetate

Ea Papergrade Sulfite Papergrade Sulfite (J,U)

- Blow Pit Wash

- Drum Wash

F Semi-Chemical Semi-Chemical (B)

- Ammonia

- Sodium

G Mechanical Pulp GW-Thermo-Mechanical (M)

GW-Coarse, Molded, News (N)

GW-Fine Papers (O)

GW-Chemical-Mechanical (L)

H Non-Wood Chemical Pulp Miscellaneous mills not covered by a specific subpart

I Secondary Fiber Deink Deink Secondary Fiber (Q)

- Fine Papers

- Tissue Papers

- Newsprint

J Secondary Fiber Non-Deink Tissue from Wastepaper (T)

Paperboard from Wastepaper (E)

- Corrugating Medium

- Non-Corrugating Medium

Wastepaper-Molded Products (W)

Builders’ Paper and Roofing Felt

(40 CFR Part 431 Subpart A)

K Fine and Lightweight Papers from Purchased Pulp Non-Integrated Fine Papers (R)

- Wood Fiber Furnish

- Cotton Fiber Furnish

Lightweight Papers (X)

- Lightweight Papers

- Lightweight Electrical Papers

L Tissue, Filter, Non-Woven, and Paperboard from

Purchased Pulp

Non-Integrated

- Tissue Paper (S)

- Filter and Non-Woven (Y)

- Paperboard (Z)

a

 Revised under the Cluster Rules.
Chapter 1 - Introduction

8

A major source is a

stationary source that

has the potential to

emit 10 tons per year

of any one HAP or

25 tons per year of

total HAPs.

1.5 What is the purpose of the Pulp and Paper

NESHAP?

The purpose of this NESHAP is to reduce HAP emissions from the pulp and

paper industry, thus reducing public health hazards. The EPA regulated this

industry because pulp and paper mills are major sources of HAP emissions

listed in Section 112 of the Clean Air Act (CAA). Section 112(d) of the

CAA directs EPA to set maximum achievable control technology (MACT)

standards for major stationary sources. MACT standards are technologybased emission limitations that require the maximum degree of emission

limitations that is achievable considering cost, human health,

environmental, and energy impacts.

Pulp and paper mills emit 240,000 tons of HAPs annually that impact both

air quality and public health. The pulp and paper NESHAP will reduce

1996 emissions of HAPs from pulp and paper facilities by 153,000 tons per

year (a 64 percent reduction). Figure 3 lists the HAPs emitted in the largest

quantities from pulp and paper mills. 

Figure 3.

Highest Emitted Hazardous Air Pollutants

from Pulp and Paper Mills

Hazardous Air Pollutants

Acrolein Methanol

Acetaldehyde Methylene chloride

o-Cresol Methyl ethyl ketone

Carbon tetrachloride Phenol

Chloroform Propionaldehyde

Cumene 1,2,4-Trichlorobenzene

Formaldehyde o-Xylene
Chapter 1 - Introduction

9

The control techniques used to reduce HAP emissions will also reduce

emissions of other pollutants. For example, the NESHAP will reduce

volatile organic compound (VOC) emissions by 450,000 tons per year. 

Volatile organic compounds cause a variety of adverse health effects and are

precursors to the formation of tropospheric (ground level) ozone.

Emissions of total reduced sulfur (TRS) compounds cause the odors

commonly associated with pulp and paper production. Exposure to TRS

emissions has been linked to symptoms including headaches, watery eyes,

nasal problems, and breathing difficulties. Total reduced sulfur emissions

are regulated by new source performance standards (NSPS) under

Section 111 of the CAA. Although not specifically regulated by the

NESHAP, the NESHAP will result in a reduction of TRS emissions by

87,000 tons per year. 
Chapter 1 - Introduction

10

The list of mills in

Appendix A is

provided for

information only. 

The list is not

necessarily

complete, nor does

it represent an

EPA determination

that any specific

mill is subject to

the rules.

1.6 How many sources does the NESHAP affect?

Figure 4 shows the location of the pulp and paper facilities in the United

States that are potentially affected by the pulp and paper NESHAP. 

Appendix A lists the pulp and paper mills (including facility name, and

location by city and state) that were identified as potentially affected sources

at the time the NESHAP was published.

Figure 4.

Location of Pulp and Paper Mills

State Mills State Mills State Mills

Alabama 19 Kansas 2 New Mexico 1

Arkansas 8 Kentucky 5 New York 49

Arizona 2 Louisiana 13 Ohio 30

California 34 Massachusetts 38 Oklahoma 6

Colorado 1 Maryland 3 Oregon 12

Connecticut 10 Maine 18 Pennsylvania 31

Delaware 2 Michigan 33 South

Carolina

9

Florida 11 Minnesota 9 Tennessee 13

Georgia 24 Missouri 3 Texas 11

Iowa 2 Mississippi 10 Virginia 12

Idaho 1 Montana 1 Vermont 6

Illinois 10 North

Carolina

17 Washington 22

Indiana 12 New

Hampshire

12 Wisconsin 46

New Jersey 14 West Virginia 2

Total 564

Source: Lockwood-Post Directory, 1996.
Chapter 1 - Introduction

11

Identify your State

and local contacts

using the Membership

Directory at the

STAPPA/ALAPCO

website at

http://www.4cleanair.

org

STAPPA/ALAPCO =

State and Territorial

Air Pollution

Program

Administrators/

Association of Local

Air Pollution Control

Officials

Copies are

available free of

charge from the

EPA library.

1.7 What if I have questions?

If you are the owner or operator of a pulp and paper mill, you can get

additional information from:

 your State or local air pollution control agency

 trade associations, such as Technical Association of the Pulp

& Paper Industry (TAPPI) at http://www.tappi.org or

American Forest and Paper Association (AF&PA) at

http://www.afandpa.org

If you work for a State or local regulatory agency and have questions

regarding the implementation of this NESHAP, you should contact your

EPA Regional Office. A list of EPA Regional Office contacts is included in

Appendix D. 

1.8 How do I get additional copies of this document?

You can get copies of this document from:

 EPA’s Technology Transfer Network (TTN) on the world

wide web at http://www.epa.gov/ttn/atw/pulp/pulppg.html

 Library Services Office (MD-35)

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

Telephone: (919) 541-2777

 National Technical Information Services (NTIS)

Technology Administrations

5285 Port Royal Road

Springfield, Virginia 22161

Telephone: (703) 605-6000

Fax: (703) 321-8547

Note: NTIS will charge a fee for each document

requested.
Chapter 1 - Introduction

12

An overview of this

NESHAP is

available on a

40 minute video

tape. You can view

this tape at your

State or local air

pollution control

office.

Check the ATW for

correction notices

and amendments.

1.9 Where can I find additional information about this

NESHAP?

You can find information about the basis and purpose of this NESHAP in

the Federal Register notices and background information documents. The

background information documents are:

 Pulp, Paper, Paperboard Industry - Background Information

for Proposed Air Emissions Standards for Manufacturing

Processes at Kraft, Sulfite, Soda, and Semi-chemical Mills. 

Publication No. EPA-453/R-93-050a. October 1993

 Pulp, Paper, Paperboard Industry - Background Information

for Promulgated Air Emissions Standards for Manufacturing

Processes at Kraft, Sulfite, Soda, and Semi-Chemical,

Mechanical, and Secondary and Non-wood Fiber Mills. 

Publication No. EPA-453/R-93-050b. October 1997

Federal Register notices pertaining to the NESHAP are:

 Proposed NESHAP: published December 17, 1993

(58 FR 66078)

 Correction notice to the proposed NESHAP: published

March 17, 1994 (59 FR 12567)

 Notice of Data Availability (NODA): published

February 22, 1995 (60 FR 9813)

 Supplemental Notice: published March 8, 1996

(61 FR 9383)

 Promulgated NESHAP: published April 15, 1998

(63 FR 18504)

 Correction of minor errors on the April 15, 1998 Notice: 

published August 7, 1998 (63 FR 42238)

 Interpretation and Technical Amendment published

September 16, 1998 (63 FR 49455)
Chapter 1 - Introduction

13

 Proposed amendments regarding the interim MACT standard 

(63 FR 71408) and direct final rule, December 28, 1998

(63 FR 71385)

 Direct Final Amendment: Addresses nine technical issues

raised by the industry. April 12, 1999 (64 FR 17555)

 Proposed amendments to add testing and monitoring

alternatives (65 FR 3907), published January 25, 2000

 Final Rule Amendments: Adds alternatives to the testing and

monitoring of boilers and open biological treatment units 

December 22, 2000 (65 FR 80755)

 Final Rule Amendments: Includes amendments to

Appendix C. January 22, 2001 (66 FR 6922)

You can get these documents and other relevant documents from:

 EPA’s Air Toxics website (ATW) at

http://www.epa.gov/ttn/atw or

http://www.epa.gov/ttn/atw/pulp/pulppg.html. These

sites contain background documents, preambles, regulations,

guidance documents, and policy memos

 “What’s New” page of the ATW at

http://www.epa.gov/ttn/atw/atwnew for the most current

information

 The Air Dockets (A-92-40 and A-95-31) are available for

public inspection between 8 a.m. and 4 p.m., Monday

through Friday, except for Federal holidays. The address for

the dockets can be found at

http://www.epa.gov/ttn/atw/pulp/pulppg.html.
Chapter 1 - Introduction

14

The Kraft Pulp

Mill Compliance

Assessment Guide

covers the Cluster

Rules as well as

NSPS and other

rules affecting

kraft mills.

1.10 Where can I find additional information on the

pulp and paper industry?

You can get additional information from:

 Biermann, C.J. 1993. Essentials of Pulping and

Papermaking. San Diego, CA: Academic Press, Inc.

 Burgess, T. 1995. The Basics of Foul Condensate Stripping. 

1995 Kraft Recovery Short Course. Atlanta, GA: 

TAPPI PRESS.

 EPA. 1998. Permit Guidance Document for Pulp, Paper and

Paperboard Manufacturing Point Source Category, 40 CFR

Part 430, draft. Office of Water, Washington, DC.

 EPA. 1995. Office of Compliance Sector Notebook Project: 

Profile of the Pulp and Paper Industry. 

Publication No. EPA/310-R-95-015. 

http://es.epa.gov/oeca/sector/index.html#pulp Office of

Enforcement and Compliance Assurance, Washington, DC.

 EPA. 1999. Kraft Pulp Mill Compliance Assessment Guide. 

Publication No. EPA/310-B-99-001. Office of Enforcement

and Compliance Assurance, Washington, DC.

 How Paper is Made: An Overview of Pulping and

Papermaking from Woodyard to Finished Product. 1997. 

Available on CD-ROM, Atlanta, GA: TAPPI PRESS.

 Kocurek, M.J. and Stevens, C.F.B., eds. 1983. Pulp and

Paper Manufacture. Third Edition. Joint Textbook

Committee of the Paper Industry.

 Mimms, A., Kocurek, M., Pyatte, J. and Wright, E. eds. 

1993. Kraft Pulping. Atlanta, GA: TAPPI PRESS.

 Smook, G.A. 1992. Handbook for Pulp and Paper

Technologists. Second Edition. Bellingham, WA: Angus

Wilde Publications.
15

If you are already

familiar with

pulping and

bleaching

processes, you can

move ahead to

Chapter 3.

The types of pulp

mills are:

 kraft

 soda

 sulfite

 semi-chemical

 mechanical

 secondary fiber

 non-wood fibers

Chapter 2 - Description of the Pulping and

Bleaching Processes

Three major types of fibers are used to make pulp and paper products: 

wood; secondary fibers (recycled fibers); and non-wood fibers (e.g., cotton,

flax, hemp). However, the majority of pulp and paper products are made

from wood, and most wood mills use the kraft pulping process.

Because kraft mills represent the majority of the industry, this chapter

describes the processes at kraft mills using wood. A general process

overview for each of the other types of mills is also provided. This chapter

does not explain each individual process, but rather focuses on the main

activities affected by the NESHAP. For further information about the pulp

and paper industry and process operations, please refer to the list of

materials provided in Chapter 1.

2.1 What distinguishes the types of mills that

manufacture pulp and paper?

Kraft, soda, and sulfite mills all use chemicals in their pulping processes.

These processes differ primarily in the chemicals used for digesting wood

chips. Mechanical pulping involves shredding or grinding wood chips

without the use of chemicals and semi-chemical pulping combines chemical

and mechanical methods. Secondary fiber mills mechanically separate pulp

from waste paper products. Non-wood fiber mills can use mechanical and

chemical pulping processes. Figure 5 summarizes the characteristics of the

different types of chemical pulping processes.
Chapter 2 - Pulping and

Bleaching Processes

16

Figure 5.

Chemical Pulping Process Differences

Pulping

Process Type

Typical

Pulp

Produced

Chemicals

Used

Typical

Pulp

Yield

Percent

Type of Wood

Used

Typical Pulp

Uses

Kraft Kraft NaOH, Na2S 40-50 Softwood and

hardwood

Writing paper;

paper bags;

cardboard;

specialty

products such

as rayon,

acetate, and

cellophane

Soda Soda NaOH 45-55 Hardwood Writing paper;

specialty

products such

as rayon,

acetate, and

cellophane

Sulfite Acid sulfite H2SO3,

M(HSO3)

(M=Ca, Mg,

Na, NH4)

45-55 Softwood and

hardwood

Writing paper;

specialty

products such

as rayon,

acetate, and

cellophane

Semi-chemical Neutral

Sulfite

Semichemical

Na2SO3

Na2CO3

65-80 Hardwood Corrugated

containers

 Source: Smook, 1992.
Chapter 2 - Pulping and

Bleaching Processes

17

The NESHAP has

the same emission

limits for

papergrade and

dissolving grade

pulp production.

2.2 What is the kraft pulping process?

The pulping process converts raw materials into a fibrous mass that can be

formed into paper or cardboard. Wood contains both cellulose fibers and

lignin; the objective of the kraft pulping process is to dissolve the lignin and

leave most of the cellulose fibers intact.

The main operations performed in the kraft pulping process are: 

 digestion of wood to form pulp

 pulp processing to recover spent cooking chemicals and to

remove impurities and uncooked wood chips (deknotting,

pulp washing, pulp screening)

 concentration of used pulping liquor for chemical recovery

Figure 6 depicts a typical overview of a kraft pulp and paper mill. More

detailed diagrams for each equipment system in the pulping process are

provided in Appendix E.

Kraft digesting process

Kraft pulping entails cooking, or digesting, wood chips at elevated

temperature and pressure in an alkaline pulping liquor that contains sodium

sulfide (Na2S) and sodium hydroxide (NaOH). Cooking may be performed

in either batch digester or continuous digester systems. For mills that use

softwood feedstock (e.g., pine), the digester system generally will include a

turpentine recovery system. The turpentine is recovered from digester relief

vent gases. 

The pulping liquor and elevated temperature and pressure promote

breakdown of the bonds in the lignin compounds. Depending on pulping

conditions, as much as 90-95 percent of the lignin can be removed from

wood in kraft pulping.

Two types of pulp are produced:

 papergrade (for making paper, paperboard, tissue)

 dissolving grade (for making rayon, cellophane, acetate, food

additives)
18

Figure 6.

Example Overview of a Kraft Pulping Mill with a Papermaking System
Chapter 2 - Pulping and

Bleaching Processes

19

Pulp

from

Digester

Pulp

to 

Washer

Knots

Weak black liquor

consists of

dissolved wood

compounds and

spent cooking

chemicals. 

Kraft pulp processing steps

Kraft mills remove impurities from the raw pulp prior to bleaching or

papermaking. The primary pulp cleaning operations include deknotting (in

the knotter), brown stock washing (in the pulp washing system), and pulp

screening (in the screening system).

Deknotting removes

knots and other

portions of uncooked

wood from the pulp

slurry. Kraft mills

burn the knots and

uncooked wood for

energy recovery,

dispose of them as

waste, or recycle them

for repulping. The diagram to the right shows a typical knotter.

Brown stock washing recovers spent cooking liquor (weak black liquor) for

reuse in the pulping process. Efficient washing is critical to maximize the

return of cooking liquor to chemical recovery and to minimize carryover of

cooking liquor (known as brown stock washing loss) into the bleach plant. 

A variety of brown stock washing technologies are used; the most common

technology is a series of two to four rotary vacuum washers. In each

washer, wash water is applied to displace cooking liquor in the pulp;

countercurrent washing is generally used to reduce fresh water

requirements. Other common washer types are diffusion washers, rotary

pressure washers, horizontal belt filters, wash presses, and

dilution/extraction washers. Figure 7 shows a typical rotary vacuum washer

system.
20

Washer Washer Washer

Water

Pulp from

Knotter

System

Sealtank

Sealtank

Sealtank

Foam

tank

Pulp

storage

tank 

Scr

Hood vent gases

Figure 7.

Brown Stock Washing System (Rotary Vacuum)
Chapter 2 - Pulping and

Bleaching Processes

21

A screen system

removes oversized

particles from the

pulp slurry prior to

the bleaching or

papermaking

system.

A decker is used to

thicken the pulp for

storage after

screening or

subsequent

delignification

steps.

Pulp screening removes the remaining oversized particles (fiber bundles

and contaminants) from washed pulp. The pulp is diluted to low percent

solids, then passed through a perforated screen, and rejects are continuously

removed from the screen. Methods for removing rejects are shaking and

vibration, hydraulic sweeping action, back-flushing, or pulsing the flow

through the openings with various moving foils, paddles, and bumps. Mills

may operate open, partially closed, or closed screen rooms. In open screen

rooms, wastewater from the screening process is discharged to wastewater

treatment. In closed screen rooms, wastewater is reused in brown stock

washing or other pulping operations and ultimately enters the chemical

recovery system. 

A decker system is all of the equipment used to thicken the pulp slurry after

the pulp washing system. It includes decker vents, filtrate tanks, and

vacuum pumps.

Evaporator system

Weak black liquor collected from the pulp washers goes into a weak black

liquor storage tank. The weak black liquor is sent to the multiple effect

evaporator (MEE) to evaporate water and concentrate the weak black liquor

in order to increase solids content. Typically, weak black liquor recovered

from the brown stock washers contains between 13 and 17 percent solids. 

The weak black liquor is then concentrated to 60-80 percent solids, which is

required for efficient combustion in the recovery boiler. An MEE will

include four to seven effects, or bodies, arranged in series. At pulp mills

using soft wood, a tall oil recovery system is generally incorporated into the

evaporator system to recover tall oil from the black liquor. Tall oil is sold

for use in manufacturing cosmetics.

Oxygen delignification system

Some mills that produce bleached pulp may also have an oxygen

delignification stage either in the pulping area or as a prebleaching stage. 

The oxygen delignification process reduces the lignin content without

reducing pulp strength or yield. High efficiency oxygen delignification

minimizes the amount of bleaching chemicals needed to achieve adequate

pulp brightness.
Chapter 2 - Pulping and

Bleaching Processes

22

There are currently two types of oxygen delignification systems available: 

high consistency and medium consistency. Medium consistency systems

are more popular due to safer operation and lower capital costs. Design and

placement of these systems vary from mill to mill. Oxygen delignification

systems of the two-stage design are most often employed in the U.S. for

new installations. Figure 8 shows a typical oxygen delignification system.

Gas collection systems

Gas collection systems, or noncondensible gas (NCG) systems, are used to 

collect gases from the various pulping processes and transport them to an

appropriate air pollution control device. There are two basic categories of

NCGs: low volume, high concentration (LVHC); and high volume, low

concentration (HVLC).

Low volume, high concentration (LVHC) systems typically collect gases

from the following systems:

 digester system

 turpentine recovery system

 evaporator system

 steam stripper system

 any other system serving one of these functions

High volume, low concentration (HVLC) systems typically collect gases

from the following systems:

 knotter system

 pulp washing system

 screen system

 oxygen delignification system

 weak liquor storage tanks

 any other equipment serving one of these functions
23

Mixer

Oxygen

Tower

Washer

Filtrate

tank

Pulp from

Screen and 

Decker System

Figure 8.

Typical Oxygen Delignification System (Medium Consistency)
Chapter 2 - Pulping and

Bleaching Processes

24

Historically, most

LVHC gases have

been controlled,

while a smaller

portion of the

HVLC gases have

been controlled.

Steam stripper

systems were

historically

installed to control

TRS odor.

A number of mills use a dedicated incinerator to control NCG emissions,

but most mills use process combustion sources such as the lime kiln, power

boilers, or a recovery boiler.

Condensate stripping

The pulping process equipment may include a steam stripper system to

remove organics and total reduced sulfur (TRS) compounds from various

liquid process condensate streams. Steam stripping is a multistage

distillation separation process that uses direct steam as the heat source. The

pulping process condensate streams most often stripped are the turpentine

decanter underflow, blow steam condensates, and certain evaporator

condensates. The stripped condensates may then be used as hot process

water.

Kraft pulping process condensates originate from the following systems:

 digester system

 turpentine recovery system

 evaporator system
Chapter 2 - Pulping and

Bleaching Processes

25

Each bleaching

stage performs

three functions:

 mixing of pulp

 and bleaching

 chemicals

 reaction of

 bleaching

 chemicals with

 the pulp

 washing the

 chemicals out of

 the pulp

2.3 What is bleaching?

Bleaching brightens the pulp in a series of chemical operations that are

together called a bleaching line. A bleaching line typically consists of a

sequence of three to six bleaching stages. The number of stages varies

depending on the brightness requirements of the pulp and the specific

design of the mill. Typically, the stages are sequenced as an alternating

series of bleaching and extraction stages. In a bleaching stage, the pulp is

treated with chemical bleaching agents. In an extraction stage, chemicals

(usually sodium hydroxide) are added to neutralize the chemical reactions

and the acidity of the pulp prior to the next bleaching stage. An extraction

stage is not required in all cases.

Each bleaching stage consists of three steps: mixing of pulp and bleaching

chemical (and in some cases steam); reaction of the chemical with the pulp

in a retention tower; and washing the chemical out of the pulp. Thus, the

equipment considered part of a stage includes chemical and steam mixers,

retention (bleaching or extraction) towers, and the washers and their

associated seal (filtrate) tanks and/or vacuum pumps.

Figure 9 depicts the major equipment found in a typical three-stage

bleaching plant. The function of these equipment systems and a brief

description follow. 
26

Chlorinated bleaching stage vent gases

to scrubber

Pulp flow

Water/filtrate flow

Gas stream

M Mixer

Pulp from

Pulping 

System

Bleaching

Tower

Washer

Extraction

Tower

Washer

Sealtank

Sealtank

Bleaching

Tower

M

M M

Extraction

chemicals

Bleaching

chemicals

Bleaching

chemicals

Figure 9.

Example Bleaching Line
Chapter 2 - Pulping and

Bleaching Processes

27

Bleaching stage

means all process

equipment

associated with a

discrete step of a

chemical

application and

removal in the

bleaching process.

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 chemicals

Almost any oxidant could be used as a bleaching agent. However, for

bleaching pulp, the chemical must be both powerful and inexpensive to

produce or purchase. There are a variety of chemicals that meet these

criteria. Both chlorinated and non-chlorinated chemicals are used for

bleaching. The chemicals and their common bleaching stage abbreviations

are shown below. These bleaching chemicals are grouped into two

categories: chlorinated and non-chlorinated. 

Chemicals Abbreviation

Chlorinated Bleach Chemicals

Elemental chlorine C

Hypochlorite H

Chlorine dioxide D

Chlorine with chlorine dioxide

substitution

(CD), (C+D)

Non-chlorinated Bleach Chemicals

Oxygen O

Peroxide P

Ozone Z

Chlorinated bleaching chemicals. There are three chlorinated chemicals

commonly used for bleaching pulp: elemental chlorine (C), chlorine

dioxide (D), and hypochlorite (H). Since elemental chlorine is a good

delignifying agent, it performs best when used in the first bleaching stage. 

Non-chlorinated bleach chemicals. Common examples of non-chlorinated

bleaching chemicals include: oxygen (O); peroxide (P); and ozone (Z). 

Bleach stages that use various combinations of alkali, oxygen, and peroxide

are common in many bleach plants.
Chapter 2 - Pulping and

Bleaching Processes

28

The NESHAP

requires collection

and control of HAP

emissions from the

chlorinated

bleaching stages

only!

Bleaching mixers

Bleaching chemicals must be thoroughly mixed with the pulp to ensure pulp

quality, to minimize chemical waste, and to minimize the generation of

bleaching contaminants such as chlorinated dioxins and furans. Enclosed

rotary high-shear mixers or static in-the-pipe mixers are used to mix the

pulp and bleaching chemicals.

Bleaching retention towers

Retention towers are used to maintain bleaching conditions for the pulp as it

passes through each bleaching stage. For complete bleaching chemical

reaction, it is necessary to maintain a certain temperature, time, consistency,

pressure, and pH for each bleach stage. Conditions vary with the bleaching

chemical used (e.g., chlorine, chlorine dioxide, hydrogen peroxide). In

many bleaching systems, the retention towers are named by the bleach

chemical used or the function of that particular bleaching stage

(e.g., chlorination tower).

There are two primary types of retention towers: the upflow tower; and the

downflow tower. The choice of tower design depends on the particular

conditions desired for the bleach stage. As a general rule, chlorinated

bleaching stages use an upflow tower design or a similar design. See

diagram number 29 in Appendix E.

Bleached pulp washers

To minimize chemical usage and equipment corrosion, it is important to

remove as much bleaching chemical as possible from the pulp before it

enters the next bleaching stage. Bleached pulp washing is performed in the

same type of equipment that washes the brown stock. See discussion on

brown stock washers on page 19. 

More detailed diagrams on the air and water discharges of each system are

provided in Appendix E.
Chapter 2 - Pulping and

Bleaching Processes

29

What is pulp preparation and papermaking?

The final stages at a pulp and paper mill include the preparation of pulp for

papermaking and the actual papermaking process. In the pulp preparation

area, the pulp fibers are cleaned to remove unwanted particles (such as dirt

and sand) from the pulp stock. The cleaned fibers will then undergo some

level of refining. In the refining process, the pulp fibers are subjected to

mechanical action to develop their optimal papermaking properties with

respect to the product being made.

In the papermaking process, the pulp stock is converted into paper. This

process begins when the pulp stock is distributed across the forming table. 

On the forming table, the paper sheet formation starts as the excess water

contained in the pulp stock drains from the pulp fibers. The newly formed

paper sheet is removed from the forming table and is conveyed through a

series of presses to remove additional water and to continue the sheet

forming process. The remaining water contained in the paper sheet is

removed as the sheet travels around a series of steam-heated cylinders. 

After the paper sheet leaves the dryers, it may undergo several other

processes, depending on the final paper product. These additional processes

include; calendering (where the sheet is pressed to reduce thickness and

smooth the surface), winding (where the sheet is wound onto a reel), and

coating (where various chemical or dyes are applied to the paper sheet).
Chapter 2 - Pulping and

Bleaching Processes

30

The soda pulping

process was the first

chemical pulping

method and was the

precursor to the kraft

pulping process.

2.4 Soda mills

The soda pulping process utilizes an alkaline liquor with sodium hydroxide

as the only active chemical. Except for the difference in chemicals used,

this process is the same as that described for the kraft mill.
Chapter 2 - Pulping and

Bleaching Processes

31

The sulfite pulping

process uses acid

solutions of sulfurous

acid (H2SO3) and

bisulfite ions (HSO3

-

).

2.5 Sulfite mills

The sulfite pulping process uses an acid solution of sulfurous acid (H2SO3)

and bisulfite ion (HSO3

-

 ) to break the lignin bonds between wood fibers,

while kraft mills use an alkaline solution. Because the sulfite cooking

process is an oxidizing reaction, sulfur dioxide is generated instead of the

reduced sulfur compounds generated by the kraft process (a reducing

reaction). Thus, the chemical recovery processes at sulfite mills are

different than at kraft mills. Otherwise, the process is similar to the kraft

process.

Sulfite pulp has less color than kraft pulp and can be more easily bleached,

although the sulfite pulp is not as strong as kraft pulp. Figure 10 depicts an

overview of a typical sulfite pulping system. 
32

Figure 10.

Example Sulfite Pulping System
Chapter 2 - Pulping and

Bleaching Processes

33

Semi-chemical pulp is

generally not

bleached.

2.6 Semi-chemical mills

Semi-chemical pulping involves partial digestion of wood chips in a weak

chemical solution such as sodium sulfite (Na2SO3) and sodium carbonate 

(Na2CO3) followed by mechanical refining for fiber separation. Semichemical pulp is very stiff, making this process common in corrugated

container manufacture. Figure 11 shows an overview of a typical semichemical pulping system.
34

Figure 11.

Example Semi-chemical Pulping System
Chapter 2 - Pulping and

Bleaching Processes

35

Bleaching systems

that use chlorine or

chlorine dioxide are

the only emission

sources at

mechanical,

secondary fiber, and

non-wood fiber mills

affected by the pulp

and paper NESHAP.

Secondary fiber

mills make pulp

from recycled

paper and other

products.

2.7 Mechanical, secondary fiber, and non-wood fiber

pulp mills

Mechanical pulping

Mechanical pulping uses physical pressure instead of chemicals to separate

wood fibers. Mechanical pulping processes have the advantage of

converting up to 95 percent of the dry weight of the fiber source into pulp,

but require an enormous amount of energy relative to chemical pulping. 

Mechanically produced pulp is of lower strength than chemically produced

pulp and is used principally for newsprint and other non-permanent paper

goods.

Mechanical pulps are brightened with hydrogen peroxide (H2O2) and/or

sodium sulfite (Na2SO3). The brightening chemicals are applied during the

pulp processing stage (e.g., in-line brightening), or in chemical application

towers. These chemicals only brighten the pulp and do not permanently

bleach the pulp. Typically, bleaching of mechanical pulps using chlorine or

chlorine dioxide is not practiced because of the high cost of bleaching

chemicals and negative impact on pulp yield.

Secondary fiber pulping

Secondary fibers include any fibrous material that has undergone a

manufacturing process and is being recycled as the raw material for another

manufactured product. Secondary fibers have less strength and bonding

potential than virgin fibers. The fibrous material is dropped into a large

tank, or pulper, and mixed by a rotor. The pulper may contain either hot

water or pulping chemicals to promote dissolution of the paper matrix. 

Debris and impurities are removed by “raggers”(wires that are circulated in

the secondary fiber slurry so that debris accumulates on the wire) and

“junkers” (bucket elevators that collect heavy debris pulled to the side of the

pulper by centrifugal force).
Chapter 2 - Pulping and

Bleaching Processes

36

The NESHAP does

not apply to mills

that rewater

purchased pulp

(e.g., dried bales or

sheets of pulp

being made into a

slurry).

Non-wood fiber pulping

Non-wood pulping is the production of pulp from fiber sources other than

trees. Non-wood fibers used for papermaking include straws and grasses

(e.g., flax, rice), bagasse (sugar cane), hemp, linen, ramie, kenaf, cotton, and

leaf fibers. Pulping of these fibers may be performed by mechanical means

at high temperatures or using a modified kraft or soda process. Non-wood

fiber pulp production is not common in the U.S.
Chapter 2 - Pulping and

Bleaching Processes

37

2.8 References for Chapter 2

Biermann, C.J. 1993. Essentials of Pulping and Papermaking. San Diego,

CA: Academic Press, Inc.

Burgess, T. 1995. The Basics of Foul Condensate Stripping. 1995 Kraft

Recovery Short Course. Atlanta, GA: TAPPI PRESS.

EPA. 1995. Office of Compliance Sector Notebook Project: Profile of the

Pulp and Paper Industry. EPA/310-R-95-015. Office of Enforcement and

Compliance Assurance, Washington, DC. 

EPA. 1993. Pulp, Paper, Paperboard Industry - Background Information

for Proposed Air Emissions Standards for Manufacturing Processes at Kraft,

Sulfite, Soda, and Semi-chemical Mills. EPA-453/R-93-050a. Office of

Air Quality Planning and Standards, Research Triangle Park, NC.

Mimms, A., Kocurek, M., Pyatte, J., and Wright, E., eds. 1993. Kraft

Pulping. Atlanta, GA: TAPPI PRESS. 

Smook, G.A. 1992. Handbook for Pulp and Paper Technologists. Second

Edition. Bellingham, WA: Angus Wilde Publications.
38

A copy of the

April 15, 1998

NESHAP is in

Appendix B. Refer

to the ATW for

correction notices

and amendments.

The NESHAP does

NOT apply to

paper mills unless

they also produce

pulp.

Find a list of HAPs

at http://www.epa.

gov/ttn/atw/

pollsour.html

Chapter 3 - Overview of the Pulp and Paper

NESHAP

3.1 Which mills are subject to the NESHAP?

The pulp and paper NESHAP applies to existing and new major sources that

produce pulp, paper, or paperboard, and use any of these pulping processes:

 kraft using wood

 soda using wood

 sulfite using wood

 semi-chemical using wood

 mechanical using wood

 processes using secondary fibers or non-wood fibers

A major source is any mill that emits or has the potential to emit

(considering Federally enforceable controls) 10 tons per year (tpy) or more

of any HAP or 25 tpy or more of any combination of HAPs.
Chapter 3 - Overview of

NESHAP

39

General

Requirements of the

NESHAP:

 vent control on

 pulping systems

 treatment of

 condensates from

 kraft pulping

 systems only

 vent control on

 bleaching systems

 elimination of

 certain bleaching

 chemicals

 no control of

 papermaking

 systems

3.2 What processes and equipment systems must be

controlled?

The NESHAP has separate emission limits for pulping system vents,

pulping process condensate streams, and bleaching systems. The

applicability of these standards varies depending on the type of mill.

If the Mill is

This Type...

Then the NESHAP Covers These Processes...

Pulping

System Vents

Pulping

Condensates

Bleaching Systems

That Use the

Following

Compounds

Kraft X X Chlorine or any

chlorinated compound

Sulfite X Chlorine or any

chlorinated compound

Semi-chemical X Chlorine or any

chlorinated compound

Soda X Chlorine or any

chlorinated compound

Mechanical Chlorine or chlorine

dioxide

Secondary Fiber Chlorine or chlorine

dioxide

Non-Wood Fiber Chlorine or chlorine

dioxide
Chapter 3 - Overview of

NESHAP

40

For purposes of

this NESHAP,

LVHC systems are:

 digester

 system

 turpentine

 recovery

system

 evaporator

 system

 steam stripper

 system

 any other

 system serving

 one of these

 functions

Systems that are

not regulated:

 wood yards

 pulping systems

 at mechanical,

 non-wood, and

 secondary fiber

 pulp mills

 tall oil recovery

 systems

 causticizing

 systems

 papermaking

 systems

In addition, the specific pulping process vents covered by the standards vary

depending on the type of mill and the classification of the pulping system as

a new or existing source. See Figure 12. The applicability and control

requirements of each type of mill are explained in detail in Chapters 4

through 7.

Figure 12.

Equipment Systems Covered by the

Pulping Vent Standards

If the

Mill is

This

Type...

Then These Equipment Systemsa

 are

Covered at Existing Sources...

And These Equipment

Systems are Covered at

New Sourcesb

...

Kraft  LVHC systems

 Pulp washing system

 Oxygen delignification system

 Decker systems that use any process water

 other than fresh water or paper machine

 white water or any process water with

 total HAPs concentration > 400 ppmw

 Knotter systems with HAP emissions

 greater than 0.05 kg/Mg oven-dried pulp

 Screen systems with HAP emissions

 greater than 0.1 kg/Mg oven-dried pulp

 Combined knotter and screen systems

with

 HAP emissions greater than 0.15 kg/Mg

 oven-dried pulp

Same as existing sources

plus all...

  Decker systems

  Screen systems

  Knotter systems

  Weak liquor storage

 tanks

Soda LVHC systems Same as existing sources

plus all...

  Pulp washing systems

Sulfite  Digester system

 Evaporator system

 Pulp washing systems

Same as existing sources

plus all...

  Weak liquor storage

 tanks

  Strong liquor storage

 tanks

  Acid condensate storage

 tanks

SemichemicalLVHC systems Same as existing sources

plus all...

  Pulp washing systems

a

 See Appendix F for a list of specific equipment within each system. b

 See page 49 for the definition of a new source.
Chapter 3 - Overview of

NESHAP

41

The NESHAP has

one alternative

emission limit for

pulping system

vents, pulping

condensates, and

bleaching systems

that does not

require testing and

monitoring.

3.3 What are the emission control requirements?

The NESHAP provides several alternative emission limits for the pulping

vent standard, pulping condensates standard, and bleaching system standard. 

For each regulated emission point, a mill can choose the emission limit with

which to comply and can use any emission control technology to achieve

compliance.

The format (e.g., percent reduction or outlet concentration) of the alternative

emission limits varies depending on the type of mill (Figure 13). For ease

of explanation, Figure 13 provides only the formats of the alternative limits,

since the actual emission limits vary depending on the type of mill. The 

emission limits for each type of mill are presented in Chapters 4 through 7

and are summarized in Appendix G.

Where two or more pulping processes share a piece of equipment, that piece

of equipment is considered a part of the pulping process type with the more

stringent NESHAP requirements for that piece of equipment.
Chapter 3 - Overview of

NESHAP

42

Figure 13.

Alternative Emission Limits

For the Following

Standards...

The Regulated

Pollutant is...

And a Mill Can Choose One of the

Following Emission Limitsa

...

Pulping system vents

  Kraft

  Soda

  Semi-chemical

Total HAPs  Percent reduction

 Outlet concentration (parts per million by

volume) for thermal oxidizer

 Design specification for thermal oxidizer

 Duct vents to a boiler, recovery furnace,

or lime kilnb

Pulping system vents

  Sulfite

Total HAPs  Percent reductionc

 Mass emission limit (lb/ton oven-dried

pulp)c

Pulping system

condensates

  Kraft

Total HAPs  Recycling to equipment subject to pulping

standards

 Percent reduction (HAP mass in the

condensates)

 Mass removal (lb/ton oven-dried pulp)

 Outlet concentration (parts per million by

weight) (option not available for

biological treatment systems)

Bleaching system

  Kraft

  Soda

  Sulfite

Chlorinated HAPs (other

than chloroform)

 Percent reduction

 Outlet concentration (ppmv) from the

treatment device

 Mass emission limit (lb/ton oven-dried

pulp)d

 Eliminate use of chlorinated compounds

Chloroform  Eliminate use of hypochlorite and

chlorine

 Effluent (water) limitations

a Emission limits vary for different types of pulping systems and control devices. A mill will likely use several

closed-vent systems and each one can comply with any of these alternative emission limits. b The vent stream must be introduced with the primary fuel or into the flame zone. For boilers and recovery 

furnaces with heat input capacities of 150 MMBtu/hr of more, the vent stream can be introduced with the

combustion air. c Percent reduction and mass emission limits apply to sulfite pulping system vents, and any emissions from vents,

wastewater, and condensate streams from the control device. d Mass emission limit applies to total emission from all regulated bleaching stages in the bleaching system.
Chapter 3 - Overview of

NESHAP

43

3.4 What control systems will mills typically use to

meet the emission limits?

The control systems that most mills are likely to use to meet the emission

limits shown in Figure 13 are listed below:

 Pulping system vents

- thermal oxidizers

- power boilers, lime kilns, recovery furnaces

 Pulping process condensates

- steam strippers

- biological treatment

- recycling to pulping equipment that is controlled by

the NESHAP

 Bleaching system vents

- caustic scrubbers (for chlorinated HAPs, other than

chloroform)

- process modifications to eliminate the use of chlorine

and hypochlorite
Chapter 3 - Overview of

NESHAP

44

Figure 14 explains

in general how

mills must

demonstrate

compliance with

the NESHAP.

Administrator

means an

authorized

representative of

the EPA (e.g., a

State that has been

delegated the

authority to

implement and

enforce this

NESHAP).

3.5 How do mills demonstrate initial and continuous

compliance?

In general, mills must conduct an initial performance test and then

continuously monitor a set of control device or process operating

parameters. Exceeding a monitoring parameter will constitute a violation of

the standard.

Initial performance test. A performance test is required for most sources

regulated by this NESHAP. The performance test serves two purposes:

(1) To demonstrate that the control device complies with the

emission limit (Figure 14 explains the pollutants that must be

measured and the allowable surrogates that a mill may

choose to measure as an alternative)

(2) To establish the process operating parameter values (e.g., fire

box temperature for thermal oxidizers) that must be

monitored to demonstrate continuous compliance with the

standard

The NESHAP specifies the required monitoring parameters for most control

devices. If a mill uses a control device for which the monitoring parameters

are not specified, then the mill must propose and demonstrate, to the

satisfaction of the Administrator, a set of monitoring parameters that can

prove continuous compliance with the NESHAP. During the performance

test, mills must test simultaneously for emissions and monitor the

appropriate operating parameters to establish the parameter values (e.g., the

specific fire box temperature) that constitute continuous compliance.
Chapter 3 - Overview of

NESHAP

45

The NESHAP

generally requires

continuous

monitoring of

operating

parameters (not

emissions) to

demonstrate

compliance.

Continuous monitoring. Continuous monitoring is used to demonstrate

that a mill is in compliance with the NESHAP at all times. Mills must

continuously monitor operating parameters and report all instances where

the values deviate from the maximum or minimum values established

during the initial performance test. As an alternative, mills may install a

continuous emissions monitor.

Recordkeeping and reporting requirements. Mills must comply with the

recordkeeping and reporting requirements of the NESHAP General

Provisions (40 CFR 63) and those of the pulp and paper NESHAP. These

requirements include initial notifications, retaining records of performance

tests and monitoring data, and periodic reporting of periods of excess

emissions. Table 1 of Appendix B identifies which sections of the General

Provision requirements apply and which are overridden by this NESHAP.

In addition, the pulp and paper NESHAP requires some mills to submit a

control strategy report. The control strategy report must be submitted with

the initial notification (by April 15, 1999) and updated every 2 years until

compliance is achieved. The report must include the following:

 description of emission controls or process modifications

selected for compliance

 compliance schedule

 a report on the progress of installing the emission controls or

process modifications during the past 2-year period.

The control strategy report is required only if a mill uses one of the

following strategies that provide either additional compliance time or

compliance flexibility:

 Bleaching systems that comply with the Voluntary

Technology Advanced Incentives Program (see page 70)

 HVLC system vents that comply after April 16, 2001

 HVLC system vents that comply with the Clean Condensate

Alternative (see page 75)
Chapter 3 - Overview of

NESHAP

46

Figure 14.

What Pollutants or Surrogates Must Be Measured?

If These Systems are

Covered by the

NESHAP...

Then the

Regulated

Pollutant is...

And a

Performance

Test is

Required at this

Frequencya

...

And a Mill May

Choose to Testb

for this

Surrogate

Pollutant...

And These

Parameters

Must be

Continuously

Monitored

Pulping Total HAPs Initially Methanol Operating

parameters or

methanol outlet

concentration

Bleaching Chlorinated

HAPs (excluding

chloroform)

Initially Chlorine Operating

parameters or

chlorine outlet

concentration

Chloroform Nonec -- Nonec

Condensates

Biological

treatment

Total HAPs

(in condensates)

Quarterlyd Methanold Operating

parameters

(daily)

Steam stripping Total HAPs

(in condensates)

Initially Methanol Operating

parameters or

methanol outlet

concentration a The U.S. EPA or the delegated authority may require an owner or operator to conduct performance tests at the

affected facility at any other time when the action is authorized under Section 114 of the CAA (40 CFR

subsection 63.7(a)(3)). b Compliance tests are conducted using the following methods:

Compound(s) Test method

Total HAPs; methanol M308

Chlorinated HAPs Any method approved by the Administrator

Chlorine M26A

Total HAPs; methanol in

 condensates M305

Methanol in condensates NCASI GC/FIDe

c A mill can comply by eliminating the use of chlorine and hypochlorite or by complying with the numerical limits

of the effluent limitations guidelines and standards for water in 40 CFR 430. d The initial performance test and annual 1st quarter tests must be performed for acetaldehyde, methanol, methyl

ethyl ketone, and propionaldehyde. However, if the ratio between the four HAPs and methanol is established in

the 1st quarter, methanol can be used as a surrogate for total HAPs in the 2nd, 3rd, and 4th quarter tests instead

of performing the tests for the four HAPs.

e The National Council of the Paper Industry for Air and Stream Improvement (NCASI) direct injection gas

chromatography/flame ionization (GC/FID) method may be used as an alternative to EPA Method 305.
Chapter 3 - Overview of

NESHAP

47

For purposes of

this NESHAP,

HVLC systems are:

 knotter system

 pulp washing

 system

 screen system

 oxygen

 delignification

 system

 weak liquor

 storage tanks

3.6 When must mills comply?

The major compliance milestones for affected sources are shown below. 

This information presents only a portion of the requirements faced by

owners and operators of pulp and paper mills. Appendix H provides the

detailed milestone compliance timeline for existing sources.

Affected Sources Must Comply by April 16, 2001...

Except for the Following... Which Must Comply...

New sources At startup or by June 15, 1998,

whichever is later

HVLC system vents at kraft millsa Within 8 years (April 17, 2006)

Dissolving grade bleaching systems

at kraft or sulfite pulping millsb Within 3 years of publication of therevised effluent limitations

guidelines and standards

Bleaching system at any mill

choosing to implement the

Voluntary Advanced Technology

Incentives Programc

 for effluent

limitations guidelines and

standards

Within 6 years (April 15, 2004)

a

 LVHC systems must still meet the April 16, 2001 compliance date (see page 55). b

 Dissolving grade bleaching systems are similar to bleaching systems at bleached kraft

 or sulfite mills, but usually contain six to eight bleach stages for maximum delignification

 and pulp cleanliness. The April 15, 1998 Cluster Rules did not publish effluent

 limitations guidelines and standards for these subcategories. Development of these

 revised rules is underway.

c

 Refer to page 70.

Also, by April 15, 1999, the following is due:

 Initial notification

 Initial control strategy report
Chapter 3 - Overview of

NESHAP

48

For new sources,

the emission limits

are the same as

existing sources.

See page 49 for the

definition of a new

source.

3.7 What additional requirements apply to new

sources?

New sources at pulp and paper mills have more stringent compliance

requirements than existing sources. These include:

 More emission points must be controlled. For pulping

systems, the emission limits (see Figure 12) for new and

existing processes are the same, but more emission points

must be controlled at new sources. For bleaching systems

and pulping condensates, the emission limits and emission

points that must be controlled for new and existing sources

are identical.

 Earlier compliance dates. New sources must comply at the

date of startup or on June 15, 1998, whichever is later.

 Preconstruction approval. The owner or operator of mills

subject to the pulp and paper NESHAP must submit an

application to EPA for approval to construct any new source

that is subject to this rule. The preconstruction approval

process applies only if two conditions are met: 

- if the construction or reconstruction is a “new source”

as defined in Section 3.8 

- the new or reconstructed source in and of itself is a

major source 

Construction must not commence until the EPA Administrator

approves the application. The EPA Administrator will approve the

application after determining that the source, if properly constructed,

will not cause a violation of the NESHAP. The requirements for the

submission and approval of construction applications are contained

in 40 CFR 63.5 (e) and (f).
Chapter 3 - Overview of

NESHAP

49

The definition of a

new source is

different under the

Clean Water Act. 

See 40 CFR 122.2

and

40 CFR 430.01(j)

for the definition of

a new source for

effluent limitations

guidelines and

standards, and

pretreatment

standards.

Upon

reconstruction, an

existing source

immediately

becomes subject to

the new source

requirements!

3.8 What is a new source?

What constitutes a new or reconstructed source for each mill type that is

subject to this NESHAP is defined below.

A New

Source at a ... Using...

Is the Construction of Any

One of the Following...

Or the

Reconstructiona

 of

Any One of the

Following...

That

Commences

After...

Kraft mill,

Soda mill,

Semichemical mill,

or

Sulfite mill.

Wood  A new mill

 New pulping system

 New bleaching system

 Additional pulping line

 Additional bleaching line

 Pulping system

 Bleaching system

12/17/93

Mechanical

pulping mill

Wood  Bleaching system

 Bleaching line

Bleaching system 03/08/96

Other mills Secondary

or nonwood fibers

 Bleaching system

 Bleaching line

Bleaching system 03/08/96

a

 Reconstruction means replacement of components to the extent that 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. (40 CFR 63.2 Subpart A).

What is an “Additional Line?” An additional line means a line that adds

capacity to an existing pulping or bleaching system. For example, consider a

mill with two existing pulping lines. The construction of a third line would

constitute an additional line and would be subject to new source controls. On

the other hand, a like-kind replacement of one of the lines would not be

considered an additional line. However, the replacement of one of the lines

with a new line that increases the capacity of the pulping system would be

considered an additional line that is subject to the new source requirements.

What Does “Reconstruction” Mean? Reconstruction means the replacement

of components to the extent that 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. If this condition is met, upon construction, an

existing source immediately becomes subject to the MACT standards for new

sources irrespective of any change in emissions of HAPs. See 40 CFR 63.2

and 63.5.
Chapter 3 - Overview of

NESHAP

50

The pulp and paper NESHAP defines either the entire pulping system or

bleaching system as the equipment to which the 50 percent criterion is applied. 

For example, consider a mill that is refurbishing one of its two pulping lines by

replacing worn out equipment or components. To determine if reconstruction

occurs, the replacement costs would be compared to the construction costs for

replacing the entire pulping system (e.g., both lines). If the replacement cost is

less than 50 percent, the line is treated as an existing source. However, if the

cost exceeds 50 percent, then the replacement/construction project would be

deemed as a reconstruction of the pulping system, and both lines would

become subject to the new source provisions, even if emissions after the

reconstruction are the same or decrease.
51

Systems that are

not regulated:

 wood yards

 tall oil recovery

 systems

 causticizing

 systems

 papermaking

 systems

The CCA focuses

on reducing HAP

emissions

throughout the mill

by reducing the

HAP mass in

process water

streams that are

recycled to various

process areas in

the mill.

Chapter 4 - NESHAP Requirements for Kraft Mills

For kraft mills, the NESHAP contains emission standards for pulping system

vents, pulping process condensates, and bleaching system vents.

There are several alternative emission limits for each process covered. 

Compliance times will vary based on the process and emission limit selected,

even within the same mill. This designed flexibility promotes and encourages

new technologies, particularly joint air/water controls and pollution prevention

technologies.

The NESHAP also includes an option called the Clean Condensate Alternative

(CCA). The CCA applies only to kraft pulping system vent standards for the

HVLC system and features both pollution prevention and emission averaging. 

The CCA is described on page 75.

If You Need the Following Information... Then Read...

Standards for kraft pulping system vents Section 4.1

Standards for kraft pulping process condensates Section 4.2

Standards for kraft bleaching system vents Section 4.3

Description of the clean condensate alternative Section 4.4

Comparison of requirements for the NESHAP

and the NSPS

Section 4.5
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

52

For purposes of this

NESHAP, the LVHC

system includes all

vents from:

 digester system

 turpentine recovery

 system

 evaporator system

 steam stripper

 system

and

The HVLC system

includes all vents

from:

 pulp washing

 system

 knotter system

 screen system

 decker system

 oxygen

 delignification

 system

 weak liquor

storage

 tanks

The combined

knotter and screen

system limit applies

only if the mill is

unable to

differentiate

emissions between

the two systems.

4.1 Standards for kraft pulping system vents

The NESHAP requires the pulping system emission points to be enclosed,

collected in a closed-vent system, and then vented to a control device. This

section describes the emission points that must be controlled, the five

alternative emission limits, and the compliance requirements.

What kraft pulping system vents must be controlled?

The NESHAP specifies that vents from the mill systems must be controlled. 

All the vents from the LVHC system must be controlled. The HVLC vents

requiring control vary based on the quantity of emissions and whether the

source is new or existing. 

The Following Pulping Systems Must be Controlleda...

Existing Sources

 LVHC system

 Pulp washing system

 Oxygen delignification system

 Decker systems that use any process water other than fresh water or paper machine

white water, or process water with a concentration of HAPs greater than 400 parts

per million by weight (ppmw)

 Knotter systems with HAP emissions equal to or greater than 0.1 pounds per ton

oven-dried pulp

 Screen systems with HAP emissions equal to or greater than 0.2 pounds per ton

oven-dried pulp

 Combined knotter and screen systems with HAP emissions equal to or greater than

0.3 pounds per ton oven-dried pulp

New Sources

 Same as existing sources plus...

 All decker systems

 All screen systems

 All knotter systems

 All weak liquor storage tank vents

a Each equipment system has multiple emission points. For example, the evaporator system

comprises pre-evaporators, multi-effect evaporators, concentrators, vacuum systems,

associated condensers, hot wells, and condensate streams. A complete list of the emission

points in each equipment system is provided in Appendix F.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

53

These emission

limits apply to

each control

device.

A sixth alternative

is available for

kraft HVLC system

vents only. See

Section 4.4 for an

explanation of the

Clean Condensate

Alternative.

What are the emission limits for kraft pulping system vents?

The emissions from kraft pulping system vents must meet one of five

alternative emission limits, as shown below. These emission limits apply to

each control device used to control HAP emissions. A mill will likely use

several closed-vent systems and control devices (including both add-on control

devices and existing combustion devices) and each can comply with any of

these five alternative emission limits. These emission limits apply to both new

and existing sources.

Pulping System Vent Gases Must be Collected in a Closed-vent System

and Routed to One of These Five Control Devices...

1. A boiler, lime kiln, or recovery furnace in which the HAP gas stream

is introduced with the primary fuel or into the flame zone

2. A boiler, lime kiln, or recovery furnace with a heat input capacity of

at least 150 MMBtu/hr in which the HAP gas stream is introduced

with the combustion air.

3. A thermal oxidizer operated at a minimum temperature of 1,600°F

and a minimum residence time of 0.75 seconds

4. A thermal oxidizer that reduces the total HAP concentration at the

outlet to 20 ppmv corrected to 10% O2 on a dry basis, measured as

total HAPs or methanol

5. Any control device that reduces total HAP emissions by 98% by

weight, measured as total HAPs or methanol
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

54

A closed-vent

system means a

system that is not

open to the

atmosphere and

comprises piping,

ductwork,

connections, and if

necessary, flowinducing devices

that transport gas

or vapor from an

emission point to a

control device.

What does the NESHAP require for enclosures and closed-vent

systems?

All regulated equipment system vents must be enclosed and routed through a

closed-vent system to the control device that is selected for compliance. The

requirements for enclosures and closed-vent systems are presented below. The

requirements are intended to prevent leaks and ensure that process openings

(e.g., sampling ports on a brown stock washer enclosure) are closed while the

mill is in operation.

This Equipment.... Must Meet These Requirements....

Enclosures, openings, and hoods Maintain negative pressure

and

If closed during the initial

performance test, must be closed

during operation except for

sampling, inspection, maintenance,

or repairs

Components operated at positive

pressure

Operate with no detectable leaks

(500 parts per million by volume

[ppmv] VOC above background)

Bypass lines that could divert vent

stream containing HAPs to the

atmosphere

Seal and secure the opening so that

the valve or closure mechanism

cannot be opened without breaking

the seal

or

If computer controlled, monitor for

presence of gas stream flow at least

once every 15 minutes
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

55

Compliance Dates:

LVHC system:

 April 16, 2001

HVLC system:

 April 17, 2006

HVLC systems that

comply before

April 16, 2001 are

not required to

submit a

compliance

strategy report.

When must mills comply with the kraft pulping vent standards?

The LVHC system sources at kraft mills must comply with the NESHAP by

April 16, 2001, while the HVLC system sources must comply by

April 17, 2006.

For HVLC system vents complying after April 16, 2001, a non-binding

compliance strategy report must be submitted initially and updated every

2 years until compliance is achieved. The compliance strategy report must

contain, among other information, a description of the emission controls or

process modifications selected for compliance and a compliance schedule

indicating when each step toward compliance will be reached.

For safety purposes, kraft mills typically separate pulping vent streams into two

groups: low volume, high concentration (LVHC) vent streams and high

volume, low concentration (HVLC) vent streams. The NESHAP does not

specify which vents must be routed to the LVHC and HVLC collection

systems. Each mill makes this decision. However, compliance dates are based

on EPA’s definition of LVHC and HVLC system equipment, and these

compliance dates do not change based on how a mill chooses to collect their

system vents. For example, a mill could control an evaporator vent (LVHC

source) along with a group of HVLC vents. In such cases, the emissions from

this closed-vent system would have to comply by April 2001, because 2001 is

the compliance date specified for the LVHC system source.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

56

The test method

specified is used to

determine pollutant

concentration. 

Additional

calculations or

formulas are

specified in the

NESHAP to

convert the

concentration

values into the

appropriate format

to demonstrate

compliance with a

particular emission

limit.

How does a mill demonstrate initial compliance with the kraft

pulping system vent standards?

A mill must demonstrate compliance through an initial performance test for

each closed-vent system and control device. However, the rule contains three

alternative emissions limits for which an initial performance test of the control

device is not required. If a mill complies with the pulping system vent

standards by venting the gases to a boiler, lime kiln, or recovery furnace, the

mill must demonstrate only that the gases are being introduced with the

primary fuel or into the flame zone (or with the combustion air if the heat input

rate of the boiler, lime kiln, or recovery furnace is at least 150 MMBtu/hr). 

Also, if a mill complies with the pulping system vents standards by venting the

gases to a thermal oxidizer operating at the minimum design specifications, the

mill must demonstrate only that the gases are being properly introduced into

the thermal oxidizer.

The initial performance test has three objectives:

(1) To demonstrate that each control device complies with the emission

limit. Refer to Figure 15.

(2) To demonstrate that the closed-vent system captures and contains

all HAP emissions. Refer to Figure 16.

(3) To establish the process operating parameter values that must be

monitored to demonstrate continuous compliance. For example, the

test would establish the minimum fire box temperature of the thermal

oxidizer that indicates 98 percent by weight reduction of total HAPs.

Figure 15.

How Does a Mill Demonstrate Initial Compliance with

the Kraft Pulping System Vent Emission Limits?

To Demonstrate Initial

Compliance With This

Emission Limit...

Conduct an Initial

Performance Test Following

This Method...

To Measure These

Parameters...

Introduce HAP emission

stream with the primary fuel,

into the flame zone, or with

the combustion air

None required. Demonstrate

that gases are properly

introduced.

None required

Operate at a minimum

temperature of 1,600F and a

minimum residence time of

0.75 seconds

None required None required

Reduce the total HAP

concentration at the outlet to

 20 ppmv corrected to 10%

O2 on a dry basis

Method 308 Total HAP or methanol

concentration at the outlet of

the thermal oxidizer

Reduce total HAP emissions

by 98% by weight

Method 308 Total HAP or methanol mass

at the control device inlet and

outlet
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

57

Continuous

monitors are

required except for

vent streams that

are combusted in a

lime kiln, recovery

furnace, or boiler.

These same tests

are required as

part of the initial

performance test.

How does a mill demonstrate continuous compliance with the

kraft pulping system vent standards?

Mills must install a continuous monitoring system to measure either HAP

concentration or control device operating parameters. Figure 17 presents

the monitoring, reporting, and recordkeeping requirements for each

alternative emission limit.

In addition, a mill must periodically inspect and maintain all enclosures and

closed-vent systems. These requirements are explained in Figure 16. The

mill must maintain a site-specific inspection plan for the enclosures and

closed-vent system. Records of all inspection results and repairs must also

be kept according to the specifications of 40 CFR 63.454.

Figure 16.

How Does a Mill Demonstrate Initial and Continuous Compliance with

the Closed-Vent Systems Standard?

If the System has... Then Inspect... And Report...

And Keep

Records of...

Enclosure opening Visually inspect every 30

days to ensure closed and

sealed

Any exceedences of the

closed-vent standard in

quarterly reports. If no

exceedences occur, submit

semi-annual reports.

All visual checks and

any repairs

Annually demonstrate 

negative pressure

Same as above All pressure tests

Closed-vent system Visually inspect every 30

days for visible defects

Same as above All visual checks and

repairs

Positive pressure

closed-vent system

Annually demonstrate no

detectable leaks (less than

500 ppmv)

Same as above All leak tests

Bypass line valve Inspect every 30 days to

ensure valve is in a closed

position and vent stream is

not diverted through

bypass line

Same as above All visual checks and

repairs
58

Figure 17.

How Does a Mill Demonstrate Continuous Compliance with the Kraft Pulpin

System Vent Emission Limits?

If a Mill Chooses This

Alternative Emission

Limit...

Then Continuously Monitor These

Parameters... And Report This Information... And Keep T

Introduce HAP emissionstream with the primaryfuel, into the flame zone,or with the combustionair

None required None required None required

Operate at a minimumtemperature of 1,600°Fand a minimumresidence time of 0.75seconds

Fire box temperature  Certify in the performance test report that

the minimum residence time is achieved

 Semi-annual emissions and continuous

monitoring performance report

 If exceedences occur, then quarterly

reports are required (40 CFR 63.10(e))

Fire box tempe

Reduce the total HAPa

concentration at theoutlet to 20 ppmv

corrected to 10% O2 on

a dry basis

Fire box temperature

or

 Semi-annual emissions and continuous

monitoring performance report

 If exceedences occur, then quarterly

reports are required (40 CFR 63.10(e))

Fire box tempe

Total HAP concentrationa Same as above Total HAP con

Reduce total HAPaemissions by 98% byweight

When using a thermal oxidizer, monitor fire box temperature

Same as above Fire box tempe

When using a control device other thana thermal oxidizer or incineration,operating parameters must beestablished during the initialperformance test and approved by theAdministratorb

Same as above Parameters ap

a Methanol may be used as a surrogate for total HAPs. bAdministrator means an authorized representative of the EPA (e.g., a State that has been delegated the authority to implement and enf

 NESHAP).
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping System Vents

59

The NESHAP does

not specify rigid

averaging times,

but rather allows

State permitting

authorities

flexibility in

establishing millspecific times. 

Check the ATW

periodically for 

additional

information

concerning

averaging times.

Control device down time

Total process operating time

× 100%

25 hours

4,250 hours

× 100%  0.59%

Must a mill comply at all times?

For pulping system vents, the NESHAP establishes an allowable percent of

operating time during which HAP emission levels in excess of the

established limit shall not be considered to be a violation of the standard. 

Periods of excess emissions include when the control device is inoperable

and when the operating parameter values established during the initial

performance test cannot be maintained at the appropriate level. The

allowance is in addition to excused periods under the startup, shutdown or

malfunction provisions, and is calculated by dividing the time of excess

emissions by the total process operating time in a semi-annual reporting

period.

The excess emissions allowances are:

 1 percent of operating time for control devices used for

LVHC system vents

 4 percent of operating time for control devices used for

HVLC system vents

 4 percent of operating time for control devices used for

combined LVHC and HVLC system vents (i.e., controlled by

the same device)

Even though periods of excess HAP emissions may be exempt under the

MACT requirements, these periods of excess emissions must still comply

with NSPS total reduced sulfur (TRS) requirements, and any applicable

State requirements.

To calculate the percent of periods of excess emissions in a semi-annual

period, divide the number of hours in the reporting period during which the

control device was not operating or parameter deviations occurred by the

total number of process operating hours and multiply by 100 percent. For

example, to calculate the semi-annual excess emissions for an LVHC

system control device where the device down time was 25 hours and the

total process operating time was 4,250 hours:
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

60

The condensate

streams subject to

control and the

alternative emission

limits are the same

for new and existing

sources.

Liquid streams

intended for

byproduct recovery,

such as the combined

turpentine/water

streams prior to the

turpentine decanter

or concentrated black

liquor, are not

considered process

condensate streams

subject to the control

requirements of this

regulation.

4.2 Standards for kraft pulping process condensates

The NESHAP requires condensate streams from the pulping system to be

collected in a closed collection system and treated. The NESHAP provides

five alternative emission limits (shown on page 61). This section describes

the condensates that must be controlled and the alternative emission limits.

What is a condensate and why control it?

Kraft pulping condensates are HAP-containing liquids that are condensed

from pulping system vent streams. These HAP-containing liquids result

from the contact of water with organic compounds in the pulping process. 

In absence of this rule, most condensates would be discharged into open

collection systems and transported to either the wastewater treatment plant

or a publicly owned wastewater treatment plant. The emissions of concern

are the HAPs that volatilize as the condensates travel through these open

systems.

What kraft pulping condensates must be controlled?

The NESHAP requires control of condensates from all of the equipment in

the following systems:

 digester system

 turpentine recovery system

 evaporator system (condensates from weak liquor feed stage

vapors and vacuum systems only).

 LVHC collection system

 HVLC collection system

The LVHC and HVLC collection system condensates means those

condensates generated by the condensation of moisture in the closed-vent

collection systems that convey the LVHC and HVLC system vent gases to a

control device.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

61

By segregating

condensate streams

containing the

greatest amount of

HAP and treating

only these streams, an

equivalent emission

reduction can be

achieved at a lower

cost.

Most mills are

expected to use

steam stripping for

alternative

emission limits 4

and 5.

Does the mill have to collect all those streams?

No. A mill may choose to collect and control all the condensate streams

from the equipment systems listed on page 60. Alternatively, the NESHAP

contains two options for minimizing the volume of condensate that must be

treated (referred to as volume reduction options). These options are

summarized below.

A Mill Must Collect and Control One of the Following

Combinations of Streams...

 All condensate streams

 Volume reduction option 1: Treat all LVHC and HVLC collection system

streams plus streams that contain 65% of the total HAP mass from the digester

system, turpentine recovery system, and evaporator system (only condensates

from weak liquor feed stage vapors and vacuum systems)

 Volume reduction option 2: Treat any subset of the regulated streams that

contain in total 7.2 lbs HAP per ton of oven-dried pulp at mills that do not

perform bleaching or 11.1 lbs HAP per ton of oven-dried pulp at mills that

perform bleaching

What are the control requirements?

The NESHAP provides five alternative emission limits for condensate

streams as shown below. The three strategies expected to be used by most

mills are: recycling, biological treatment, and steam stripping.

Kraft Pulping Process Condensates Must be Collected in a Closed-collection

System and Treated to Meet One of These Five Alternative Emission Limits...

1. Recycle the condensate to a piece of equipment that meets the control

standards for pulping system vents (see page 53)

2. Use a biological treatment system to reduce or destroy the total HAPsa

 to meet

the emission limits in alternatives 3 or 4

3. Treat the condensates to reduce or destroy the total HAPsb

 by 92% by weight

4. Treat the condensates to remove 10.2 pounds HAPsb

 per ton of oven-dried

pulp at mills performing bleaching or 6.6 pounds HAPsb

 per ton of oven-dried

pulp at mills that do not perform bleaching

5. Treat the condensates to achieve a total HAPb

 concentration of 330 ppmw at

the outlet of the control device at mills that perform bleaching or 210 ppmw

at the outlet of the control device at mills that do not perform bleaching a

 Measured acetaldehyde, methanol, methyl ethyl ketone, propionaldehyde b

 Measured as either the sum of acetaldehyde, methanol, methyl ethyl ketone, and

 propionaldehyde, or as methanol.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

62

The condensate

tank requirement

applies only to

tanks used to store

or handle the

regulated

condensates, not

tanks used to store

weak liquor.

What does the NESHAP require for condensate closed

collection systems?

Regardless of the emission limit selected, the condensates subject to control

must be transported in a closed collection system such that no emissions

occur. The NESHAP requirements for closed collection systems are

presented below.

This Equipment....

Must Meet ALL of These

Requirements....

Closed collection systems used to

transport pulping process condensates

containing HAPs

All of the individual drain system

requirements specified in §63.960,

63.961, and 63.962 of Subpart RRa

and any air vents in the collection

system must meet standards of

§63.443 (c) and (d) for the closed-vent

systems and HAP reductions for kraft

pulping system vent emissions

Condensate tanks used in the closed

collection system

Operate with no detectable leaks

(500 ppmv VOC above background)

and

Vent emissions to a closed-vent

system (see page 54) and route to a

control device (see page 53)

and

When the tank contains pulping

process condensates or any HAP

removed from the pulping condensate

stream, all openings must be kept in a

closed, sealed position - except

during sampling, inspection,

maintenance, or repair operations

a

 Subpart RR of 40 CFR 63 (National Emission Standards for Individual Drain Systems)

 establishes design, operating, inspection, and monitoring requirement standards for

 controlling air emissions from individual drain systems. The standards control

 emissions from individual drain systems using covers or seals, or hard-piping.

 Subpart RR also requires inspections of water seals and closure devices for defects or

 damage initially and establishes repair requirements for individual drain systems. The

 NESHAP requires inspection every 30 days.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

63

The mill can meet the closed collection system requirements in two ways:

• Hardpiping

• Use existing drains, but cover all openings and route all open

vents through a closed-vent collection system to a control

device meeting the NESHAP requirements for pulping

system vents.

If there are air vents off the closed collection system, these vents must be

routed to a closed-vent system. These air vents must comply with the kraft

pulping system standards for closed-vent systems and HAP emissions (see

pages 53 and 54).

When must a mill be in compliance?

Mills must achieve compliance with the pulping process condensate

requirements by April 16, 2001.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

64

For demonstrating

initial compliance for

the kraft pulping

process condensate

standards, total HAPs

are measured as

acetaldehyde,

methanol, methyl

ethyl ketone, and

propionaldehyde

How does a mill demonstrate initial compliance for kraft pulping

process condensate standards?

Mills must conduct a performance test to demonstrate initial compliance. A

performance test is required for each closed collection system and treatment

option. 

With respect to pulping condensates, the performance test serves four

purposes:

(1) To demonstrate that the appropriate condensate streams are

being collected and treated. The options for determining the

streams to be collected and controlled are presented on page 61. If a

mill uses one of the volume reduction options, the NESHAP

requires documentation to support the choice. For example, if a mill

opts to control condensate streams based on mass of total HAPs, the

mill must present test results to support that a complying mass of the

total HAPs is collected. Even in the case where a mill chooses to

collect and treat all pulping condensate streams, the mill must

demonstrate that all of the condensate streams have been identified

and collected. 

(2) To demonstrate that the closed collection system does not allow

any emissions to occur. Refer to page 62.

(3) To demonstrate that the control device complies with the

emission limit. For all alternative emission limits except biological

treatment, the mill can measure either total HAPs or methanol

concentration to document compliance with the emission limits. For

biological treatment, total HAP concentrations must be measured. 

See Figure 18.

(4) To establish the process operating parameter values that must

be continuously monitored. During the performance test, the mill

must measure the parameter values that the mill will monitor to

indicate continuous compliance. For example, the values of steam

feed rate, condensate feed rate, and temperature are specified as the

monitoring parameters for steam strippers.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

65

For the recycle

treatment option,

the performance

test would consist

only of verifying

that no leaks were

present in the

closed collection

system and

confirming closedvent system and

control device

requirements.

The test method

specified is used to

determine liquid

stream pollutant

concentration. 

Additional

calculations or

formulas are

specified in the

NESHAP to

convert the

concentration

values into the

format appropriate

to demonstrate

compliance with a

particular emission

limit.

Figure 18.

How Does a Mill Demonstrate Initial

Compliance with Kraft Pulping Condensate Emission Limits?

To Demonstrate Initial

Compliance With This

Emission Limit...

Conduct an Initial

Performance Test

Following This Method...

To Measure These

Parameters...

Recycle the condensate to

controlled equipment

None required None required

Use a biological treatment

system to meet 92%

reduction or to meet mass

limits

Method 305a

 and

Total HAPsb

and

Part 63, Appendix C Fraction of total HAPsb

removed (fbio)

Treat condensates to meet

92% reduction

Method 305a Total HAPb

 or methanol

mass at the control device

inlet and outlet

Treat the condensates to

meet mass limits

Method 305a Total HAPb

 or methanol

mass at the control device

inlet and outlet

Treat the condensates to

meet concentration limits

Method 305a Total HAPb

 or methanol

concentration at the control

device outlet

a The National Council of the Paper Industry for Air Stream Improvement (NCASI) direct

injection gas chromotography/flame ionization detection (GC/FID), may be used as an

alternative to EPA Method 305 for measuring methanol. b Measured as acetaldehyde, methanol, methyl ethyl ketone, and propionaldehyde.

How does a mill demonstrate continuous compliance with

pulping process condensate standards?

Mills must install continuous monitors to measure control device operating

parameters, except when recycling condensates to controlled process

equipment. In addition, quarterly testing is required if a mill chooses to

comply using biological treatment. The monitoring requirements depend on

the alternative emission limit selected. Figure 19 summarizes the

monitoring, reporting, and recordkeeping requirements for each alternative

emission limit.

The closed collection system must be visually inspected every 30 days

according to the following requirements:

 National Emission Standards for Individual Drain Systems

(63.964 subpart RR) requires inspection and monitoring
66

Figure 19.

How Does a Mill Demonstrate Continuous Compliance with Kraft Pulping Process Condensate 

If a Mill Chooses to

Comply With

Alternative Emission

Limits Using This

Technique...

Then Continuously Monitor All of

These Parameters... And Report This Information... And Keep These 

Recycle the condensateto controlledequipment 

None required None required None required

Steam stripper (percentreduction,concentration, or masslimits)

Process wastewater feed rate  Semi-annual emissions and

continuous monitoring performancereport

 If exceedences occur, then quarterly

reports are required(40 CFR 63.10(e))

Process wastewate

Steam feed rate Same as above Steam feed rateProcess wastewater column feedtemperature

Same as above Process wastewate

temperature

Steam stripper(concentration)

Steam stripper outlet concentration Same as above Steam stripper out

Biological treatmentsystem 

Quarterly test of HAP percentreduction or mass removala Same as above HAP percent redu

Outlet soluble BOD5b Same as above Outlet soluble BO

Mixed liquor volatile suspendedsolidsb Same as above Mixed liquor vola

Horsepower of aerator unitsb Same as above Horsepower of aeInlet liquid flowb Same as above Inlet liquid flowLiquid temperatureb Same as above Liquid temperatur

Other device Operating parameters demonstrated to

the Administrator’s satisfaction

Same as above Parameters approv

Volume reductionoptions

Same as above Same as above Same as above

a The initial performance test and annual 1st quarter mass removal or percent reduction tests must be performed for acetaldehyde, met

ketone, and propionaldehyde. However, if the ratio between the four HAPs and methanol is established in the 1st quarter, methanol 3rd, and 4th quarter tests instead of performing the test for the four HAPs. b Site-specific monitoring parameters may be used instead of those parameters specified in the NESHAP.
Chapter 4 - NESHAP Requirements

Kraft Mills

Pulping Process Condensates

67

Although there are

no explicit back-up

control

requirements as

part of the

NESHAP, back-up

controls may be

necessary for mills

that are concerned

that the excess

emission allowance

is inconsistent with

expected control

device operating

experience.

 Subpart S requires reporting and recordkeeping of all visual

inspection results. Semi-annual reports must be submitted. 

If exceedences occur, then quarterly reports are required.

Must a mill comply at all times?

The NESHAP provides a 10 percent excess emissions allowance for all

control devices other than biological treatment systems (63 FR 49455). For

example, the allowance would include steam stripper tray damage or

plugging, efficiency losses in the stripper due to contamination of

condensate with fiber or black liquor, steam supply downtime, and

combustion control device downtime.

Unlike the pulping standard, the 10 percent allowance for condensates

includes excused periods of excess emissions associated with the startup,

shutdown, and malfunction.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

68

Bleaching is the

brightening of pulp by

the addition of

oxidizing or reducing

chemicals.

A bleaching line is

a group of

bleaching stages

arranged in a

series such that

bleaching of the

pulp progresses as

the pulp moves

from one stage to

the next. Typically

a bleaching line

contains

3-5 stages.

4.3 Standards for the kraft bleaching system vents

At kraft mills, the emission limits apply to bleaching systems that use

chlorine or chlorinated compounds. The rules have emission limits for both

chloroform and chlorinated HAP (excluding chloroform). Kraft mills must

comply with both of these requirements. This section describes the

emission points that must be controlled, the alternative emission limits, and

compliance requirements.

What bleaching emission points must be controlled?

The NESHAP applies only to bleaching lines that use chlorinated

compounds and only to the bleaching stages where chlorine or chlorinated

compounds are introduced. Extraction stages are not covered. All vents in

a regulated stage must be controlled. A stage consists of the following

equipment:

• retention towers

• washers

• seal tanks

• chemical and steam mixers (if vented to the atmosphere)

• vacuum pumps (if present)

Are there any exemptions to the bleaching requirements?

Yes. Any bleaching system that does not use chlorine or any chlorinated

HAP is exempt from all NESHAP requirements for bleaching.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

69

The requirements for

enclosures and

closed-vent systems

are the same as for

the pulping system

vent standards

(page 54).

What are the control requirements for chlorinated HAPs?

The equipment at each bleaching stage where chlorinated compounds are

introduced must be enclosed and routed via a closed-vent collection system

to a control device. The rules provide three alternative emission limits for

demonstrating compliance, as shown below. Most mills are expected to use

caustic scrubbers to comply.

Bleaching System Gases Must be Collected in a Closed-vent System and Meet One

of These Three Alternative Emission Limitsa

...

1. Reduce chlorinated HAP b

 emissions by 99% by weight

2. Achieve a total outlet mass emission rate 0.002 pounds chlorinated HAPsb

per ton oven-dried pulp for all subject stages

3. Achieve an outlet concentration of 10 ppmv chlorinated HAPsb

a Some mills may be able to meet the outlet concentration or mass limits through use of

process modifications (i.e., 100 percent chlorine dioxide substitution). In these cases,

enclosures and closed-vent systems are not required. b Chlorinated HAPs (excluding chloroform) may be measured as total chlorinated HAP or

 as chlorine.

What are the control requirements for chloroform?

The rules provide two alternative emission limits for chloroform control. 

Both of these options (shown below) require process modifications. A mill

can comply by eliminating the use of chlorine and hypochlorite or by

complying with the numerical limits of the effluent limitations guidelines

and standards for water. If the compliance date for the effluent limitations

guidelines and standards is later than for the NESHAP, the earlier NESHAP

compliance dates must be met.

To Reduce Chloroform Emissions From the Bleaching Process,

Use One of These Two Options...

1. Eliminate the use of chlorine and hypochlorite

2. Comply with applicable Effluent Limitations Guidelines and Standards

(40 CFR 430)a

a

 Refer to Appendix I for a summary of the wastewater regulations for bleached

papergrade kraft mills.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

70

Bleaching Systems

Compliance Dates:

Most mills: 

April 16, 2001

Mills enrolled in

VATIP: April 15,

2004

VATIP is available

only to papergrade

kraft and papergrade

soda mills that

discharge directly to

receiving waters.

The application rate

limitation and the

dioxin and

adsorbable organic

halide limits are

provided to prevent a

bleaching system

from “backsliding”

(i.e., increasing

chlorinated bleaching

chemical use during

the extended

compliance period). 

When must bleaching systems comply?

 Bleaching systems must comply by April 16, 2001 with two exceptions.

 Mills enrolled in the Voluntary Advanced Technology

Incentives Program (VATIP)

 Dissolving grade kraft mills

Voluntary Advanced Technology Incentives Program (VATIP). Under the

Effluent Limitations Guidelines and Standards (40 CFR Part 430.24), a mill

may choose to enroll one or more of its bleach lines in the Voluntary

Advanced Technology Incentives Program. The program provides extended

compliance with the water pollution control requirements for bleached

papergrade kraft and soda mills in exchange for achieving greater water

pollutant reductions than the regulatory baseline. Mills electing this

program receive a 3-year extension for complying with the NESHAP

bleaching standards (i.e., must comply by April 15, 2004). Three conditions

must be met to qualify for the extension.

(1) Comply with the interim MACT standard for chloroform

emissions by either: 

No increase the application rates of either chlorine or hypochlorite

(in kg per Mg oven-dried pulp) in the bleaching system beyond the

average daily rates used over the three months prior to June 15,

1998, 

or

Comply with the enforceable effluent limitations guidelines

for 2,3,7,8 - tetrachloro-dibenzo-p-dioxin and adsorbable

organic halides at least as stringent as the BAT levels set out

in 40 CFR 430.24(a)(1) as expeditiously as possible, but no

later than by April 16, 2001.

(2) Submit a control strategy report by April 1999 (see 63.445(b)).

(3) Submit an updated control strategy report every two years

under 63.455(b) until compliance is achieved. The report

must contain milestones and status reports for achieving

compliance.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

71

The compliance

date for dissolving

grade kraft mills is

not specified in the

NESHAP, but is

anticipated

between

2003-2005.

Dissolving grade kraft mills must comply within 3 years after publication

of revised effluent limitations guidelines and standards under 40 CFR

430.14 through 430.17 and 40 CFR 430.44 through 430.47. These rules are

scheduled to be revised sometime between 2000 and 2002.

How does a mill demonstrate initial compliance with the

bleaching standards?

Chlorinated HAPs. Mills must demonstrate initial compliance with

chlorinated HAP standards by conducting an initial performance test for

each bleaching stage where chlorine or chlorinated compounds are

introduced.

The initial performance test has two objectives:

(1) To demonstrate that the control device complies with the

emission limit.

(2) To demonstrate that the closed-vent system captures and

contains all HAP emissions. Refer to Figure 16.

(3) To establish the process operating parameter values that

must be monitored to demonstrate continuous

compliance.

At the option of the mill, compliance may be demonstrated by measuring

either total chlorinated HAPs (including chloroform) or chlorine

concentration. The following methods must be used:

Chlorinated HAPs - Any method that has been

demonstrated to the Administrator’s

satisfaction.

Chlorine - Method 26A, as modified by

63.457(b)(5) of the rules.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

72

Continuous

monitoring is

required unless a

mill complies by

eliminating all use

of chlorine or

chlorinated

compounds as

bleaching agents.

These same

demonstrations are

required as part of

the initial

performance test.

Chloroform. No initial performance test is required if the mill chooses to

eliminate use of chlorine and chlorinated HAPs. The mill must demonstrate

in the initial notification that is not using these chemicals. Alternatively, if a

mill chooses to comply with the Effluent Limitations Guidelines and

Standards, then all compliance demonstration requirements of 40 CFR 430

apply.

How does a kraft mill demonstrate continuous compliance with

the bleaching standards?

For chlorinated HAPs, mills must install a continuous monitoring system

to measure either emissions, or control device or process operating

parameters. The monitoring, reporting, and recordkeeping requirements are

summarized in Figure 20.

In addition, the mill must conduct periodic inspection and maintenance of

all enclosures and closed-vent systems. These requirements are explained

below. The mill must maintain a site-specific inspection plan for the

enclosures and closed-vent system. Records of repairs based on the

inspections must also be kept.

If the System has... Then Inspect... And Report...

And Keep

Records of...

Enclosure opening Visually inspect every 30

days to ensure closed and

sealed

Any exceedences of the

closed-vent standard in

quarterly reports. If no

exceedences occur, submit

semi-annual reports.

All visual checks and

any repairs

Annually demonstrate 

negative pressure

Same as above All pressure tests

Closed-vent system Visually inspect every 30

days for visible defects

Same as above All visual checks and

repairs

Positive pressure

closed-vent system

Annually demonstrate no

detectable leaks (less than

500 ppmv)

Same as above All leak tests

Bypass line valve Inspect every 30 days to

ensure valve is in a closed

position and vent stream is

not diverted through

bypass line

Same as above All visual checks and

repairs

Note: This is the same table as the one presented on page 57.

For chloroform, if the mill chooses to eliminate the use of hypochlorite and

chlorine, then no parametric monitoring is required to show continuous

compliance. If the mill chooses not to eliminate the use of hypochlorite and

chlorine, then the mill must comply with the effluent limitations guidelines

and standards.
73

Figure 20.

How Does a Kraft Mill Demonstrate Continuous Compliance with Emission Limits for Chlo

If a Mill Chooses This

Technique to Comply

With This Alternative

Emission Limit...

Continuously Monitor These

Parameters... Report This Information... And Keep These 

Gas scrubber to reducechlorinated HAPemissions by 99% byweight or to achieve anoutlet mass emissionrate  0.002 pounds

chlorinated HAPs perton oven-dried pulp

pH or oxidation/reduction potential ofeffluent

 Semi-annual emissions and

continuous monitoring performancereport

 If exceedences occur, then quarterly

reports are required(40 CFR 63.10(e))

pH or oxidation/reeffluent

Vent gas inlet flow rate Same as above Vent gas inlet flow Scrubber liquid influent flow rate Same as above Scrubber liquid in

Gas scrubber to achievean outlet concentrationof chlorinated HAPs10 ppmv

Chlorine concentration at the outlet ormeasure all three of the following

parameters

Same as above Chlorine concentr

following

pH or oxidation/reduction potential ofeffluent

Same as above pH or oxidation/re

effluent

Vent gas inlet flow rate Same as above Vent gas inlet flowScrubber liquid influent flow rate Same as above Scrubber liquid in

Any control deviceother than a gasscrubber or processmodifications

Determine appropriate monitoringparameter values during the initialperformance testa

Same as above Parameters approv

a As specified in 40 CFR Part 63.453(n)
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

74

Mills in the voluntary advanced technology incentives program must

monitor compliance in the interim!

If a mill chooses the "no backsliding" alternative to comply with the interim

MACT standard for chloroform emissions, the NESHAP specifies

monitoring, reporting, and recordkeeping requirements. These

requirements, which are summarized in the figure below, apply from June

1998 up to the time that the mill demonstrates compliance with all the

applicable bleaching system emission limits. The NESHAP does not

specify monitoring, reporting, and recordkeeping requirements for mills that

choose to comply with the BAT levels for 2,3,7,8, - tetrachloro-dibenzo-pdioxin and adsorbable organic halides instead of the "no backsliding"

alternative.

If a Mill Chooses

This Interim

Emission Limit...

Then Continuously

Monitor These

Parameters...

And Report This

Information...

And Keep These

Records for

5 Years...

No increase in the 

use of

hypochlorite and

chlorine

Chlorine and

hypochlorite

application rates in

lb/ton oven-dried pulp

(daily average)

An initial control

strategy report by

April 1999 that

meets the

requirements of

63.455. Updated

control strategy

report every 2 years,

 and

Daily application

rates of chlorine and

hypochlorite must

be reported every

six months

Daily application

rates

Comply with the

BAT levels for

2,3,7,8 -

tetrachlorodibenzo-p-dioxin

and adsorbable

organic halides

Nonea Nonea Nonea

a

Comply with any monitoring, reporting, and recordkeeping requirements of

 the BAT permit.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

75

The CCA applies

only to the kraft

HVLC system:

 washers

 knotters and

 screens

 deckers

 oxygen

 delignification

4.4 Clean condensate alternative for HVLC vents

The clean condensate alternative (CCA) is a pollution prevention alternative

emission limit for pulping vents that is available only to kraft HVLC

systems. The CCA allows mills to meet the HVLC emission limits by

reducing the HAP concentration in the process waters that are recycled to

other pieces of process equipment. This approach allows mills to control

HAP emissions by reducing the amount of HAPs that are volatilized from

selected process equipment instead of using combustion devices to control

HVLC system vent streams. By reducing the HAP concentration in process

water, the amounts of volatilized HAPs are also reduced.

To achieve compliance, the facility must demonstrate that the HAP

emission reductions using the CCA technology are equal to or greater than

those emission reductions that would have been achieved through

compliance with the HVLC system requirements.

For example, a mill could use a stand-alone biological treatment device to

reduce the total HAP concentration in pulping process condensates. The

effluent from the stand-alone biological treatment device could be used as

process water in the pulping washing system and causticizing system. In

this scenario, initial compliance using the CCA would be demonstrated by

showing that the reduction of emissions from both the pulping washing

system and causticizing system is equal to or greater than the reductions that

would have been achieved by applying the pulping vent standards to the

pulp washing system vent emissions.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

76

The CCA is similar

to emission

averaging.

The concept of the

CCA is the reduction

of HAP emissions

through reduction of

HAP concentration in

process water.

The CCA can be

used by both new

and existing

sources.

Which equipment systems can be used to generate the

emission reductions?

Process condensates are recycled throughout the mill. The CCA allows

mills to take credit for emission reductions achieved in several systems

through the use of CCA technologies.

Sources From Which Emission Reductions Can be Credited...

 Pulping systems (HVLC)

 Bleaching systems

 Causticizing systems

 Papermaking systems

What emission reductions are creditable?

A CCA technology must achieve the emission reductions by removing

HAPs from condensate streams. The CCA emission reductions are

generated by either of two methods:

 control of condensates that are not regulated under the kraft

pulping condensate standard

 control beyond the levels required by the condensate

standard

Emission reductions from add-on controls on vent streams do not count.

Can a mill use the CCA for only part of the emission reduction

requirement for the HVLC system?

Yes. The HAP emission reductions resulting from the CCA can be used as

partial or complete fulfilment of the emission reductions required for the

HVLC pulping standard. For example, a mill may elect to use the CCA in

lieu of vent controls for the washer system, but comply by using vent

controls for the rest of the HVLC system.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

77

All CCA emission

reductions must be

based on actual

test data.

Emission reductions

achieved by the CCA  Baselineemissions 

Emission levels after

the CCA has been

implemented

How does a mill use the CCA?

A mill must follow these steps to implement the CCA:

(1) Determine baseline emissions. Baseline emissions are to be

measured after compliance has been achieved with all of the

following:

 Kraft pulping process condensate standards

 All effluent limitations guidelines and standards in

40 CFR subpart B

 Emission reductions attributable to control

technology required by local, State, or Federal

agencies

Furthermore, baseline emissions must include any control

equipment installed and operated before December 17, 1993.

(2) Calculate emission reductions that would have been achieved

through compliance with the kraft pulping HVLC system

standards.

(3) Measure emissions reductions achieved by the CCA.

(4) Demonstrate compliance through the CCA by documenting

that emission reductions achieved through the CCA are

greater than or equal to emission reductions that would have

been achieved through compliance with the kraft pulping

HVLC system standards.
Chapter 4 - NESHAP Requirements

Kraft Mills

Bleaching Systems

78

Since the CCA

applies only to the

HVLC system, the

compliance date

for existing sources

is April 17, 2006.

How does a mill demonstrate initial compliance?

A mill must conduct a performance test before and after CCA

implementation. Baseline emission levels and all CCA emission reductions

must be based on actual test data. 

How does a mill demonstrate continuous compliance?

The control strategy using the CCA will vary among mills, depending on

mill configuration and emission points selected. Thus, the monitoring and

reporting requirements for the CCA are not specified in the rules. Each mill

must propose monitoring, reporting, and recordkeeping requirements for the

Administrator’s approval.

What approvals are required to use the CCA?

Mills that opt to use the CCA must submit a CCA control strategy report

along with the initial notification. Updates are required every 2 years. The

requirements of the control strategy report are specified at

40 CFR 63.455(b) and 40 CFR 63.447(g).

The mill must report to the Administrator by the final compliance date the

rationale, calculations, test procedures, and data used to demonstrate

compliance. The Administrator will make the final compliance

determination.
Chapter 4 - NESHAP Requirements -

Kraft Mills - NSPS vs. NESHAP

79

In addition to TRS,

the NSPS limits

particulate matter

from recovery

furnaces, smelt

dissolving tanks,

and lime kilns

4.5 How do the requirements for the NSPS and the

NESHAP compare?

The kraft NSPS (40 CFR 60, subpart B) contains TRS emission limits for

the following sources: the digester system, brown stock washer system,

evaporator system, recovery furnace, smelt dissolving tank, lime kiln, and

condensate stripper system. The kraft NSPS applies to equipment that was

constructed, modified, or reconstructed after September 24, 1976. Because

the pulp and paper NESHAP (subpart S) does not cover recovery furnaces,

smelt dissolving tanks, or lime kilns, the only equipment systems that have

overlapping NSPS and the NESHAP requirements are the digester, brown

stock washer, evaporator, and condensate stripper systems. 

To demonstrate compliance with the NSPS and NESHAP (subpart S), it is

possible that the same device could be used to control emissions from these

equipment systems. Figure 21 compares the NSPS and NESHAP emissions

limits for the control devices that are likely to be used to comply with both

of these regulations. Note that only one control option (the thermal oxidizer

design requirement of 1600F for 0.75 seconds) automatically satisfies both

the NESHAP and NSPS requirements. For all of the other potential control

devices mills must demonstrate compliance with both the NSPS and the

NESHAP.
Chapter 4 - NESHAP Requirements -

Kraft Mills - NSPS vs. NESHAP

80

The MACT control

technologies can

be used to comply

with the NSPS

limits for TRS, but

mills still must

demonstrate that

the NSPS emission

limits for TRS are

being met.

A thermal oxidizer

is the only option

where meeting the

NESHAP

automatically

meets the NSPS for

TRS. 

Figure 21.

Comparison of NESHAP (Subpart S) and NSPS (TRS) Emission

Limit Requirements

If a Mill Uses

This Control

Option...

The NSPS

Requires... And the NESHAP Requires...

Does NESHAP

Compliance

Ensure NSPS

Compliance?

Lime Kilna A maximum TRS

outlet concentration

of 8 ppmv corrected

to 10% oxygen

Vent streams be introduced with

primary fuel or into the flame

zone

No

Recovery Furnacea Straight recovery: A

maximum TRS outlet

concentration of

5 ppmv corrected at

8% oxygen

Vent streams be introduced with

primary fuel, into the flame zone,

or with the combustion air

No

Cross recovery: A

maximum TRS outlet

concentration of 25

ppmv corrected to 8%

oxygen

Same as above No

Power

Boiler

1200F for

0.5 second

Vent streams be introduced with

primary fuel, into the flame zone,

or with the combustion air

No

Thermal Oxidizer

or other

combustion

deviceb

1200F for

0.5 second

1600F for 0.75 second

 

 or

Yes

20 ppmv total HAPs or methanol

at 10% oxygen

 or

No

98% reduction by weight of total

HAPs or methanol

No

Other

noncombustion

devices

5 ppmv TRS at actual

oxygen content of

untreated stream

20 ppmv total HAPs or methanol

at 10% oxygen

 or

No

98% reduction by weight of total

HAPs or methanol

No

a The NSPS requirements are only for those devices that are subject to the NSPS.

b The gases are combusted with other waste gases in an incinerator or other device, or combusted

in a lime kiln or recovery furnace not subject to the NSPS (60.283 (a)(1)(iii)).
81

The NESHAP

requirements for

semi-chemical and

soda mills are similar

to the requirements

for kraft mills except

that pulping process

condensates are not

regulated at semichemical and soda

mills.

Chapter 5 - NESHAP Requirements for

Semi-Chemical and Soda Mills

For semi-chemical and soda mills, the NESHAP contains emission

standards for pulping system vents and bleaching system vents. There are

several alternative emission limits for both processes, and mills can choose

the emission limits with which to comply.

The requirements in the NESHAP for semi-chemical and soda mills are

described in this chapter.

If You Need the Following Information... Then Read...

Standards for semi-chemical and soda pulping

system vents

Section 5.1

Standards for semi-chemical and soda

bleaching system vents

Section 5.2
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Pulping System Vents

82

For purposes of

this NESHAP, the

LVHC system

includes all vents

from:

 digester system

 turpentine

 recovery

 system

 evaporator

system

For semi-chemical

and soda mills, the

NESHAP does not

apply to existing

HVLC systems.

5.1 Standards for semi-chemical and soda pulping

system vent standards

What pulping system vents must be controlled?

The NESHAP requires certain equipment in the pulping systems at semichemical and soda mills to be enclosed, collected in a closed-vent system,

and then vented to a control device. 

The Following Pulping System Vents Must be Controlled...

Existing Sources

 LVHC system

New Sources

 LVHC system

 Pulp washing system

Each equipment system has multiple emission points. For example, the

pulp washing system can include vacuum drum washers, diffusion washers,

rotary pressure washers, horizontal belt filters, intermediate stock chests,

associated vacuum pumps, filtrate tanks, and foam breakers. A complete

list of the emission points in each equipment system is provided in

Appendix F.
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Pulping System Vents

83

The NESHAP does

not provide the

Clean Condensate

Alternative to

semi-chemical and

soda pulping

systems because

the Clean

Condensate

Alternative was

provided to kraft

mills as an option

for meeting the

HVLC system

emission limits.

HVLC systems at

existing semichemical and soda

mills are not

regulated by the

NESHAP.

What are the emission limits for semi-chemical and soda

pulping system vents?

The emissions from semi-chemical and soda pulping system vents must

meet one of five alternative emission limits, as shown below. These

emission limits apply to each control device used to control HAP emissions. 

A mill will likely use several closed-vent systems and control devices

(including both add-on control devices and existing combustion devices)

and each can comply with any of these five alternative emission limits. 

These emission limits apply to both new and existing sources.

Pulping System Vent Gases Must be Collected in a Closed-vent

System and Routed to One of These Five Control Devices...

1. Any control device that reduces total HAP emissions by 98% by

weight, measured as total HAPs or methanol

2. A boiler, lime kiln, or recovery furnace with a heat input capacity

of at least 150 MMBtu/hr in which the HAP gas stream is

introduced with the combustion air

3. A boiler, lime kiln, or recovery furnace in which the HAP gas

stream is introduced with the primary fuel or into the flame zone

4. A thermal oxidizer operated at a minimum temperature of 1,600°F

and a minimum residence time of 0.75 seconds

5. A thermal oxidizer that reduces the total HAP concentration at the

outlet to  20 ppmv corrected to 10% O2 on a dry basis, measured

as total HAPs or methanol

Note: These emission limits are the same as for kraft mills (see page 53).
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Pulping System Vents

84

A closed-vent

system means a

system that is not

open to the

atmosphere and

comprises piping,

ductwork,

connections, and if

necessary, flowinducing devices

that transport gas

or vapor from an

emission point to a

control device.

What does the NESHAP require for enclosures and closed-vent

systems at semi-chemical and soda mills?

All regulated equipment system vents must be enclosed and routed through

a closed-vent system to the control device that is selected for compliance. 

The requirements for enclosures and closed-vent systems are presented

below. The requirements are intended to prevent leaks and ensure that

process openings (e.g., sampling ports on a brown stock washer enclosure)

are closed while the mill is in operation.

This Equipment....

Must Meet These

Requirements....

Enclosures, openings, and hoods Maintain negative pressure

and

If closed during the initial

performance test, must be closed

during operation except for

sampling, inspection, maintenance,

or repairs

Components operated at positive

pressure

Operate with no detectable leaks

(500 ppmv VOC above

background)

Bypass lines that could divert vent

stream containing HAPs to the

atmosphere

Seal and secure the opening so that

the valve or closure mechanism

cannot be opened without breaking

the seal

or

If computer controlled, monitor for

presence of gas stream flow at least

once every 15 minutes

Note: These requirements are the same as for kraft mills (presented on

page 54).
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Pulping System Vents

85

Because semichemical and soda

mills are not

affected by the

Effluent

Limitations

Guidelines and

Standards, the

NESHAP does not

allow these mills

any extended

compliance times.

The excess

emission

allowances are

the same for

kraft, semichemical, and

soda mills. Refer

to page 59 for

additional

details.

When must mills comply with the semi-chemical and soda

pulping process standards?

Pulping systems at semi-chemical and soda mills must comply with the

MACT standards by April 16, 2001. 

How does a mill demonstrate initial and continuous compliance

with the pulping system vent standards?

A mill must demonstrate compliance through an initial performance test and

then continuously monitor a set of control device operating parameters for

each closed-vent system and control device. When complying by venting

gases to a boiler, lime kiln, or recovery furnace, the initial performance test

must demonstrate that the gases are being introduced with the primary fuel

or into the flame zone. If the boiler, lime kiln, or recovery furnace has a

heat input capacity of at least 150 MMBtu/hr, the initial performance test

must demonstrate that the HAP gases are introduced with the combustion

air.

The initial and continuous compliance requirements for semi-chemical and

soda mills are identical to those for kraft mills. Please read pages 56

through 59 of this document.

Must a mill comply at all times?

For pulping system vents, the NESHAP establishes an allowable percent of

operating time during which HAP emission levels in excess of the

established limit shall not be considered to be a violation of the standard.

For soda and semi-chemical mills, the excess emission allowances are:

 1 percent of operating time for control devices used for

LVHC system vents

 4 percent of operating time for control devices used for pulp

washing systems (HVLC)

 4 percent of operating time for control devices used for

combined LVHC and pulp washing system vents

(i.e., controlled by the same device)
Chapter 5 - NESHAP Requirements

Semi-Chemical and Soda Mills

Bleaching System Vents

86

Currently, there is

only one soda mill

operating in the

U.S.

5.2 Standards for bleaching system vents at

semi-chemical and soda mills

Semi-chemical mills

Generally, semi-chemical mills in the United States do not have bleaching

systems and therefore are not subject to bleaching standards. Technically,

the rule would apply if a semi-chemical mill installed a bleaching system

using chlorine. While this is not expected to occur, such a mill would have

to comply with the emission standards for chlorinated HAPs (excluding

chloroform) from bleaching vents. The rule would not apply to bleaching

systems using chlorinated compounds other than chlorine. Refer to

Section 4.3 for information about bleaching standards, excluding the

chloroform standard.

Soda mills

At soda mills, emission limits apply to bleaching systems that use chlorine

or chlorinated compounds. The emission standards and compliance

demonstration requirements for soda mills are the same as for kraft mills

(presented in Section 4.3) and are not repeated in this chapter. Refer to the

following pages for specific information.

 Emission points to be controlled—page 68

 Control requirements for chlorinated HAPs and

chloroform—page 69

 How to demonstrate initial compliance—page 71

 How to demonstrate continuous compliance—page 72.
87

Chapter 6 - NESHAP Requirements for

Sulfite Mills

For sulfite mills, the NESHAP contains emission standards for pulping

system vents and bleaching system vents.

The NESHAP contains two alternative emission limits for pulping system

vents. A mill can choose to comply with either limit. Different numerical

emission limits are specified for calcium- and sodium-based pulping

systems than for magnesium- and ammonium-based pulping systems.

The NESHAP also contains several alternative emission limits for bleaching

process system vents. The NESHAP does not regulate pulping process

condensates at sulfite mills.

If You Need the Following Information... Then Read...

Standards for sulfite pulping system vents Section 6.1

Standards for sulfite bleaching system vents Section 6.2
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

88

The emission limits

are the same for

existing and new

sources. 

Appendix C

contains a

flowchart summary

of the NESHAP.

6.1 Standards for sulfite pulping system vents

The NESHAP requires the pulping systems to be enclosed, collected in a

closed-vent system, and then vented to a control device. This section

describes the emission points that must be controlled, the two alternative

emission limits, and the compliance requirements.

What sulfite pulping system vents must be controlled?

The NESHAP specifies that all the vents from the digester system,

evaporator system, and pulp washing systems must be controlled. 

Additional equipment must be controlled at new sources. These pulping

system vents are identified below.

The Following Pulping System Vents Must be Controlled...

Existing Sources

 Digester system

 Evaporator system

 Pulp washing system

New Sources

 Same as existing sources plus...

 All weak liquor storage tanks

 All strong liquor storage tanks

 All acid condensate storage tanks

Each equipment system has multiple emission points. For example, the

evaporator system comprises pre-evaporators, multi-effect evaporators,

concentrators, vacuum systems, associated condensers, hot wells, and

condensate streams. A complete list of the emission points in each

equipment system is provided in Appendix F.
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

89

These emission

limits apply to the

entire source, not

to individual pieces

of equipment as do

the emission limits

for pulping system

vents at other

mills.

Outlet emission

level and percent

reduction

requirements must

account for HAP

releases from

vents, condensates,

and wastewater

from control

devices used to

reduce HAP

emissions.

What are the emission limits for sulfite pulping system vents?

The sulfite pulping system vents must meet either a percent reduction or

mass emission limit identified for the specific type of sulfite pulping process

(i.e., calcium- and sodium-based or magnesium- and ammonium-based

pulping processes). The emission limits apply to the combined emissions

from both the regulated equipment and any vents, wastewater, and

condensate streams generated from any control device used to reduce the

HAP emissions. Therefore, a mill must choose either the percent reduction

or the mass emission format and demonstrate compliance with the emission

limit using the combined emissions from the entire pool of regulated

equipment. Compliance may not be demonstrated at individual pieces of

equipment or individual closed-vent systems.

If the Sulfite Pulping System

is This Type...

Then Choose One of the

Following Emission Limits...

Calcium-based and

Sodium-based

Reduce total HAP concentration to

0.89 lb/ton oven-dried pulp,

measured as total HAPs or

methanol

or

Reduce total HAP emissions by

92% by weight, measured as total

HAPs or methanol

Ammonium-based and

Magnesium-based

Reduce total HAP concentration to

2.2 lb/ton oven-dried pulp,

measured as total HAPs or

methanol

or

Reduce total HAP emissions by

87% by weight, measured as total

HAPs or methanol
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

90

A closed-vent

system means a

system that is not

open to the

atmosphere and

comprises piping,

ductwork,

connections, and if

necessary, flowinducing devices

that transport gas

or vapor from an

emission point to a

control device.

What does the NESHAP require for enclosures and closed-vent

systems?

All regulated equipment systems must be enclosed and routed through a

closed-vent system to the control device that is selected for compliance. 

The requirements for enclosures and closed-vent systems are presented

below. The requirements are intended to prevent leaks and ensure that

process openings (e.g., sampling ports on a brown stock washer enclosure)

are closed while the mill is in operation.

This Equipment....

Must Meet These

Requirements....

Enclosures, openings, and hoods Maintain negative pressure

and

If closed during the initial

performance test, must be closed

during operation except for

sampling, inspection, maintenance,

or repairs

Components operated at positive

pressure

Operate with no detectable leaks

(500 ppmv VOC above

background)

Bypass lines that could divert vent

stream containing HAPs to the

atmosphere

Seal and secure the opening so that

the valve or closure mechanism

cannot be opened without breaking

the seal

or

If computer controlled, monitor for

presence of gas stream flow at least

once every 15 minutes

Note: These requirements are the same as for kraft mills (presented on

page 54).
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

91

When must mills comply with the sulfite pulping process

requirements?

Affected sources at sulfite mills must comply with the NESHAP by

April 16, 2001.

How does a mill demonstrate initial compliance with the sulfite

pulping system vent standards?

A mill must demonstrate compliance through an initial performance test. 

Total HAP may be measured as methanol using Method 308.

The initial performance test has three objectives:

(1) To demonstrate that the control device complies with the

emission limit.

(2) To demonstrate that the closed-vent system captures and

contains all HAP emissions. Refer to Figure 23.

(3) To establish the process operating parameter values that must

be monitored to demonstrate continuous compliance. For

example, at a calcium-based and sodium-based sulfite mill, the vent

gas flow rate, scrubbing media flow rate, and pH of the scrubber

effluent that indicate 92 percent reduction by weight of total HAPs

or methanol using Method 308.
Chapter 6 - NESHAP Requirements

Sulfite Mills

Pulping System Vents

92

The excess

emissions

allowance (for

kraft, semichemical, and soda

mills) does NOT

apply to sulfite

mills.

These same tests

are required as

part of the initial

performance test.

How does a mill demonstrate continuous compliance with the

sulfite pulping system vent standards?

Mills must install a continuous monitoring system to measure either control

device or process operating parameters. Control device (other than gas

scrubbers) or process parameters to be monitored are determined by the

facility (i.e., site-specific). Continuous monitors for the selected parameters

are required to demonstrate continuous compliance. Figure 24 presents the

continuous compliance monitoring requirements.

In addition, the mill must comply with the requirements for periodic

inspection and maintenance of all enclosures and closed-vent systems. 

These requirements are explained in Figure 23. The mill must maintain a

site-specific inspection plan for the enclosures and closed-vent system. 

Records of repairs based on the inspections must also be kept.

Figure 23.

How Does a Mill Demonstrate Initial and Continuous Compliance with

the Closed-Vent Systems Standard?

If the System has... Then Inspect... And Report...

And Keep

Records of...

Enclosure opening Visually inspect every 30

days to ensure closed and

sealed

Any exceedences of the

closed-vent standard in

quarterly reports. If no

exceedences occur, submit

semi-annual reports.

All visual checks and

any repairs

Annually demonstrate 

negative pressure

Same as above All pressure tests

Closed-vent system Visually inspect every 30

days for visible defects

Same as above All visual checks and

repairs

Positive pressure

closed-vent system

Annually demonstrate no

detectable leaks (less than

500 ppmv)

Same as above All leak tests

Bypass line valve Inspect every 30 days to

ensure valve is in a closed

position and vent stream is

not diverted through

bypass line

Same as above All visual checks and

repairs

Note: These are the same requirements as for kraft mills (presented on

page 57).
93

Figure 24.

How Does a Mill Demonstrate Continuous Compliance with the

Sulfite Pulping System Vent Standards?

If the Sulfite Pulping

System is This Type...

And the Mill Chooses

This Alternative

Emission Limit...

And the Mill Chooses

This Technique...

Continuously Monitor

These Parameters...

And Report Th

Information.

Calcium-based andSodium-based

Reduce total HAPa

concentration at theoutlet to 0.89 lb/ton or

reduce total HAPa

emissions by 92% byweight

Gas scrubber pH or oxidation/reduction

potential of effluentVent gas inlet flow rateScrubber liquid influentflow rate

 Semi-annual

emissions andcontinuousmonitoringperformancereport

 If exceedence

occur, thenquarterly repoare required(40 CFR63.10(e))

Site-specific parameters Determine appropriate

monitoring parametervalues during the initialperformance testb

Same as above 

Ammonium-based andMagnesium-based

Reduce total HAPa

concentration at theoutlet to 2.2 lb/ton or

reduce total HAPa

emissions by 87% byweight

Same as above Same as above Same as above 

a Methanol may be used as a surrogate for total HAPs. b As specified in 40 CFR Part 63.453(a).
Chapter 6 - NESHAP Requirements

Sulfite Mills

Bleaching System Vents

94

The compliance

date for dissolving

grade sulfite mills

is not specified in

the NESHAP, but is

anticipated

between

2003-2005.

6.2 Standards for sulfite bleaching system vents

At sulfite mills the emission limits apply to bleaching systems that use

chlorine or chlorinated compounds. The NESHAP has emission limits for

both chloroform and chlorinated HAP. Sulfite mills must comply with both

of these requirements. The emission standards and compliance

demonstration requirements for sulfite mills are the same as for kraft mills

(presented in Section 4.3) and are not repeated in this chapter. Refer to the

following pages for specific information.

 Emission points to be controlled—page 68

 Control requirements for chlorinated HAPs and

chloroform—page 69

 How to demonstrate initial compliance—page 71

 How to demonstrate continuous compliance—page 72.

When must sulfite bleaching systems comply?

Bleaching systems must comply by April 16, 2001 with one exception.

 Dissolving grade sulfite mills must comply within 3 years after

publication of revised effluent limitations guidelines and standards

under 40 CFR 430.14 through 430.17 and 40 CFR 430.44 through

430.47. These rules are scheduled to be revised sometime between

2001 and 2002.
95

Secondary fiber

means recycled fiber.

The chloroform

control requirements

of the NESHAP do not

apply to bleaching

systems at these types

of mills.

Typically, a bleaching

line contains

3-5 stages.

Chapter 7 - NESHAP Requirements for

Mechanical, Secondary Fiber,

and Non-wood Fiber Pulp Mills

The NESHAP regulates bleaching system vents for mechanical pulping,

secondary fiber, and non-wood fiber pulp mills. The NESHAP applies to

bleaching systems that use chlorine or chlorine dioxide, and has identical

requirements for mechanical, secondary fiber, and non-wood fiber

processes.

The pulping process system vents and condensates are not regulated at these

mills. 

7.1 Standards for bleaching system vents

At mechanical, secondary fiber, and non-wood fiber pulp mills the

NESHAP regulates chlorinated HAPs (excluding chloroform). The

emission limits apply to bleaching systems that use chlorine or chlorine

dioxide. However, if a bleaching system for one of these processes also

accepts pulp from a kraft, semi-chemical, soda, or sulfite process, then more

stringent bleaching system requirements will apply (i.e., the bleaching

system also must meet the chloroform control requirements).

What mechanical, secondary fiber, and non-wood fiber

bleaching system emission points must be controlled?

The NESHAP applies only to bleaching stages that use chlorine or chlorine

dioxide. Extraction stages are not covered. All vents in a regulated stage

must be controlled. A stage consists of the following equipment:

 retention towers

 washers

 seal tanks

 chemical and steam mixers (if vented to the atmosphere)

 vacuum pumps (if present)
Chapter 7 - NESHAP Requirements

Mechanical Pulping, Secondary

Fiber, and Non-wood Fiber Mills

Pulping System Vents

96

There are no control

requirements for

chloroform at these

other types of mills.

The requirements for

enclosures and

closed-vent systems

are the same as for

the pulping system

vent standards

(page 54).

Are there any exemptions to the bleaching requirements?

Yes. Any bleaching system that does not use chlorine or chlorine dioxide is

exempt from all NESHAP requirements for bleaching.

What are the control requirements for chlorinated HAPs?

The equipment at each bleaching stage where chlorinated compounds are

introduced must be enclosed and routed via a closed-vent collection system

to a control device. The rule provides three alternative emission limits for

demonstrating compliance, as shown below. Most mills are expected to use

caustic scrubbers to comply.

Bleaching System Gases Must be Collected in a Closed-vent System

and Meet One of These Three Alternative Emission Limitsa

...

1. Reduce chlorinated HAP b

 emissions by 99% by weight

2. Achieve a total outlet mass emission rate 0.002 pounds

chlorinated HAPsb per ton oven-dried pulp for all subject stages

3. Achieve an outlet concentration of chlorinated HAPsb

10 ppmv

a Some mills may be able to meet the outlet concentration or mass limits through use of

process modifications (i.e., 100 percent chlorine dioxide substitution). In these cases,

enclosures and closed-vent systems are not required. b Chlorinated HAPs (excluding chloroform) may be measured as total chlorinated HAP or

 as chlorine.

Note: These emission limits are the same for kraft mills (presented on

page 69).

When must mechanical, secondary fiber, and non-wood fiber

bleaching systems comply?

All mechanical, secondary fiber, and non-wood fiber processes must comply

with the chlorinated HAP control requirements by April 16, 2001.
Chapter 7 - NESHAP Requirements

Mechanical Pulping, Secondary

Fiber, and Non-wood Fiber Mills

Pulping System Vents

97

How does a mill demonstrate initial compliance with the

bleaching standards?

Chlorinated HAPs. The mill must demonstrate initial compliance with

chlorinated HAP standards by conducting an initial performance test for

each bleaching stage where chlorine or chlorinated compounds are

introduced.

The initial performance test has three objectives:

(1) To demonstrate that the control device complies with the

emission limit.

(2) To demonstrate that the closed-vent system captures and

contains all HAP emissions. Refer to Figure 16.

(3) To establish the process operating parameters that must

be monitored to demonstrate continuous compliance.

At the option of the mill, compliance may be demonstrated by measuring

either total chlorinated HAPs or chlorine concentration. The following

methods must be used:

Chlorinated HAPs - Any method that has been

demonstrated to the Administrator’s

satisfaction.

Chlorine - Method 26A, as modified by

63.457(b)(5) of the rule.
Chapter 7 - NESHAP Requirements

Mechanical Pulping, Secondary

Fiber, and Non-wood Fiber Mills

Pulping System Vents

98

Continuous

monitoring is

required unless a

mill complies by

eliminating all use

of chlorine or

chlorinated

compounds as

bleaching agents.

These same tests

are required as

part of the initial

performance test.

How does a mill demonstrate continuous compliance with the

bleaching standards?

For chlorinated HAPs, a continuous monitoring system must measure

either emissions, or control device or process operating parameters. The

monitoring, reporting, and recordkeeping requirements are summarized in

Figure 25.

In addition, the mill must conduct periodic inspection and maintenance of

all enclosures and closed-vent systems. These requirements are explained

below. The mill must maintain a site-specific inspection plan for the

enclosures and closed-vent system. Records of repairs based on the

inspections must also be kept.

If the System has... Then Inspect... And Report...

And Keep

Records of...

Enclosure opening Visually inspect every 30

days to ensure closed and

sealed

Any exceedences of the

closed-vent standard in

quarterly reports. If no

exceedences occur, submit

semi-annual reports.

All visual checks and

any repairs

Annually demonstrate 

negative pressure

Same as above All pressure tests

Closed-vent system Visually inspect every 30

days for visible defects

Same as above All visual checks and

repairs

Positive pressure

closed-vent system

Annually demonstrate no

detectable leaks (less than

500 ppmv)

Same as above All leak tests

Bypass line valve Inspect every 30 days to

ensure valve is in a closed

position and vent stream is

not diverted through

bypass line

Same as above All visual checks and

repairs

Note: These are the same requirements as for kraft mills (presented on

page 57).
99

Figure 25.

How Does a Kraft Mill Demonstrate Continuous Compliance with Emission Limits for Chlo

If a Mill Chooses This

Technique to Comply

With This Alternative

Emission Limit...

Continuously Monitor These

Parameters... Report This Information... And Keep These 

Gas scrubber to reducechlorinated HAPemissions by 99% byweight or to achieve anoutlet mass emissionrate  0.002 pounds

chlorinated HAPs perton oven-dried pulp

pH or oxidation/reduction potential ofeffluent

Semi-annual emissions and

continuous monitoring performancereport

If exceedences occur, then quarterly

reports are required(40 CFR 63.10(e))

pH or oxidation/reeffluent

Vent gas inlet flow rate Same as above Vent gas inlet flow Scrubber liquid influent flow rate Same as above Scrubber liquid in

Gas scrubber to achievean outlet concentrationof chlorinated HAPs10 ppmv

Chlorine concentration at the outlet ormeasure all three of the following

parameters

Same as above Chlorine concentr

following

pH or oxidation/reduction potential ofeffluent

Same as above pH or oxidation/re

effluent

Vent gas inlet flow rate Same as above Vent gas inlet flowScrubber liquid influent flow rate Same as above Scrubber liquid in

Any control deviceother than a gasscrubber or processmodifications

Determine appropriate monitoringparameter values during the initialperformance testa

Same as above Parameters approv

a As specified in 40 CFR Part 63.453(n)

Note: This is the same figure as the one presented on page 73.
100

The Cluster Rules do

NOT represent all of

the air and water

pollution regulation

of the pulp and paper

industry.

Chapter 8 - Other Federal Regulations Affecting

Pulp and Paper Mills

The Cluster Rules do not represent all of the air and water pollution

regulation of the pulp and paper industry. Pulp and paper mills are subject

to additional air requirements under the CAA; additional water requirements

under the Clean Water Act; and other Federal, State and local laws not

associated in any way with the Cluster Rules.

Federal regulations affecting the pulp and paper industry include:

 National Ambient Air Quality Standards (NAAQS)

 Kraft Mill New Source Performance Standards (NSPS)

(40 CFR 60, Subparts B and BB)

 Industrial Boilers NSPS (40 CFR 60, Subparts D, Db, and

Dc)

 Gas-Fired Turbines NSPS (40 CFR 60, Subpart GG)

• NESHAP (40 CFR 63, Subpart MM)

 Prevention of Significant Deterioration (PSD)/New Source

Review (NSR)

 National Pollutant Discharge Elimination System (NPDES)

Related Statutes and Regulations

 Spill Prevention Control and Countermeasure (SPCC) Plans

(40 CFR 112)

 Notice of Discharge of Reportable Quantities of Hazardous

Substances (40 CFR 116 and 117)

 Resource Conservation and Recovery Act (RCRA)

 Emergency Planning and Community Right-to-Know Act

(EPCRA)/Comprehensive Environmental Response,

Compensation and Liability Act (CERCLA)
Chapter 8 - Other

Regulations

101

BACT = best

available control

technology

LAER = lowest 

achievable emissions

rate

8.1 What other Federal air regulations affect the pulp

and paper industry?

Federal air regulations affecting the pulp and paper industry are shown

below.

The Following Air

Regulation... Affects... By...

NAAQS Energy generation at

pulp and paper mills

Controlling NOx, PM,

VOC,a

 and SO2 as part

of the state

implementation plans

NSPS

40 CFR 60, Subpart B Kraft pulp mills Controlling PM and

TRS at existing sources

under state regulations. 

State regulations are

based on EPA

guidelines.

40 CFR 60, Subpart BB Kraft pulp mills Controlling PM and

TRS

40 CFR 60, Subpart D,

Db, and Dc

Industrial boilers Controlling PM, NOx,

SO2

40 CFR 60, Subpart GG Gas-fired turbines Controlling PM, SO2,

NOx

NESHAP Chemical recovery

processes at kraft,

soda, sulfite, and

standalone semichemical pulp mills

Controlling gaseous

organic and metal HAP

PSD/NSR Pulp and paper mills

installing new or

modified equipment

Requiring a

pre-construction permit

that imposes emission

limitations based on

BACT or LAER for

criteria pollutants for

which there is a

significant emission

increase.
Chapter 8 - Other

Regulations

102

National Ambient Air Quality Standards (NAAQS) have been established

for six criteria pollutants. Pulp and paper mills are potential sources of

particulate matter (PM), ozone precursors (volatile organic compounds

[VOCs] and nitrogen oxides [NOx]), and sulfur dioxide (SO2). Each State

must develop a State Implementation Plan (SIP) to identify sources of air

pollution and to determine what actions are necessary to achieve attainment

with the NAAQS for all criteria pollutants. The SIP contains emission

regulations that may affect the pulp and paper industry, including emission

limitations and standards and pre-construction permitting requirements

(e.g., New Source Review [NSR], Prevention of Significant Deterioration

[PSD]).

Kraft Mill New Source Performance Standards (NSPS) (40 CFR 60,

Subpart BB). The majority of kraft mills in operation are currently

regulated under the kraft mill NSPS (40 CFR Subpart BB) or State

regulations for existing sources promulgated under Section 111(d) of the

Act (40 CFR 60, Subpart B). The kraft mill NSPS sets emission limits for

particulate matter and TRS for recovery furnaces, smelt dissolving tanks,

lime kilns, digester systems, brown stock washer systems, multiple effect

evaporators, black liquor oxidation systems, and condensate stripper

systems. See page 79 for a more detailed discussion of the kraft mill NSPS,

as this regulation applies to kraft mills only.

Industrial Boilers NSPS (40 CFR 60, Subparts D, Db, and Dc) and GasFired Turbines NSPS (40 CFR 60, Subpart GG). Almost all pulp and

paper facilities have boilers and turbines for generating electricity and

steam. Newer combustion units may be subject to regulation under one of

these rules which set emissions limits for particulate matter, nitrogen

oxides, and sulfur dioxide.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

(40 CFR 63, Subpart MM). The NESHAP for chemical recovery

combustion sources at kraft, soda, sulfite, and semi-chemical pulp mills (40

CFR 63, Subpart MM) establishes emission limits for gaseous organic and

metal HAP. Subpart MM applies to all existing and new kraft, soda, sulfite,

and stand-alone semi-chemical pulp mills with chemical recovery processes

that involve the combustion of spent pulping liquor.
Chapter 8 - Other

Regulations

103

NPDES = National

Pollutant Discharge

Elimination System

8.2 What other Federal water regulations affect the

pulp and paper industry?

Federal water regulations affecting the pulp and paper industry are shown

below:

The Following Water

Regulation... Affects... By...

NPDES: Technology and

water quality-based

limitations

Direct-discharging of

pollutants into

navigable waters

Setting effluent

limitations on pollutants

based on available

technology and intended

use of receiving

waterbody; also sets

monitoring and

reporting requirements

Pretreatment program Indirect-discharging

of pollutants to

publicly-owned

treatment works

(POTWs)

Setting pollutant

discharge limits to

POTWs

Storm water permit

application

Any facility Establishing pollution

prevention plans and

best management

practices (BMP)

Section 110 of CWA

(40 CFR 110)

Any facility Prohibiting oil

discharges

Spill Prevention Control

and Countermeasure

(SPCC) (40 CFR 112)

Oil storing/

consuming facilities

Requiring a spill

prevention and control

plan, reporting, plan

updates, and training

obligations

Notice of Discharge of

Reportable Quantities of

Hazardous Substances

(40 CFR 116 and 117)

Any facility Requiring reporting of

designated hazardous

substance discharges to

U.S. government

following the

Department of

Transportation

regulations
Chapter 8 - Other

Regulations

104

The acronyms are

defined on the next

page in Figure 26.

The applicability of

these standards is

explained on

page 106 in

Figure 27.

National Pollutant Discharge Elimination System (NPDES) Program

(Clean Water Act, Section 402). The NPDES program controls direct

discharges into navigable waters. The scope of this program is quite broad,

and most point source discharges associated with a pulp and paper mill will

be subject to NPDES permitting requirements. The effluent limitations

guidelines and standards and requirements for direct discharging mills are

presented in the table below. The applicability of these standards is more

fully explained in Figure 27.

These Clean Water Act Standards

Apply...

For These Mill Types or

Production Operations...

BAT,

PSES, and

PSNS

BPT,

BCT,

NSPS BMP

Dissolving Kraft X X X

Bleached Papergrade Kraft

and Sodaa

XXX

Unbleached Kraft X X X

Dissolving Sulfite X X X

Papergrade Sulfitea XXX

Semi-chemical X X X

Mechanical X

Non-wood Chemical X X

Secondary Fiber Deink X

Fine and Lightweight Papers

from Purchased Pulp

X

Tissue, Filter, Non-Woven,

and Paperboard from

Purchased Pulp

X

a

 The effluent limitations guidelines and standards for these subcategories were revised in

 the Cluster Rules.
Chapter 8 - Other

Regulations

105

Figure 26.

A Guide to the Acronyms for Technology-Based Water Standards

Acronym Definition Description of Standard

PSESa Pretreatment Standards for Existing

Sources

Industry-by-industry pretreatment

standards for existing sources that

discharge their wastewater indirectly

(i.e., to a POTW).

PSNSa Pretreatment Standards for New

Sources

Industry-by-industry pretreatment

standards for new sources that

discharge their wastewater indirectly

(i.e., to a POTW).

BPT Best Practical Control Technology

Currently Available

A baseline standard, applicable in all

circumstances

BCT Best Conventional Pollutant Control

Technology

More stringent than BPT. Only

applies if certain cost tests are met. 

Must be “cost-reasonable.” See

51 FR 24,974-24,976 (July 9, 1986),

for EPA’s BCT methodology.

BAT Best Available Technology

Economically Achievable

A standard similar to BPT/BCT, but

with cost concerns playing a lesser

role. A “best of the best” standard.

BMP Best Management Practices Designed to prevent or contain leaks

and spills of pulping liquor, soap,

and turpentine, and to control any

intentional diversions of these

substances.

NSPS New Source Performance Standards Applicable to new direct discharge

sources, as defined in 40 CFR 122.2.

a Although the categorical standards in 40 CFR Part 430 cover kraft pulp mills, most kraft pulp mills are direct

dischargers subject to NPDES permit requirements and not the pretreatment standards.
Chapter 8 - Other

Regulations

106

Figure 27.

Applicability of Technology-Based Standards

If a Mill

Discharges These

Pollutants...

To These Direct

Receivers

And the Mill is

Classified as an...

Then the

Required

Standards

That

Apply

are...

Conventional

pollutants

Surface waters Existing source BPT or

BCT

Toxic and

conventional

pollutants

Surface waters Existing source BAT

Any pollutants Surface waters New source NSPS

Any pollutants POTWs Existing source PSES

Any pollutants POTWs New Source PSNS

Source: 40 CFR 125.3

Spill Prevention Control and Countermeasure (SPCC) Plans

(40 CFR 112). This regulation applies to all facilities that store or use oil or

oil products, and which because of their location, could reasonably be

expected to discharge oil into navigable waters of the United States. Such

facilities are required to prepare a SPCC plan.

Notice of Discharge of Reportable Quantities of Hazardous Substances

(40 CFR 116 and 117). This regulation defines the discharges into

navigable waters of the United States that must be reported to appropriate

agencies of the U.S. Government. This requirement does NOT apply to

discharges covered by a facility’s NPDES permit.
Chapter 8 - Other

Regulations

107

TRI = Toxic

Release Inventory

BIF = Boilers and

Industrial

Furnaces (40 CFR

266, Subpart H)

8.3 What Federal hazardous wastes regulations

affect the pulp and paper industry?

Federal hazardous wastes and emergency planning regulations affecting the

pulp and paper industry are shown below:

The Following

Hazardous

Waste

Regulation... Affects... By...

RCRA Black liquor at

pulp mills

Requiring reclamation and reuse

of black liquor

Steam stripper

systems

Exempting on-site combustion

of concentrated methanol

condensates derived from steam

stripper overhead gases from the

BIF regulation

EPCRA/CERCLA Pulp mills  Requiring annual reporting

of discharges (TRI Form R

reports) for certain pollutants

 Requiring mills to provide

information on chemicals

used in the bleach plant

 Requiring mills to report

emergency spills or off-site

releases (air, water, or solid

wastes)

Resource Conservation and Recovery Act (RCRA). Most RCRA

requirements are not industry specific but apply to any facility that

transports, treats, stores, or disposes of hazardous wastes. The pulping

process generally does not generate significant RCRA-related hazardous

waste streams. However, handling of black liquor can create RCRA-related

concerns. Black liquor is exempt from regulation as a solid waste under

40 CFR 261.2(e) and Table 1, 261.4(a)(6), but only if the black liquor is

reclaimed in a recovery furnace and reused in the pulping process. 

Therefore, potential liquor spills that are not reused in the process, such as

leaks from surface impoundments used to store black liquor prior to

recovery will be an issue for RCRA compliance assessment.
Chapter 8 - Other

Regulations

108

Concentrated steam

stripper

condensates consist

primarily of

methanol which can

be burned as a fuel.

RCRA/Boilers and Industrial Furnaces (BIF) regulation (40 CFR 266,

Subpart H). One of the options for controlling emissions from kraft

pulping process condensates is to steam strip HAPs from the condensate

streams. The vent gas from the steam stripper is required to be sent to a

combustion device for destruction. If the methanol in the steam stripper

vent gas were concentrated, using a rectification column, the concentrated

condensate could be burned as a fuel. However, the concentrated methanol

condensate could be identified as hazardous waste under RCRA because it

exhibits the ignitability characteristic. Boilers burning such a hazardous

waste fuel would ordinarily be required to comply with the emission

standards for boilers and industrial furnaces burning hazardous waste.

Because the rectification practice would save energy, not increase

environmental risk, and would provide a cost savings, combustion sources

at kraft mills that burn condensates derived from steam stripper overhead

vent gases are excluded from RCRA. The exclusion applies only to the

condensates generated from the steam stripper methanol rectification

process and only to combustion units located at the facility generating the

condensate stream.

Emergency Planning and Community Right-to-Know Act (EPCRA)/

Comprehensive Environmental Response, Compensation, and Liability

Act (CERCLA). Section 313 of EPCRA requires pulp mills to submit a

Toxic Release Inventory (TRI) report to EPA each year. These reports,

referred to as Form R, include the amounts of toxic chemicals that the

facility releases into the environment (i.e., air, water, and land) both

routinely and as a result of accidents. In general reported releases would

include releases of toxic chemicals from pulp mill process vent air

emissions and from mill wastewater discharges. Data must be provided for

any of the more than 600 listed toxic chemicals that are manufactured,

processed, or otherwise used above the reporting threshold.
Chapter 8 - Other

Regulations

109

More regulations

are coming!

Five NESHAP for

combustion

sources are

scheduled for

2001.

Effluent limitations

guidelines and

standards

scheduled for

2001-2002.

8.4 What upcoming regulations will affect pulp and

paper mills?

Pending regulations that will affect the pulp and paper industry include:

 NESHAP for Combustion Sources. EPA plans to publish

several NESHAP that will affect power boilers, process

heaters, gas turbines, reciprocating internal combustion

engines, and incinerators.

 Effluent Limitations Guidelines and Standards. EPA plans

to publish revised effluent limitations guidelines and

standards for additional subcategories in the near future. 

These include: dissolving kraft; dissolving sulfite;

unbleached kraft; semi-chemical; mechanical pulp; nonwood chemical pulp; secondary fiber deink; secondary fiber

non-deink; fine and lightweight fibers from purchased pulp;

and tissue, filter, non-woven, and paperboard from purchased

pulp.

Pending water regulations consist of EPA proposing effluent limitations

guidelines and standards for the pulp and paper industry subparts that were

not included in the Cluster Rules. And finally, EPA is considering whether

pulp mill wastewater treatment system sludges are to be considered a

hazardous waste and subject to RCRA Subtitle C. Since the effluent

guidelines address concerns about chlorine containing compounds, it is

expected that there will be no change in the exemption of pulp mill sludges

from being classified as a hazardous waste.
EPA Form 2220-1 (Rev. a-77) PREVIOUS EDITION IS OBSOLETE

TECHNICAL REPORT DATA

(please read instructions on the reverse before completing)

1. REPORT NO.

EPA-456/R-01-002

2. 3. RECIPIENT'S ACCESSION NO.

4. TITLE AND SUBTITLE

Pulp and Bleaching System NESHAP for the Pulp and Paper

Industry: A Plain English Description

5. REPORT DATE

September 2001

6. PERFORMING ORGANIZATION CODE

7. AUTHOR(S) 8. PERFORMING ORGANIZATION REPORT NO.

9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.

 10203A

11. CONTRACT/GRANT NO.

68-D6-0011

12. SPONSORING AGENCY NAME AND ADDRESS

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

13. TYPE OF REPORT AND PERIOD COVERED

Final Report

14. SPONSORING AGENCY CODE

15. SUPPLEMENTARY NOTES

16. ABSTRACT

National emission standards for hazardous air pollutants (NESHAP) were

promulgated for the pulp and paper industry under authority of Section

112(d) of the Clean Air Act as amended in 1990. This document provides

plain English descriptions of the pulping and bleaching processes, the

requirements of the NESHAP (Subpart S), the scope of effluent limitations

guidelines and standards and additional references and sources of

information about pulp and paper mills.

17. KEY WORDS AND DOCUMENT ANALYSIS

a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group

Air pollution

 MACT

 NESHAP subparts

Pulp and paper mills

Hazardous air pollutant

 Pulp Mills

Paper mills

Air pollution

 MACT

 NESHAP subparts

Pulp and paper mills

Hazardous air pollutant

 Pulp Mills

Paper mills

13b

18. DISTRIBUTION STATEMENT

Unlimited

19. SECURITY CLASS (This Report)

UNCLASSIFIED

21. NO. OF PAGES

167

20. SECURITY CLASS (This Page)

UNCLASSIFIED

22 PRICE