Multi-Pollutant Sector Rule for the Pulp and Paper Industry

Response to Comments Received on

Proposed Information Collection Request

(Published on June 23, 2010)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

Natural Resources and Commerce Group

Research Triangle Park, NC 27711

November 16, 2010
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Table of Contents

Page

1.0 Introduction..........................................................................................................................1

2.0 Requirement to Collect Information ....................................................................................2

3.0 Burden of the Proposed ICR................................................................................................7

3.1 Streamlining the ICR .............................................................................................. 7

3.2 Time to Complete the ICR...................................................................................... 9

3.3 Timing of the ICR................................................................................................. 12

3.4 Inventory Requirement ......................................................................................... 13

3.5 Process Flow Diagrams......................................................................................... 14

3.6 HAP Additives...................................................................................................... 15

4.0 NCASI Emissions Information..........................................................................................17

5.0 Power Boiler Information ..................................................................................................18

6.0 State-Only Permit Limits...................................................................................................20

7.0 Potential Changes...............................................................................................................22

8.0 Technical Clarifications.....................................................................................................23

8.1 Nominal Throughput Data .................................................................................... 23

8.2 Emission Calculation Method Code ..................................................................... 23

9.0 Other Specific Comments..................................................................................................25

9.1 Equip Detail Tab................................................................................................... 25

9.2 Kraft Condensates Tab.......................................................................................... 26

9.3 PCC Tab................................................................................................................ 26

9.4 Emissions Test Data Tab ...................................................................................... 26

9.5 Segregation of CBI ............................................................................................... 27

10.0 CEMS Data ........................................................................................................................28

List of Tables

Page

Table 1. List of Commenters on Proposed ICR for Pulp and Paper Sector NSPS and 

NESHAP Residual Risk and Technology Review...............................................................1
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Acronyms and Abbreviations

ADTP Air-dried ton(s) of pulp

AEI Annual emissions inventory

AF&PA American Forest & Paper Association

BACT Best available control technology

BLS Black liquor solids

Btu British thermal unit(s)

CAA Clean Air Act

CATs Californians for Alternatives to Toxics

CBD Center for Biological Diversity

CBI Confidential business information

CEMS Continuous emissions monitoring system

CISWI Commercial/industrial solid waste incinerator(s)

CO Carbon monoxide

dscf Dry standard cubic foot (feet)

EPA U.S. Environmental Protection Agency

FR Federal Register

GHG Greenhouse gas

gpm Gallon(s) per minute

gr Grain(s)

HAP Hazardous air pollutant(s)

hr Hour(s)

ICR Information collection request

lb Pound(s)

MACT Maximum achievable control technology

MM Million

NAAQS National ambient air quality standards

NCASI National Council for Air and Stream Improvement, Inc.

NCG Noncondensible gas

NEI National Emissions Inventory

NESHAP National emissions standards for hazardous air pollutant

NOI Notice of intent

NOX Nitrogen oxides

NSPS New source performance standards

OSHA U.S. Occupational Safety & Health Administration

PCC Precipitated calcium carbonate

PM Particulate matter

PSD Prevention of Significant Deterioration

QA Quality assure

RCRA Resource Conservation and Recovery Act

RICE Reciprocating internal combustion engine(s)

RTR Residual risk and technology review

SARA Superfund Amendments and Reauthorization Act

SDT Smelt dissolving tank

SO2 Sulfur dioxide

SOG Stripper off gas

TRS Total reduced sulfur
1

1.0 Introduction

On June 23, 2010, the U.S. Environmental Protection Agency (EPA) requested comment 

(75 FR 35792) on a proposed information collection request (ICR) for the pulp and paper multipollutant sector rule (EPA ICR No. 2393.01). The sector rule includes both the new source 

performance standards (NSPS) review and the national emission standards for hazardous air 

pollutants (NESHAP) residual risk and technology review (RTR). The respondents affected by 

this action are owners/operators of mills that are major sources of hazardous air pollutant (HAP) 

emissions, as defined in 40 CFR 63.2. These major source mills include: 

 Mills that perform chemical wood pulping (kraft, soda, sulfite, or semichemical)

 Mills that perform mechanical, groundwood, secondary fiber, and non-wood pulping

 Mills that perform bleaching

 Mills that manufacture paper or paperboard products

A 60-day comment period (ending August 23, 2010) was provided for the public to 

submit comments to EPA regarding the proposed new data collection. A total of three comments 

were received by EPA regarding the proposed information collection request. (See 

www.regulations.gov, docket ID no. EPA-HQ-OAR-2007-0544, for the complete comments.) 

Table 1-1 lists the names of the commenters, the commenters’ affiliations, and the docket item

number assigned to each of the comments submitted to EPA. Where one commenter (0011) 

endorsed the comments by another commenter (0009), the docket item numbers associated with 

both commenters were presented together in the comment summary.

Table 1. List of Commenters on Proposed ICR for Pulp and Paper Sector NSPS and 

NESHAP Residual Risk and Technology Review

Docket No.

EPA-HQ-OAR2007-0544 Date Received Commenter Name and Affiliation

0009 08/23/2010

Timothy G. Hunt

Senior Director, Air Quality Programs

American Forest & Paper Association (AF&PA)

0010 08/23/2010

Stephen E Woock

EHS&S Federal Regulatory Affairs Manager

Weyerhaeuser Company

0011 08/23/2010

Roy McAuley

Executive Director

Alabama Pulp & Paper Council

This document summarizes the substantive comments received by EPA on the proposed 

ICR and presents EPA’s response to each of those comments. The comment summaries and 

responses are grouped by topic in the following sections.
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2.0 Requirement to Collect Information

Comment: Commenters 0009 and 0011 noted that in the Federal Register (FR) notice of 

the proposed ICR, EPA asserts that the information being solicited in the industry questionnaire 

is necessary in order to meet Clean Air Act (CAA) requirements. The two commenters argued 

that EPA is substantially overstating what it is required to do under the CAA. According to the 

commenters, the questionnaire is directed, to a significant extent, at obtaining information to

support EPA rulemaking that is not required and that, in the context of the large number of 

additional CAA requirements being imposed on the industry, should not be undertaken at this 

time. Thus, the commenters argued that much of the paperwork burden EPA proposes to impose 

through the proposed ICR is unnecessary. Commenter 0011 also stated that some of the 

information requested by EPA is outside the scope of the CAA.

The commenters noted that the preamble for the proposed ICR (75 FR 35794) states that 

“Section 111(b)(1)(B) of the CAA mandates that EPA review and, if appropriate, revise existing 

NSPS at least every eight years....Another review of the kraft pulp mill NSPS is required under 

the CAA.” According to the commenters, this statement ignores the fact that CAA section 

111(b)(1)(B) also states that “the Administrator need not review any such standard if the 

Administrator determines that such review is not appropriate in light of readily available

information on the efficacy of such standard.” The commenters noted that there are no other 

qualifiers on the Administrator’s decision not to review existing NSPS. As a result, the 

commenters argued that EPA has almost unlimited discretion to decide not to do a periodic 

review of the Kraft Pulp Mill NSPS. According to the commenters, stating that EPA is 

“required” to review the kraft pulp mill NSPS is claiming a justification for the ICR that does not 

really exist.

The commenters stated that EPA has already been provided a great deal of information 

about emissions from kraft pulping vents and kraft pulp mill chemical recovery systems, as well 

as the emission controls used for these sources, from the Subparts S and MM NESHAP 

rulemakings and from compliance demonstrations and continuous monitoring required by those 

regulations. The commenters noted that EPA has also been considering these emissions recently 

in its ongoing evaluation of residual risk for pulping and chemical recovery sources. The 

commenters argued that EPA could, on the basis of “readily available information,” determine 

that review of the kraft pulp mill NSPS, or a portion thereof, is not necessary.

The commenters noted that the existing NSPS require, among other things, collection and 

incineration of most sources of total reduced sulfur (TRS) compound emissions at kraft pulp 

mills and, thus, already require a high level of TRS reduction. The commenters further noted 

that the pulp and paper maximum achievable control technology (MACT) standards also require 

incineration, or similarly highly effective means, of controlling the organic gas streams from 

kraft pulp mills, which also contain TRS. Consequently, the commenters argued that EPA 

already has sufficient information to conclude that there is no more effective technology

available for controlling pulp mill TRS emissions.

The commenters acknowledged that particulate matter (PM) control technology has 

improved since the kraft pulp mill NSPS were promulgated, but noted that EPA has since that 

time promulgated stringent PM emission limits in the MACT standards for pulp mill combustion 
3

sources as a surrogate for metal HAP. The commenters noted that these MACT standards are 

much lower than the NSPS limits--0.015 vs. 0.044 grain per dry standard cubic foot (gr/dscf) for 

recovery furnaces, 0.12 vs. 0.2 pound per ton of black liquor solids (lb/ton BLS) for smelt 

dissolving tanks (SDTs), and 0.01 vs. 0.067 or 0.13 gr/dcsf for lime kilns. As a result, the 

commenters argued that EPA should conclude that review of the NSPS PM limits would not be 

productive.

The commenters further argued that EPA is under no obligation to add pollutants emitted 

by kraft pulp mills but not covered by the kraft pulp mill NSPS to those already regulated by the 

NSPS. According to the commenters, nothing in CAA section 111 requires that NSPS cover all 

pollutants emitted by a source, and the commenters stated that EPA has never interpreted it that 

way. The commenters cited the following three references as support for this position: (1) 74 

FR 51950, 51957 (Oct. 8, 2009) “The statutory scheme thus provides EPA with significant 

discretion to determine which pollutant(s) should be regulated under the NSPS.”); (2) National 

Lime Association vs. EPA, 627 F.2d 416, 426 (D.C. Cir. 1980) (observing that, while “lime 

plants were determined to be sources of nitrogen oxides, carbon monoxide, and sulfur dioxide as 

well as particulates, standards of performance were proposed and ultimately promulgated only 

with respect to particulate matter.”); (3) 70 FR 9706, 9711 (Feb. 28, 2005) (where EPA declined 

to set nitrogen oxide (NOX) limits for boilers below 100 million British thermal units per hour 

(MMBtu/hr) heat input, based on current emission levels, available technologies, and costs). 

According to the commenters, before expanding the kraft pulp mill NSPS to cover additional 

pollutants, EPA must justify its departure from its prior decisions about which pollutants the 

NSPS should cover.

The commenters argued that the FR preamble glosses over the fact that, even if the CAA 

required EPA to review the kraft pulp mill NSPS, the questionnaire addresses all pulp, paper, and 

paperboard mills, including pulp mills that use processes other than the kraft process subject to 

the kraft pulp mill NSPS, and mills that do not do any pulping or only pulp wastepaper. The 

commenters concluded that, for about 3/4 of the mills that would be required to fill out the 

questionnaire, EPA’s stated reason for collecting information to review NSPS is not applicable.

The commenters argued that EPA is not under any legal obligation to expand the current 

NSPS to cover other types of mills. The commenters stated that EPA has a great deal of 

discretion to choose source categories to be regulated through NSPS and to define which 

emission units within a source category will be subject to emission standards. According to the 

commenters, the CAA leaves to the EPA Administrator the determination of whether, “in his 

judgment,” the source category “causes, or contributes significantly to, air pollution which may 

reasonably be anticipated to endanger public health or welfare.” The commenters stated that 

EPA has made the judgment in the past that other types of pulp mills (such as those use the 

sulfite process or thermo-mechanical pulp mills) and non-integrated paper and paperboard and 

secondary fiber mills do not warrant development of NSPS. The commenters were not aware of 

any basis for changing that decision. The commenters noted that the emissions from those other 

types of pulp and paper mills are lower now than they were in the past, because of MACT 

standards and numerous other air pollution control regulations. (The commenters further noted

that sulfite process pulp mills have largely disappeared—the commenters believe there may only 

be five sulfite mills still operating in the U.S.—which the commenters argued makes them even 

less of a target for development of categorical NSPS limitations.)
4

The commenters also argued that EPA’s claimed basis for needing information to review

and revise NESHAP is overstated. The commenters specifically pointed to the FR preamble 

statement that “recent case law and legal petitions suggest the need to review the pulp and paper 

NESHAP” and that EPA needed “to make the NESHAP consistent with CAA precedent 

established in recent judicial rulings.” (75 FR 35,794) According to the commenters, these 

statements appeared to be in direct conflict with the judicial review and emission standard review 

provisions that Congress included in the CAA. The commenters stated that under CAA section 

307, NESHAP must be challenged through a petition for review filed in the courts of appeals 

within 60 days after publication of the rule. The commenters noted that neither the Subpart S nor 

the Subpart MM NESHAP was challenged in that manner. According to the commenters, EPA 

is under no obligation to conform these regulations to principles announced in some cases 

involving challenges to other NESHAP. The commenters further noted that Subparts S and MM 

have been in effect for many years, and have been relied on by pulp and paper mills in making 

their compliance expenditures and other capital investments. The commenters stated that 

Congress established a system designed to provide certainty and clarity: anyone objecting to a 

rule must challenge it within 60 days; otherwise it remains in effect. According to the 

commenters, there is no provision for continued revision of the MACT standards in Subparts S 

and MM. The commenters stated that those standards are to remain in place unless EPA 

determines more stringent limits are necessary to avoid unacceptable residual risk under CAA 

section 112(f), or EPA determines that there have been significant advances in hazardous air 

pollutant control technology, pursuant to CAA section 112(d)(6).

The commenters argued that the preamble glosses over the fact that, even if EPA were 

required to review existing pulp and paper NESHAP to address prior case law, that would not 

provide any justification for seeking information from the majority of the estimated 386 mills to 

which the questionnaire would be directed, since most of those mills are not currently subject to 

Subparts S or MM. The commenters indicated that, at a minimum, the ICR needs to clearly state 

that the major paperwork burdens on those mills are being imposed in order to support a further 

expansion of NESHAP, if that is EPA’s intention. According to the commenters, a better 

resolution would be for EPA to exercise its discretion not to expand the NESHAP affecting the 

industry at this time, and, therefore, not to send the questionnaire to mills not currently covered 

by Subparts S or MM, especially in light of all of the other regulatory burdens facing the industry

at this time (not to mention EPA resource constraints).

Response: Three federal emission standards are the subject of the pulp and paper

information collection:

Standard Promulgation date

Standards of Performance for Kraft Pulp Mills (40 CFR part 60, 

subpart BB)

1978 

(reviewed 1986)

National Emission Standards for Hazardous Air Pollutants from 

the Pulp and Paper Industry (40 CFR part 63, subpart S)

1998

National Emission Standards for Hazardous Air Pollutants for 

Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, 

and Stand-Alone Semichemical Pulp Mills (40 CFR part 63, 

subpart MM

2001
5

Section 111(b)(1)(B) of the CAA mandates that EPA review and, if appropriate, revise 

existing NSPS at least every 8 years. Section 112(f)(2) of the CAA directs EPA to conduct risk 

assessments on each source category subject to maximum achievable control technology

(MACT) standards and determine if additional standards are needed to reduce residual risks. 

Section 112(d)(6) of the CAA requires EPA to review and revise the MACT standards, as 

necessary, taking into account developments in practices, processes, and control technologies. 

The section 112(f)(2) residual risk and section 112(d)(6) technology reviews are to be done 8 

years after NESHAP promulgation. Thus, all three of the emission standards listed above are 

due for review according to dates set forth in the CAA. While we understand that the pulp and 

paper industry is currently facing a large number of additional CAA requirements, EPA cannot 

base its decisions (whether about issuing a survey or developing a rulemaking) on what other 

rulemakings are underway for a particular industry, but on what is required under the CAA. 

It should be noted that EPA has entered into a proposed Consent Decree (to address a 

lawsuit filed by Sierra Club) that would require proposal of the subpart S RTR by June 15, 2011 

and final action by December 16, 2011. In addition, EPA has received a notice of intent (NOI) to 

sue from Californians for Alternatives to Toxics (CATs) and the Center for Biological Diversity 

(CBD), contending that EPA has failed to review the NSPS for kraft pulp mills within the 

statutory deadline under CAA section 111(b)(1)(B). The EPA received a petition for rulemaking 

in January 2009 requesting that EPA revise various NESHAP, including the NESHAP for 

chemical recovery combustion sources at pulp mills, to make the NESHAP consistent with CAA 

precedent established in recent judicial rulings. Also, in December 2008, the U.S. Court of 

Appeals for the D.C. Circuit vacated the startup, shutdown, and malfunction provisions 

contained in the NESHAP General Provisions that apply to pulp and paper mills. To the extent 

that these legal actions need to be addressed in the pulp and paper NESHAP, EPA intends to 

collect the information needed to investigate potential rule revisions at the same time as 

collecting information for the CAA-required statutory reviews. 

In the context of NSPS review, we acknowledge that CAA section 111(b)(1)(B) states 

that “the Administrator need not review any such standard if the Administrator determines that 

such review is not appropriate in light of readily available information on the efficacy of such 

standard.” (emphasis added) However, up-to-date and readily available information are lacking. 

As discussed below, much of the information EPA has available for the pulp and paper industry

is nearly 20 years old. At present, EPA has no complete data base reflecting the post-MACT and 

post-effluent guidelines configurations of pulp and paper emission units and air pollution control 

systems. The EPA is seeking additional updated information to use in the residual risk and 

technology review (RTR) regulatory analyses required under CAA sections 112(d) and 112(f)(2).

There is considerable overlap in the emission units regulated under NSPS subpart BB and the 

two NESHAP for the pulp and paper industry. As a matter of administrative efficiency, EPA 

intends to use a single collection of information to seek updated information for use in the RTR 

for both NESHAP and in reviewing the NSPS (as required under CAA section 111(b)). 

We disagree that the industry has already provided sufficient information to EPA to 

perform the required regulatory reviews. We acknowledge that the industry provided volumes of 

useful information for purposes of NESHAP development. However, this information used to 

support the subpart S and MM rulemakings is now outdated and may no longer be representative 

of the latest post-MACT developments in practices, processes, and control technologies for the 
6

pulp and paper industry. (The survey collecting pre-MACT information was sent out in 

February 1992.) Further, EPA’s Office of Air Quality Planning and Standards (OAQPS) does 

not receive the results from most compliance demonstrations and continuous monitoring being 

requested in the ICR (e.g., because these data, if submitted at all, are typically submitted to State 

agencies delegated authority to administer federal standards). The preliminary information that 

EPA has received from some mills recently for its evaluation of residual risk for the subpart S 

RTR is only a small fraction of the information needed to assess all of the required regulatory

reviews. Thus, the information EPA has in hand is not sufficient for performing thorough 

regulatory reviews. 

The EPA believes that the most appropriate and efficient way to assess the latest 

technological developments for the pulp and paper industry is to gather updated information 

through a CAA section 114 ICR. The survey would also reveal if there have been no advances 

in technologies (as the commenters assert). Information collected directly from pulp and paper 

mills will have the greatest practical utility for purposes of performing the RTR and NSPS 

reviews as information from the affected industry will contain the most up-to-date, accurate, and 

reliable equipment and operational data for each mill. CAA section 114(a) states that the 

Administrator may require any owner or operator subject to any requirement of this Act to: (A) 

Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such 

monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions 

(in accordance with such procedures or methods, at such locations, at such intervals, during 

such periods, and in such manner as the Administrator shall prescribe); (E) keep records on 

control equipment parameters, production variables or other indirect data when direct 

monitoring of emissions is impractical; (F) submit compliance certifications in accordance with 

section 114(a)(3); and (G) provide such other information as the Administrator may reasonably 

require.

We do not wish to prejudge the outcome of our regulatory reviews prior to collecting 

information upon which to base these reviews. Without more information, we cannot at present 

time conclude that a review of the NSPS emission limits is unnecessary, nor can we conclude 

that the emission limits should be changed. The aforementioned NOI asserted that EPA must 

provide standards for all air pollutants that endanger public health and welfare when reviewing 

and revising the NSPS for kraft pulp mills. We will not know whether if is prudent to extend the 

NSPS to additional pollutants until we have collected and reviewed updated information to make 

definitive determinations. 

Mills that do not manufacture kraft pulp are included in the pulp and paper survey

because they are part of the subpart S source category for which MACT standards were 

considered, and some of these mills are also part of the subpart MM source category. These 

mills are included in the survey for RTR purposes. Some of these mills may be true area sources 

of HAP emissions, and therefore exempt from the pulp and paper survey. Criteria for exemption 

from the pulp and paper sector survey are as follows: 

 The mill is not a “major source” or “synthetic area source” of HAP emissions, or

 The mill was not operational in 2009 (and remains closed), or 

 The mill does not produce pulp, perform bleaching, or serve as a primary manufacturer of 

paper or paperboard products.
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3.0 Burden of the Proposed ICR

3.1 Streamlining the ICR

Comment: Three commenters (0009, 0010, and 0011) recommended that EPA 

significantly streamline the survey. One commenter (0010) stated that EPA is seeking far more 

information—and overly detailed information—than is necessary, given the time period and the 

timing constraints that EPA feels it must address. Commenter 0010 suggested that EPA focus on 

the emissions data and emission units information, at least as a first pass at the survey. After 

EPA has completed evaluating those data, commenter 0010 indicated EPA could then target any 

additional specific mill processing and other information needed to focus the new regulations. 

Commenter 0010 noted that each of the regulations addressed by the ICR will be a follow-up 

regulatory review by EPA and are not original rulemakings in response to a new statutory

requirement. As a result, commenter 0010 argued the additional information EPA is seeking is 

largely unrelated, or at least unnecessary, to carry out the regulatory reviews that EPA is 

authorized to conduct. According to commenter 0010, much of the data and information (e.g., 

production and production information and capacities, detailed process diagrams and data, 

potential future changes) that the commenter thinks EPA should forego at least for the first round 

of the survey also tend to be confidential business information (CBI).

For those mills covered by Subparts S and MM, two commenters (0009 and 0011) 

recommended that EPA focus on requesting information as it pertains to emissions subject to 

Subpart S. Commenters 0009 and 0011 noted that EPA currently has proposed to enter into a 

consent decree with a deadline of June 15, 2011 to sign a RTR proposal for Subpart S. Based on 

conversations with EPA representatives, the two commenters expected that the survey will be 

issued to facilities in late 2010 or early 2011. Commenters 0009 and 0011 estimated it will take 

at least 2 months for EPA to compile and analyze the responses and do the final round of 

dispersion modeling with updated emissions inventory information. According to the two 

commenters, this would leave little time for the new information to be gathered by this survey to 

be meaningfully considered by the technical staff in their proposal and still allow for adequate 

review by EPA management. Therefore, commenters 0009 and 0011 recommended that EPA 

issue a more limited survey targeted toward Subpart S to try to meet its June 15 deadline, 

postponing any future information collection activities until after the Subpart S review is 

completed.

The two commenters noted that this approach would exclude data based on NSPS 

requirements and other information not related to the collection and control of HAP from 

processes covered under Subpart S. If facilities are only required to submit data applicable to 

Subpart S, commenters 0009 and 0011 indicated that chemical recovery combustion equipment, 

power boilers, and woodyard operations would be eliminated from the survey (based on the list 

of emission units listed in Attachment 1 of the survey instructions). According to the two 

commenters, this would reduce the burden of the ICR and allow EPA to focus on the data 

necessary for the Subpart S RTR it is trying to complete by June 15, 2011. To the extent that

EPA has specific data needs for data related to equipment not addressed directly by Subpart S 

(e.g., availability of power boilers used to incinerate organic HAP), commenters 0009 and 0011 

indicated that the industry would be willing to work with EPA to identify and provide the 

additional information, as they have in the past.
8

If EPA believes it cannot avoid conducting a review of the kraft pulp mill NSPS, on the 

basis of “readily available information,” commenters 0009 and 0011 recommended that EPA 

limit just to kraft pulp mills the distribution of those portions of the questionnaire relevant to 

NSPS review. The two commenters argued that sending the questionnaire to the hundreds of 

other mills would impose a major reporting burden.

Response: As explained above, there is considerable overlap in the emission units 

covered under subpart S, subpart MM, and NSPS subpart BB; there are statutory obligations 

under the CAA that EPA must fulfill for all three subparts; and it is more efficient for EPA to use 

one information collection to gather all of the information useful for performing all of the 

regulatory reviews. We understand the concerns that the commenters have regarding the large 

amount of information requested of them in such a short time. We are constrained by the 

consent decree deadline for subpart S RTR in setting the timeline for this survey. We have taken 

a number of steps to address the commenters concern and to streamline the survey. Several 

simplifying changes to the survey questions are noted throughout this document. More 

importantly, we have divided the survey into three parts based on equipment type (i.e., pulp and 

paper production units versus chemical recovery combustion units) with different submittal dates 

as follows: 

Part I - Mill Overview and Subpart S Data

a. One-page notification of true area source, non-operational, or non-applicable 

status (due in 20 days)

b. Completion of Part I data submittal (due in 30 days)

Part II - NEI Update (due in 100 days)

Part III - Chemical Recovery Combustion Sources (180 days)

Each part of the streamlined survey has a dedicated instruction document. In addition, 

we developed a survey overview document that contains information and attachments useful for 

all parts of the survey. The survey overview document includes an attached one-page notification 

form that mills may submit to indicate if the survey does not apply for their mill (e.g., because 

they are true area sources, were not operational in 2009, or do not manufacture primary pulp and 

paper products). Survey Parts I and II apply for all mills that are not exempt from the survey. 

Part III applies only for pulp mills that operate chemical recovery combustion sources.

Part I of the survey includes data useful for the subpart S technology review (general mill 

information and flow diagrams; processes, products; equipment, controls, and compliance 

options in use for pulp and paper production equipment; permit limits; and emissions test data 

for pulp and paper processing equipment). Part III of the streamlined pulp and paper survey

requests information for chemical recovery combustion units. The data request under Part III is 

similar in scope to the data request under Part I (except that all flow diagrams are requested in 

Part I). The information requested in Parts I and III will be also useful for mills with applicable 

equipment under the NSPS review.

Part II of the survey is the NEI update useful for both the subpart S and subpart MM 

residual risk reviews. As noted elsewhere by commenters, the NEI update is one of the most 

time consuming portions of the pulp and paper survey. We are requesting one NEI update (as 

opposed to an update for subpart S emission units followed by a later update for subpart MM 
9

emission units) because one update: (1) is more informative for residual risk purposes (e.g., 

consideration of facility-wide risk), and (2) is far more efficient for both EPA and respondents 

(e.g., avoids multiple repetitive data handling/manipulation operations). Also, in some cases 

emission units covered under subpart MM (e.g., a lime kiln) serves as the control devices for 

emission units covered under subpart S (e.g., non-condensable gases [NCGs] or stripper off 

gases [SOGs]). In addition to providing more time for completion of the NEI update, we 

streamlined the NEI update as follows: 

 Made any NEI updates on TRS and CAP emissions that respondents would provide

optional.

 Added a separate “NEI blank.xls” spreadsheet template for mills with no prior NEI data

(to minimize confusion), and clarified instructions for these mills.

 Revamped to NEI update instructions to provide more detail on some of the data columns 

of particular importance for residual risk purposes.

Given the consent decree schedule limitations, providing more time for industry respondents to 

supply their NEI updates reduces the amount of time that EPA has to process the NEI data 

received and model it for residual risk purposes. Therefore, EPA anticipates performing some 

preliminary risk modeling (based on NEI data in hand) while awaiting the NEI revisions from 

mills, understanding that data supplied by mills will provide a far more robust data set for further 

RTR risk modeling efforts. 

3.2 Time to Complete the ICR

Comment: Three commenters (0009, 0010, and 0011) stated that EPA underestimated 

the industry burden for responding to the questionnaire and allowed too little time (60 days) to 

respond to a very lengthy questionnaire. Commenter 0011 stated that the scope of the proposed 

questionnaire and the time provided for responses were unreasonable and unnecessary. 

Commenter 0011 stated that EPA’s estimates of the time and cost to complete the survey are 

particularly low for the mills in their state, given that those mills are larger than average.

Commenters 0009 and 0011 stated that, if EPA goes forward with the survey content as 

proposed, industry would need at least 120 days to review the ICR, get clarification on any

necessary items that are not understood, collect the information requested (assuming all of the 

information requested is available), arrange it in a format for inclusion in the spreadsheets, 

quality assure (QA) the information after entry into the spreadsheets, and get management 

review of the information to be submitted.

Commenter 0010 estimated that 3 to 15 work months (90 to 450 work days) for one 

person will be necessary to complete the survey, based on their staff’s review of the survey

elements. According to commenter 0010, their burden estimates will result in higher costs than 

EPA is estimating, depending on the labor rate. Commenter 0010 argued that if EPA does not 

streamline the survey, EPA may inadvertently encourage facilities to respond to the survey with 

less thought and fewer updates to the emissions database that EPA plans to use to pre-populate 

each facility’s survey.

Commenters 0009 and 0011 noted that most of the time to prepare and complete the ICR 

is dedicated to updating the National Emissions Inventory (NEI) data for each facility for 2009. 
10

The two commenters also noted that EPA estimated only 16 to 40 hours for facilities to update 

their NEI inventory if previously submitted. According to the commenters, for member facilities 

of the National Council of the Paper Industry for Air and Stream Improvement (NCASI), almost 

all of the air toxic emission factors have been updated in the past year, and it will require a 

significant effort for a facility simply to update the calculations based on the revised emission 

factors. The commenters argued that EPA’s estimate of 16 hours is likely not even enough to 

QA the data entered by EPA for a large integrated pulp and paper facility. The commenters 

noted that EPA is also requesting additional columns of information that mills have not 

previously provided (e.g., maximum hourly emissions).

Commenters 0009 and 0011 provided the following table outlining the differences in 

burden hours and cost where the commenters believe EPA’s estimates are not accurate. The 

basis of the commenters’ burden estimates is discussed further in the paragraphs below.

Respondent 

Activity 

Number Respondent Activity

EPA 

Hour 

Estimate Commenter’s Hour Estimate

4.B.a. NEI Update: Mills that 

previously updated their NEI 

for RTR 

16 40 if mills submitted a 2009 state 

AEI with Air Toxics 

120 if mills submitted a 2009 

state AEI without Air Toxics 

4.B.a. NEI Update: Mills that have 

not previously updated their 

NEI for RTR

40 40 if mills submitted a 2009 state 

AEI with Air Toxics 

120 if mills submitted a 2009 

state AEI without Air Toxics 

4.B.a. NEI Update: Mills with no 

prior NEI data

220 AF&PA agrees that 220 is a 

reasonable estimate in this case 

4.B.b Detailed Flow Diagrams 8 40 

4.B.c. Inventory 32 40 – Facility with NEI 

60 – Facility with no prior NEI 

4.B.c. HAP additives 8 40 

4.B.e. CEMS spreadsheet 12 40 

For states that have air toxics included in the annual emissions inventory, the two 

commenters recommended that EPA obtain data from the state agencies to update the database 

for review prior to issuing the ICR. The two commenters stated that this would significantly

decrease the time for these mills to complete the survey since they would only need to verify,

rather than update, this information.

According to commenters 0009 and 0011, the February 2010 updates to NCASI’s air 

toxics technical bulletin showed some emission rates decreasing and others increasing. As a 

result, the two commenters indicated that a mill that previously submitted an NEI revision may

want to update emissions to provide a more accurate estimate (regardless of whether the mill was 

modified since initial submittal). For this reason, the commenters did not see a difference in time 

for these mills to update their inventory. The commenters noted that additional time will be 

necessary for mills that are in states that do not require reporting of air toxics in each annual 
11

emissions inventory (AEI). The two commenters provided the following subcategories and time 

estimates for completing the NEI portion of the survey:

 Facility previously submitted NEI for RTR and reports toxics in their AEI: 40 hours for 

preparation and 40 hours for data entry

 Facility previously submitted NEI for RTR and does not report toxics in their AEI: 120 

hours for preparation and 40 hours for data entry

 Facility that did not submit an NEI for RTR and reports toxics in their AEI: 180 hours 

for preparation and 60 hours for data entry

 Facility that did not submit an NEI for RTR and does not report toxics in their AEI: 220 

hours for preparation and 60 hours for data entry

Response: The time constraints imposed by the consent decree for subpart S RTR limit 

the amount of time that can be provided for industry to respond to the pulp and paper survey. As 

noted in Section 3.1 above, we have taken steps to partition and streamline the survey where 

possible to provide respondents more time to complete the full survey. Part I (Mill Overview 

and Subpart S Data) is due after 30 days, Part II (NEI Update) is due after 100 days, and Part III 

(Chemical Recovery Combustion Sources) is due after 180 days. 

We recognize that the NEI update is likely to be the most time consuming part of the 

survey, and therefore, have provided additional time beyond the proposed 60-days for 

completion of the NEI update. We have also reduced the proposed scope of the NEI update 

(e.g., by making revisions/additions of non-HAP data optional). 

The survey has been further revised to request only off-the-shelf process flow diagrams;

simplify the request for permit limits; eliminate the questions about potential future changes; 

clarify the scope of power boiler questions; only request information on additives with 

“measurable” amounts of HAP; and to clarify various other questions in response to industry

comments.

We believe the burden estimates provided by the commenters for the respondent 

activities listed above (NEI updates, inventory, and the CEMS spreadsheet) are reasonable, and 

we are increasing these burden estimates, accordingly. We have also adjusted the burden 

estimates to reflect the 3-part streamlined survey. Because we are requesting only off-the-shelf 

process flow diagrams, with respondents marking updates on the diagrams as necessary, we 

increased the burden estimate for this respondent activity from a proposed 8 hours to 20 hours 

(instead of 40 hours as suggested by the commenters). Similarly, because we are only requesting 

information on additives with “measurable” amounts of HAP,” with “measurable” defined in a 

way that should significantly reduce the scope of the information request, we increased the 

burden estimate for this respondent activity from a proposed 8 hours to 20 hours (instead of 40 

hours as suggested by the commenters).
12

3.3 Timing of the ICR

Comment: Three commenters (0009, 0010, and 0011) stated that the timing of the 

survey is problematic and provides further justification for reducing the scope of the ICR and 

providing more than 60 days for responding.

Commenter 0010 noted that EPA has been issuing rulemakings at a significant pace over 

the past year, with several of these rules coming out around the time the EPA would distribute its 

survey. Given their limited staff and resources, commenter 0010 stated that it was important that 

EPA consider the timing of the survey relative to the burden. As an example, commenter 0010 

noted that over the next 8 months, their pulp mills expect to review proposals and final rules and 

implement actions to comply with the following air program initiatives:

 Revisions to, and first ever reports under, the Greenhouse Gas (GHG) Mandatory

Reporting rule;

 First-time inclusion of GHGs on projects they have in progress or are planning under 

EPA’s GHG Tailoring Rule for Title V and Prevention of Significant Deterioration (PSD)

 Understanding and implementing as appropriate Industry Sector Guidance on application 

of Best Available Control Technologies (BACT) for GHGs;

 Updates and additions to the Reciprocating Internal Combustion Engines (RICE) MACT

for stationary engines;

 Potential industrial boiler treatment under the proposed Clean Air Transport Rule;

 Understanding and implementing new modeling requirements for sulfur dioxide (SO2),

NOX, and PM under the tighter national ambient air quality standards (NAAQS) and 

EPA’s new NAAQS modeling initiatives; and

 Final solid waste definition rules under the Resource Conservation and Recovery Act 

(RCRA) non-hazardous secondary materials solid waste definition for energy production, 

and simultaneously understanding and implementing compliance strategy plans for the 

final Boiler MACT and/or Commercial/Industrial Solid Waste Incinerator (CISWI) rule

for each boiler and process heater onsite.

Commenters 0009 and 0011 also noted that companies may be responding to the ICR 

during the first part of 2011, which is a time when mill and company personnel who would be 

involved in responding to the ICR also are responsible for preparing numerous other reports to 

state and federal authorities (e.g. state annual emission inventories, Title V permit annual 

compliance reports, Title III reports for the Superfund Amendments and Reauthorization Act 

(SARA), etc.).

Response: We understand the commenters’ concerns regarding the timing of the survey. 

The deadlines in the consent decree for subpart S RTR dictate the timing for the subpart S 

portion of the survey (Part I) and the NEI update (Part II). As noted in Section 3.1 above, we 

have taken additional steps to partition and streamline the survey, which should alleviate some of 

the commenters’ concerns regarding the timing of the survey. While Part I of the survey (Mill 

Overview and Subpart S Data) would be due after 30 days, we are providing additional time for 

the industry to complete the remaining parts of the survey: Part II - NEI update (100 days) and 

Part III - chemical recovery combustion unit data (180 days).
13

3.4 Inventory Requirement

Comment: Two commenters (0009 and 0011) noted that in the Inventory tab of the 

survey, EPA is requesting information not previously requested in the NEI for RTR (e.g., 

maximum hourly emissions; and startup, shutdown, and malfunction [SSM] emissions). The 

commenters’ reaction to the additional inventory requirements are discussed below:

 Maximum hourly emission rates: The commenters agreed that the maximum hourly

emissions are a necessary piece of information and having this information is an 

improved approach over calculating the maximum emissions as ten times the average 

annual rate.

 Startup, shutdown, and malfunction emissions: The commenters agreed that emissions 

can be different, and usually higher, during periods of startup, shutdown, and 

malfunction. However, the commenters stated that the data for emissions during startup, 

shutdown, and malfunction are not readily available in the format requested in the survey, 

i.e., facilities only keep track of the number of minutes for each such period (as required 

under 40 CFR Part 60 Subpart BB and 40 CFR Part 63 Subpart S and MM). According 

to the commenters, most facilities do not have test data during startup, shutdown, and 

malfunction events, because the unit must be under “normal operating conditions” for a 

valid performance test. Therefore, the commenters recommended that each facility

document the number of minutes each unit subject to these regulations experienced 

startup, shutdown, and malfunction periods during 2009.

Response: Part II of the revised survey requests the following.

Field Description

Routine Emissions (TPY) Revised routine emissions

Routine Emissions Max Hourly Rate (lbs per 

hour)

Maximum hourly emission rate for routine 

emissions.

Startup Emissions (TPY) Emissions that occurred during startup periods.

Startup Emissions Max Hourly Rate (lbs per hour) Maximum hourly emission rate for startup period 

emissions.

Shutdown Emissions (TPY) Emissions that occurred during shutdown periods.

Shutdown Emissions Max Hourly Rate (lbs per 

hour)

Maximum hourly emission rate for shutdown 

period emissions.

These data fields are requested because EPA is modeling both short- and long-term risks. 

Long-term risks would be based on the annual routine emissions (tpy). The routine emissions 

(tpy) can be used in determining an average hourly emission rate for the year (e.g., tpy divided 

by operating hours) for purposes of risk modeling. Short-term risks would be based on the 

maximum hourly emission rate(s) (e.g., lb/hr data).

For routine emissions, the average hourly emission rate (e.g., tpy divided by operating 

hours) can differ from the maximum hourly emission rate due to fluctuations in production rates

or other changes in other routine operating conditions. In the absence of site- or process-specific 

information, it has been EPA’s practice to conservatively assume that maximum hourly

emissions are 10 times the routine hourly emissions for purposes of risk modeling. We would 
14

prefer to have better site-, process-, and/or pollutant-specific data (where such data can be 

reasonably estimated) than to apply this default factor-of-10 approach. We believe individual 

facilities are in the best position to provide such specific data. Estimates are acceptable. If these 

data are unavailable and are not provided, then we’ll apply our default approach. We intend to 

work with pulp and paper industry representatives through AF&PA to review the factor-of-10 

default approach and its applicability for the different types of pulp and paper processes.

Startup and shutdown are conditions of operation that can occur throughout the year 

(with the number of startups and shutdowns depending on the type of process and equipment 

involved). Malfunctions are more sudden and unpredictable in nature than are 

startups/shutdowns. We understand that emissions may differ (e.g., be higher or lower than 

routine emissions) during startup, shutdown, and malfunction periods, and that mills are unlikely

to have measured emissions during such periods. We have changed the instructions for the 

startup and shutdown fields to make responses “optional,” and eliminated the malfunction fields. 

We retained these now-optional questions in the survey in order for us to gain a better 

understanding of how emissions change during startup and shutdown for any mills that may have 

previously measured (e.g., with CEMS) or estimated such emissions. Again, we feel that 

individual mills would be in the best position to provide the specific annual (tpy) and maximum 

hourly (lb/hr) emissions data for startup and shutdown periods. 

Additional questions relating to the duration of startup and shutdown events are included 

in the Part I and III Equip detail and Controls tabs. The EPA is considering standards that could 

apply during startup and shutdown events (or whether the current standards developed for 

normal operation should apply) in light of the December 2008 vacatur of the NESHAP startup, 

shutdown, and malfunction exemption in 40 CFR Part 63 subpart A. Questions pertaining to 

emission unit and control system startup and shutdown are asked in order to provide EPA with 

an understanding of the duration, emissions potential, work practices, and control mechanisms of 

startup and shutdown events for the wide variety of equipment used at pulp and paper mills. To 

the extent that this information is supplied to the Agency, it will inform our rulemaking efforts 

and help to tailor new requirements for startup and shutdown periods for the pulp and paper 

industry. 

It is helpful for EPA to know when certain data or information are simply not known. 

Therefore, throughout the survey, we request that mills enter “unknown” where mills do not have 

the requested information, cannot obtain the information without extraordinary effort, and cannot 

provide a reasonable estimate.

3.5 Process Flow Diagrams

Comment: Commenters 0009 and 0011 noted that the ICR requests that each facility 

submit process flow diagrams, which EPA estimates will only take 8 hours. According to the 

two commenters, some facilities prepared these types of diagrams for Title V permit applications 

and renewals, but many states do not require the facility to submit updated drawings with each 

permit renewal. As a result, noted the commenters, the process flow diagrams that most facilities 

have will be outdated, will not contain all of the information and identifiers EPA is requesting, 

and many times will be in software that is no longer used. The commenters also indicated that 

these diagrams do not have the same equipment ID numbers as the NEI database. Therefore, 

according to the commenters, the time to prepare these documents has been underestimated. The 
15

commenters estimated that it will take each facility at least 40 hours to update these diagrams in 

order to provide all of the information EPA is requesting. The commenters argued that it is 

unreasonable for EPA to specify in great detail the information that needs to be included in 

process flow diagrams and then assume that mills already have the process flow diagrams and 

will only need a few hours to assemble and provide them. The commenter’s understanding was 

that this ICR would not require mills to generate new information, which the commenters said

would not be the case for most mills in order to provide the process flow diagrams that EPA is 

requesting.

Response: We acknowledge the commenters’ concerns regarding the level of detail 

specified for the process flow diagrams. Our intent was not to prescribe what information must 

be included in the diagrams, but to give survey respondents an idea of the type of information 

that EPA was looking for in the diagrams. We are only seeking off-the-shelf diagrams (not new 

drawings). We believe the diagrams will help answer a lot of questions we may have (thereby 

eliminating the need for follow-up calls to many of the mills). Respondents can use whatever 

diagrams they have, and hand mark any changes/notes if needed. Respondents can also forego 

the labeling of each emission unit with IDs. We have revised the survey instructions to clarify

these points.

3.6 HAP Additives

Comment: Commenters 0009 and 0011 noted that the ICR requests that each facility 

submit information on the HAP additives used at the paper machines. The two commenters 

stated that many facilities are constantly changing additives and trying new additives to improve 

product quality and develop new and improved products to adapt to changing market conditions 

and product demand, so any information provided will represent a snapshot in time.

The commenters also stated that suppliers are not always willing to share their 

formulations because it is proprietary information, so mills would need time to contact the many 

additive suppliers and request information on the amounts of the six HAP in each additive. The 

commenters noted that pulp and paper companies are also very reluctant to reveal the

combination and quantities of additives used in the manufacturing of their products. Therefore, 

the commenters concluded that this information would, at a minimum, likely be deemed CBI.

The commenters noted that the survey requests that a facility report any additive used in a 

“measurable” amount. According to the commenters, the U.S. Occupational Safety & Health 

Administration (OSHA) requires that chemical suppliers provide specific constituent amounts in 

Material Safety Data Sheets (MSDS) for any carcinogens that are present in amounts greater than 

0.1 percent and any non-carcinogens that are present in amounts greater than 1 percent. The 

commenters indicated that this information will be available from suppliers, and the commenters 

recommended that “measurable” amounts be based on these criteria. The commenters also 

requested that additives not be linked to a specific paper machine but reported as total usage, in 

order to preserve the confidentiality of the papermaking process.

Response: We acknowledge that numerous HAP and/or non-HAP additives are used at 

the paper machines. The questions related to HAP additives are limited to only those HAPs of 

potential concern for residual risk purposes in order to reduce the scope of the information 

request. We are not asking for suppliers to reveal specific additive formulations, nor are we 
16

asking for information beyond what is reported on MSDS sheets. Respondents to the survey

would only need to include additives with measurable quantities of HAP as reported on the 

MSDS for the additive. Based on the commenters’ suggestion, we have revised the survey

instructions to include a definition for the term “measurable” that would be consistent with 

OSHA requirements. We have also added a sentence to clarify that we are not asking for 

companies to go back to their suppliers to seek information beyond what is reported on MSDS. 

To address the concern regarding confidential information, we have removed the paper 

machine designation from the survey spreadsheet. We have also suggested in the pull-down 

menu text that annual resin use might be provided (e.g., should a mill be more comfortable 

providing an annual usage as opposed to daily or per ton of product).

As noted in the survey instructions, although it is unclear whether paper machine 

additives contribute significantly to paper machine emissions (e.g., because additives may

partition to the paper product or white water, and not necessarily to the air), the HAP additives 

information would be used to evaluate work practices related to additives. Therefore, a question 

has been added to the survey asking mills if they are aware of any non-HAP substitutes for the 

HAP additives included in their response. Mills are also asked to indicate if any of the additive 

substitutes they identify contain other compounds that may not be desirable from a worker safety 

perspective.
17

4.0 NCASI Emissions Information

Comment: Two commenters (0009 and 0011) offered the following responses to EPA’s 

statement (on page 8 of the Supporting Statement) that NCASI’s emissions test data may be outof-date and only represent NCASI members.

First, the commenters noted that NCASI issued updated Technical Bulletin No. 973 in 

February 2010 for Air Toxics emissions for Pulp and Paper Mill Sources. According to the 

commenters, the update included new site-specific data and eliminated data that were old or not 

representative of the industry. In addition, the commenters stated that NCASI used the latest 

statistical techniques to address both non-detect values and outliers.

Second, the commenters argued that, while the survey would request emissions inventory

data from other non-NCASI members, it has been the experience of pulp and paper industry

consultants that these facilities either (1) do not estimate or include all HAP that NCASI

members do in their emissions inventories due to lack of data, (2) use older NCASI emission 

factors if they were previous members of the association, or (3) obtain updated NCASI data 

through other unapproved sources. According to the commenters, in all but the last case, these 

emission estimates are not accurate and will skew the data set.

The commenters expected the majority of HAP emissions calculations (and even much of 

the criteria pollutant emissions) will be based on NCASI factors, and stated that it is important to 

note that these data have been recently updated. The commenters noted that the NCASI database 

contains data means, medians, and detailed source information, so some facilities may use a 

mean emission factor, some facilities may use median emission factors, and some facilities may

select the emission factor from the equipment that best represents their mill. According to the 

commenters, the emissions estimates for non-NCASI members may be based on older factors 

and/or omit compounds detected by NCASI. The commenters noted that their industry relies 

heavily on published emission factor data and can use different treatments of the same dataset, so 

estimated emissions from mills with similar configurations may be very different. The 

commenters argued that, as EPA examines the data and performs the risk analyses, it is 

important to understand these differences in order to ensure the proper use of data in the 

modeling effort.

Response: We acknowledge that, for the pulp and paper industry, NCASI’s technical 

bulletins are an authoritative source for emission factors. The survey instructions cite them as a 

resource. We also note that the emissions data in the latest technical bulletins have been 

updated—although as late as NCASI Technical Bulletin No. 973, the majority of the emissions 

data are still 1990s (pre-MACT) data, based on our examination of the bulletin’s appendices. It

was not our intention in the Supporting Statement to devalue NCASI’s emission factors but 

simply to explain why we believed that new emissions test data were needed.

We have no control over how mills obtain the data, and we recognize that inventories for 

NCASI member mills will likely be based on updated factors, while other mill inventories may

not. We also recognize that different mills may use different emission factors from the same 

NCASI data set. We are not prescribing how mills should estimate their emissions. We are, 

however, requesting that survey respondents provide their emissions data source in the Part II 

NEI update.
18

5.0 Power Boiler Information

Comment: Commenters 0009 and 0011 noted that EPA requests information throughout 

the survey on power boilers and other incineration devices, as these units can be used to treat 

non-condensable gas vents regulated under 40 CFR Part 60 Subpart BB and 40 CFR Part 63 

Subpart S. While the two commenters acknowledged that these units can be part of the 

compliance approach for these regulations, the commenters did not believe that EPA should 

collect detailed information related to the fuels and capacities of power boilers under this ICR.

The commenters argued that any add-on control information for these units is not 

necessary since the noncondensible gases (NCGs) are presumed to be destroyed by the boiler (as 

indicated in the survey instructions). In addition, the commenters noted that pulp and paper 

facilities have recently completed an ICR for the Boiler MACT regulations, and stated that the

Boiler MACT ICR database contains detailed information for each boiler. Therefore, the 

commenters recommended that power boiler information should not be requested again in the 

pulp and paper ICR. According to the commenters, the information requested should be limited 

to the type of unit used to control NCGs and stripper offgases (SOGs) (boiler, oxidizer, kiln, 

etc.), if the facility has a back-up control device, and how often (e.g., number of minutes) the 

mill has bypassed these control devices due to their unavailability.

Response: We have reduced the scope of the questions related to power boiler fuel use 

as a result of these comments. We have removed questions pertaining to actual 2009 fuel use

and replaced them with a less-detailed request for an approximate percent of annual heat input 

capacity (MMBtu/yr) supplied by each fuel. We have also made the questions related to heating 

values optional. This information, although less detailed, should provide EPA with enough 

information to calculate emissions and perform impacts analyses for fuel-fired equipment. 

The power boiler questions remaining in the pulp and paper survey appear in Part I (Mill 

Overview and Subpart S Data), and Part II (NEI Update). The EPA is interested in pulp and 

paper mill boilers because boilers contribute to the facility-wide risk at pulp and paper mills. 

Boilers may also be used as a control device for pulp mill NCGs or SOGs. Further, boilers are 

one of the larger sources of air pollutants at pulp and paper mills, and information on boilers 

would aid in understanding mill-wide emissions (and in putting pulp and paper process-related 

emissions into perspective).

The scope of the pulp and paper information request for boiler information is more 

limited than the information requested in the Boiler MACT survey. It would be far less timeconsuming from an Agency resource perspective to seek limited, updated boiler information in 

the pulp and paper survey than to try and piece together information from the prior Boiler MACT 

survey with the information received in the pulp and paper survey. As proposed, mills are not

required to include air pollution control device details for boilers in the Part I Controls tab since 

NCGs combusted by boilers have been demonstrated to be destroyed in the boiler and are 

subsequently unaffected by the boiler’s APCD. Also as proposed, we are not collecting existing 

or new emissions test data for boilers. We are collecting limited data for pulp and paper mill 

boilers instead of relying on the boiler MACT data set for following reasons: 
19

 The boiler data collected through the pulp and paper survey will be for the 2009 base 

year consistent with the remainder of the pulp and paper data collected (including the 

NEI data), as opposed to an earlier base year for the Boiler MACT data set.

 The limited fuel type and use (percent of MMBtu/hr capacity) data requested in the 

pulp and paper survey would simplify emission calculations (e.g., whereas the boiler 

MACT data included fuel use ranges).

 It would be a time-consuming exercise for EPA to attempt to match the Boiler MACT 

equipment IDs with the NEI emission unit IDs provided in the pulp and paper 

survey’s NEI update (and past experience with this type of exercise suggests that it 

would be nearly impossible to match all of the boilers). The pulp and paper survey

should provide the matching codes for pulp and paper boilers.
20

6.0 State-Only Permit Limits

Comment: Commenters 0009 and 0011 noted that the Inventory tab of the survey

requests permit limits for each unit affected by the ICR. The two commenters agreed that each 

facility should report federally enforceable limits, but recommended that state-only limits not be 

included. The commenters argued that state-only limits on criteria pollutants and toxics derived 

from modeling analyses often do not represent actual emissions (or in some cases even potential 

emissions) and do not allow for “apples to apples” comparison of permit limits across all 

sources. As an example, the commenters stated that many facilities “optimize” emissions of air 

toxics in their modeling analyses up to a certain percentage of the state’s allowable ambient 

levels, in order to gain a compliance margin and reduce the likelihood of future modeling when 

emission factors change slightly. The commenters indicated that modeled rates included in 

permits as state-only limits are often much higher than actual or potential emissions and would 

not give EPA any meaningful information. According to the commenters, limits are often on a 

source-by-source basis and take up several pages in the permit, so exclusion of these limits will 

reduce the burden on facilities.

Response: Permit limits are requested in Parts I and III of the streamlined survey for the 

different emission units covered by each part of the survey. Mills may provide all permit limits 

including limits for chemical recovery combustion sources in Part I if desired (and, therefore, 

would not need to include these limits in Part III). To streamline the permit limit request, the 

permit limit columns were removed from the proposed Inventory tab (which would have forced 

permit limits to be entered in a format that lined up the NEI data) and placed in new Part I and 

Part III Permit limits tabs. 

The EPA is not requesting that every single permit limit be included in the survey

response. The instruction document for the proposed survey narrowed the request for permit 

limits to concentration limits (ppmdv, gr/dscf, etc.), percent reduction, mass per unit production 

(lb/ton of material throughput, etc.) because these limits can be compared from facility to facility

independent of emission unit or mill capacity. Mass emission rate limits (lb/hr or tpy), which are 

typical of the optimized state permit limits mentioned by the commenters, are not being 

requested unless this is the only way in which limits are specified in the permit. The streamlined 

survey instruction documents for Parts I and III contain this same language.

In addition, we added a statement in the revised survey spreadsheets stating that mills do 

not have to provide every limit for pollutants with multiple limits in different units of measure. 

Instead, mills are referred to the survey instructions for a list of suggested units of measure for 

permit limits. The Part I and Part III survey instruction documents (like the proposed instruction 

document) include a table of suggested units of measure for permit limits (see Table 2 of each

instruction document). The suggested units of measure included in Table 2 of the survey

instructions were selected based on the units of measure for Federal limits. If respondents 

provide limits in the suggested terms, then EPA can readily compare permit limits with the 

federal limits in order to easily identify mill equipment with emission limits more stringent than 

existing Federal standards. The survey is further set up to prevent rekeying of Federal emission 

limits that are restated in the permit. The survey instructions specify the following:
21

“Your permit may simply restate the emission limits contained in Federal rules such as 

NESHAP subparts S and MM and NSPS subparts BB or Db. Some permits may list all of 

the compliance options contained in the Federal rules as permit limits. If this is the case, 

you do not need to enter permit limits that are exactly the same as Federal NESHAP or 

NSPS. Instead, specify the applicable Federal rule (not the specific numeric Federal 

limits) in Column F and skip the remaining permit questions/columns in the table.” 

The instructions go on to specifically state, “Please do not enter State lb/hr or tpy emission limits 

in addition to the Federal limits.”

Nevertheless, EPA is sensitive to the burden associated with completing the request for 

permit limits. In order to reduce this burden, we included survey instructions to allow mills to 

submit a copy of their permit with their survey response instead of completing the permit limit 

section of the survey. A mill-specific summary of permit limits or compliance matrix would be 

acceptable as well.
22

7.0 Potential Changes

Comment: Commenters 0009 and 0011 noted that EPA is requesting information on 

“potential changes.” The two commenters argued that this information is not appropriate and 

recommended that the tab be removed entirely, for three reasons.

First the commenters noted that facilities are in a continuous cycle to determine how to 

improve their operations and evaluate the impact of potential regulations. The commenters 

stated that, due to the ever-changing market and regulatory climate, many of these potential 

projects are either never seen to completion or are modified due to changes in regulatory

requirements. The commenters argued that the information requested is constantly changing, 

would be out of date by the time EPA was finished analyzing the information, and would change 

again based on the outcome of EPA’s analysis.

Second, according to the commenters, the request for information on any potential 

changes within the next eight years aggravates the problems described previously. The 

commenters argued that it is mere speculation to talk about what changes might take place over 

such a long time, during which regulatory requirements likely will change several times, let 

alone customer demand and requirements, process technology, and products. The commenters 

also noted that the proposed spreadsheet asks for potential changes “in the next 8 years (e.g., 

between 2009 and 2017).” According to the commenters, there is no apparent reason for 

including changes in 2009 and 2010. Additionally, the commenters noted that not all of the 

questions contain a parenthetical qualifying “in the next 8 years,” begging the question whether 

those portions are supposed to address changes from 2011 to 2019.

Third, the commenters noted that the pulp and paper industry competes globally with all 

companies searching for innovative solutions to maintain and increase their place in the market. 

Therefore, the commenters indicated that concepts to create new or improved products, improve 

process efficacy and efficiency, and comply with regulations are typically CBI, and companies 

generally would not be willing to share such “potential projects” in a public forum.

Response: We acknowledge the issues noted by the commenters with respect to 

supplying information on potential changes. The Potential changes tab was originally included 

in the survey to provide information useful for projecting new or modified source impacts. 

However, in response to the comment above, we have removed the tab from the survey.

Another method for projecting the number of new sources and modifications would be to 

look at the number of new sources and modifications that have occurred over the past 5 years 

and project forward the same number of new sources and modifications for the upcoming 5 years 

(e.g., the period over which new source impacts would be calculated). Other portions of the 

survey contain questions (e.g., equipment installation dates, reason for NSPS applicability, etc) 

that will inform this type of projection.
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8.0 Technical Clarifications

8.1 Nominal Throughput Data

Comment: Two commenters (0009 and 0011) indicated that the survey needs to be 

consistent in its terminology. According to the two commenters, data requests are inconsistent in 

requesting either design, potential or actual data. The commenters recommended that EPA

request nominal capacity data.

Response: In response to the comment, we have made the following specific changes to

the survey to improve the consistency in terminology:

 In the Part I Mill tab, noted in the instruction row that nominal production capacity will 

suffice for market pulp and paper/paperboard for 2009. [Note: The revised survey’s Mill

tab was formerly the information to the right of the orange line in Facility tab of the 

proposed survey.]

 In the Part I Equip detail tab, replaced the word “throughput” with “capacity” for the 

causticizing area to request “Causticizing area capacity (use lime kiln tons CaO/yr)” and 

noted in the instruction row that lime kiln capacity is of interest.

 In the Part I Paper prod tab, added the words “nominal production” for the 

paper/paperboard production process to request “Nominal production capacity, ADT/d” 

and noted in the instruction row that nominal production capacity is of interest.

 In the Part I survey instructions, we included example calculations to aid in 

understanding of the capacity utilization questions.

 In the Part III Equip detail tab:

o Replaced the words “feed rate” with “capacity” for recovery furnaces to request

“Spent liquor solids capacity, million lb BLS/yr (or million lb RLS/yr for sulfite)” 

and noted in the instruction row that BLS/RLS feed rate capacity is of interest.

o Replaced the words “feed rate” with “capacity” for semichemical combustion 

units to request “Spent liquor solids capacity, million lb/yr.”

o Replaced the word “rate” with “capacity” for lime kilns to request “Lime 

production capacity, ton/d.”

8.2 Emission Calculation Method Code

Comment: Commenters 0009 and 0011 noted that in the Inventory tab, the facility is 

asked to supply an emission calculation method code. The two commenters recommended the 

addition of another code for facilities that utilize an emission factor from a similar source at 

another location within the company or a published emission factor from a similar source, called 

“Similar Source Emission Factor.”
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Response: There is no specific code applicable to the situation the commenter describes. 

However, there is an emissions comment column available within the NEI framework. 

Consistent with that, we have added an “Emissions Comment” column in the NEI update next to 

the “Emission Calculation Method Code for Revised Emissions” column to allow mills to 

describe the emission factor source or emissions calculation method when none of the Emission 

Calculation Method Codes apply. 
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9.0 Other Specific Comments

9.1 Equip Detail Tab

Comment: Two commenters (0009 and 0011) offered the following comments on the 

production line, equipment capacity, and process tank questions included in the Equip Detail tab 

of the survey.

Regarding production lines, the two commenters noted that EPA is requesting that the 

facility designate each pulping line and then correlate the ancillary equipment to each line. The 

commenters were concerned that this approach will lead to confusion. According to the 

commenters, while some mills do have straight pulping lines with dedicated evaporators, 

bleaching lines, and chemical recovery units, these facilities are not the norm. The commenters 

stated that equipment at most mills is interrelated, and, except for the digesters, the products 

from these units can then travel a variety of ways in the mill. For this reason, the commenters 

recommended that Column C in the Equip Detail tab be eliminated.

Regarding equipment capacity units, the two commenters noted that, for several units, 

EPA requests capacity or throughput data in air-dried tons of pulp (ADTP). The commenters 

indicated that for some units, like evaporators, these units are not appropriate. The commenters 

suggested that EPA request data in units that are more representative (i.e., gallons per minute 

[gpm] of weak black liquor for evaporators).

The two commenters noted that EPA also requests information for process tanks for 

various materials (pulp, black liquor, green liquor, white liquor). According to the commenters,

most facilities will track total generation of these materials, but will not track the throughput of 

individual tanks. The commenters stated that many facilities do not use production-based 

emission factors for process tanks, but instead use lb/hr/tank emission factors published in 

NCASI technical bulletins. The commenters also stated that some tanks can be used for different 

materials. Therefore, the commenters suggested that EPA request only the number of tanks that 

store each material.

Response: Regarding the comment on production lines, we agree with the commenters 

that some lines will not have dedicated equipment. Consequently, we have omitted the column 

referenced by the commenters everywhere it appeared in the draft survey.

Regarding the comment on equipment capacity units, the units were originally selected 

based on the units for emission factors available in the literature (i.e., NCASI technical bulletins)

for those equipment. However, in response to this comment, we have revised the Equip detail

tab (in Part I) to ask for evaporator capacity in units of “gal/min of weak black liquor.”

In response to the comment on process tanks, we have revised the Equip detail tab (in 

Part I) to eliminate the request for annual tank throughput and are just requesting information on 

tank capacity. We need tank capacity (in gallons) to distinguish relative tank size (e.g., in case 

we develop subcategories) for any tanks not subject to subpart S that are determined to have 

uncontrolled emissions of interest for RTR. The survey instructions for tank capacity limit the 

number of tanks to be included. We are most interested in identifying any tanks that are not 

already covered by subpart S.
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9.2 Kraft Condensates Tab

Comment: Commenters 0009 and 0011 noted that the survey is constructed so a mill 

can indicate that it treats its condensates for Subpart S either in a steam stripper or in the 

biological treatment system. The two commenters noted that some facilities have both systems 

and use them in combination to demonstrate compliance or have one as a back-up system (e.g., 

when an operational problem with the stripper causes a decrease in collection and/or treatment). 

The commenters recommended that EPA include additional columns to note if the facility has 

both systems and if they are used in combination or as a back-up system.

Response: We agree with the commenters’ recommendation and have revised the Kraft 

Condensates tab to include a column for a description if multiple methods are used to treat a 

condensate. We also relabeled the Table headers (formerly A, B, C, etc) with Roman numerals 

(I, II, III, etc) to minimize confusion with spreadsheet column numbering.

9.3 PCC Tab

Comment: Commenters 0009 and 0011 noted that EPA is requesting information on 

facilities that route process exhaust to a PCC plant. The two commenters were unclear why this 

information is necessary since these facilities are typically independently owned and operated 

under a separate air permit. The commenters stated that the PCC plant is not part of the pulp and 

paper source category and requested that information on these plants not be included in the

survey.

Response: The PCC tab is included in Part III of the revised pulp and paper survey. 

EPA is seeking to understand the interrelation of lime kiln exhaust (or other process exhaust 

flow) to PCC plants and confirm the permitting relationship between the two facilities. We are 

aware of at least one pulping facility with a PCC plant that appears to be included in the same air 

permit. As we evaluate lime kilns under the pulp and paper subpart BB NSPS review and 

subpart MM RTR, it is pertinent to know how the lime kiln exhaust is being used and whether 

the exhaust being transferred to another facility is controlled or uncontrolled prior to transfer. 

We want to understand this arrangement so that we can account for it in our rulemaking (e.g., 

with clarifying rule language). Nonetheless, we have limited the PCC questions in the survey

(e.g., removed requests for the address and latitude/longitude of the PCC plant) to try to 

minimize the burden on survey respondents.

9.4 Emissions Test Data Tab

Comment: Two commenters (0009 and 0011) agreed with EPA’s request that each 

facility document the site-specific data available and include a copy of the most recent test 

reports for review and entry into a database. The two commenters stated that this approach will 

allow for EPA to extract the data for their use in a consistent manner and ensure that the data 

submitted are reviewed by EPA. The commenters hoped that this will lead to a consistent 

handling of non-detects as well as a review of the test methods, calculations, etc. to ensure that 

data are properly documented and utilized.

Response: We acknowledge the commenters’ statement. We are requesting copies of 

the most recent test reports for each mill to ensure consistency in both the calculation of the 

emissions data and the treatment of non-detect emissions data and to reduce the industry burden 
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of responding to this survey. Parts I and III of the revised survey request emissions test data for 

the different equipment and pollutants listed in attachments to each of the instruction documents. 

We added acetaldehyde and formaldehyde to the list of HAPs for which emission test data are 

requested (along with methanol which has been used as a surrogate for these HAP) because 

acetaldehyde and formaldehyde may be of particular interest for residual risk purposes. 

9.5 Segregation of CBI

Comment: According to commenters 0009 and 0011, the legitimate need to protect CBI 

from disclosure can often considerably complicate the analysis of survey information, especially

by interested members of the public. The two commenters urged EPA to segregate those 

portions of the survey that are likely to contain information that will be claimed by some or most 

companies as CBI from other portions of the survey, and to have them reported in separate 

spreadsheets, to facilitate analysis of information that likely will not be claimed as CBI by most 

or all mills. As an example, the commenters indicated that the tabs in the proposed survey

spreadsheet on pulp production, paper production, byproducts, additives, and potential changes 

appear to be the portions most likely to contain information that many or most companies will 

claim as CBI.

Response: We believe the survey already provides sufficient mechanisms for 

segregation of CBI-containing data. Specifically, mills are requested to segregate their CBI by 

shading red the CBI-containing cells in the spreadsheets and submitting the CBI data separately, 

as specified in section C2 of each survey instruction document. Creating additional separate 

spreadsheets within Parts I and III of the revised survey to include the information cited by the 

commenters might lead to confusion or encourage respondents to claim the entire spreadsheet as 

CBI, when only a few columns may contain confidential information. Separate spreadsheets are 

already provided (as proposed) for submittal of cost information which EPA recognizes has the 

potential to be considered confidential by many mills. Respondents are encouraged to consider 

carefully which information they report is truly CBI that is protected under the Clean Air Act. 

See, e.g, 42 USC 7414(c) and 40 CFR 2.301. It should be noted that some capacity information 

is already reported publicly (e.g., through data available for purchase from RISI). However, we 

understand that capacity utilization information may be considered confidential. The EPA will 

adhere to strict procedures in place for protecting the confidentiality of information submitted 

with a confidentiality claim.
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10.0 CEMS Data

Comment: Commenters 0009 and 0011 noted that, in the ICR, EPA requests only 30 

days of CEMS data. The two commenters argued that this was not a sufficient period of time to 

fully assess the variability of emissions during startup and shutdown periods, malfunction 

periods and normal operating periods. The commenters suggested that EPA request a full year of 

data to get a full representation of variability. The commenters stated that this is consistent with 

the approach that the commenters and NCASI are proposing for the Boiler MACT carbon 

monoxide (CO) standard.

Response: Based on the comment, we have revised the survey to request a full year of 

CEMS data, if available. Data are requested for periods of operation during calendar year 2009.

In addition, we have made the following revisions to the CEMS data request based on 

conversations with industry representatives:

 Added a box to the survey instructions to provide guidance on how to handle situations 

when CEMS data are not available in a form that can be transferred into EPA’s P&P 

CEMS spreadsheet.xls (or when production data are unavailable to be coupled with the 

CEMS data). Alternative formats for the CEMS data will suffice in these cases.

 Made the hourly average opacity column “optional” since mills typically demonstrate 

compliance based on 6-minute averages. The column was retained in case any mills have 

data in hourly average form (but not 6-minute averages).

 Clarified (in the survey instructions) that mills are not required to supply CEMS data for 

power boilers unless the boiler has a CEMS installed to show compliance with a 

NESHAP subpart S (or subpart MM) or NSPS subpart BB emission limit.