## Multi

- Pollutant Sector Rule for the Pulp and PaperIndustry

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 S ector Policies and Programs Division Natural Resources and Commerce Group Research Triangle Park, NC 27711

November 1 6 , 2010i 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 I CR

................................ ................................ ...................... 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 NCASIEmissions Information

................................ ................................ .......................... 17 5.0 Power Boiler Information

................................ ................................ ................................ .. 18 6.0 State

- Only

Permit L im its

................................ ................................ ................................ ... 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

................................ ............................... 1ii 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 Ai r Act CATs Californians for Alternatives to Toxics CBD Center for Biological Diversity CBI Confidential business i nformation CEMS Continuous e mission s monitoring s ystem CI SWI Commercial/industrial solid waste incinerator(s) CO Carbon monoxide d scf 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 p ollutant (s) hr Hour(s) ICR Information c ollection 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 emiss ion s standards for hazardous air pollutant NOI Notice of intent NO X Nitrogen oxides NSPS New source performance s tandards OSHA U.S. Occupational Safety & Health Administration PCC Precipitated calcium carbonate PM Particulate matter PSD Preve ntion of Significant Deterioration QA Quality assure RCRA Resource Conservation and Recovery Act RI CE Reciprocating internal combustion engine(s) RTR Residual risk and technology review SARA Superfund Amendments and Reauthorization Act SDT Smel t dissolving tank SO 2 Sulfur dioxide SOG Stripper off gas TRS Total reduced sulfur1 

### 1.0 Introduction On June 23, 20 1 0, the U.S. Environmental Protection Agency (EPA) requested comment (7 5 FR 3 5792 ) on a proposed information collection request (ICR) for the p ulp and p aper multi

pollutant s ector rule (EPA I CR No. 2393.01) . The sector rule includes both the n ew source p erformance s tandards (NSPS) review and the n ational e mission s tandards for hazardous air p ollutants (NESHAP) residual risk and t echnolo gy r eview (RTR)

. The r espondents affected b y this action are owners/operators of mills that are major sources of hazardous a ir p ollutant (HAP) emissions , as defined in 40 CFR 63.2. These major source m ills include :

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

 Mills that perform mechanical, groun dwood, secon dary fiber , and non

- wood pulping

 Mi lls that perform bleaching

 Mills that manufacture paper or paperboard products
A 60

- day comment period (ending August 23 , 2010 ) w as provided for the public to submit comments to EPA regarding the proposed new data collection. A total of three comments were received b y 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 comment s submitted to EPA. Whe re one commenter (0011) endorsed the comments by another commenter (0009) , the docket item numbers associated with both commenters we re presented together in the comment summary

. T able 1. List of Commenters on Proposed I CR for Pulp and Paper Sector NSPS and

NESHAP Residual Risk and Technology Review
Docket No. EPA

- HQ

- OAR

200 7
- 0 544 Date Received Commenter Name and Affiliation
000 9 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 Weyerha euser Company
0011 08/23/2010 Roy McAuley Executive Director Alabama Pulp & Paper Council
This document summarizes the substantive comments received b y EPA on the proposed ICR and presents EPA’s response to each of those comments. The comment summaries and responses are grouped b y topic in the following sections.2 

### 2. 0 Requirement to Collect Information
Comment: Commenter s 0009 and 0011 noted that i n 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 commenter s argued that EPA is substantially

overstat ing what it is required to do under the CAA. According to the commenter s , the questionnaire is directe d , 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 commenter s 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 b y EPA is outside the scope of the CAA. The commenter s noted that the pr eamble for the proposed I CR (75 FR 35794) states that

“ Section 111(b)(1)(B) of the CAA mandate s 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. ” Ac cording to the commenter s , 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 the re are no other qualifiers on the Administrator’s decision not to review existing NSPS. As a result, the commenter s argued that EPA has almost unlimited discretion to decide not to do a periodic review of the Kraft Pulp Mill NSPS. According to the commenter s , s tating that EPA is

“ required ” to review the kraft pulp mill NSPS is claiming a justification for the I CR that does not reall y exist. The commenter s stated that EPA has alr eady been provided a great deal of information about emissions from kraft pulping vents and kraft pulp mill chemical recovery s ys tems, as well as the emission controls used for these sources, from the Subparts S and MM NESHAP rulemakings and from complianc e demonstrations and continuous monitoring required b y those regulations. The commenter s noted that EPA has also been considering these emissions recentl y in its ongoing evaluation of residual risk for pulping and chemical recovery sources. The commenter s 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 commenter s noted that the existing NSPS require, among other things, collection and inc ineration 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 commenter s further noted that the pulp and paper maximum achievable control technology ( MACT ) stan dards also require incineration , or similarly

highl y effective means , of controlling the organic gas streams from kraft pulp mills, which also contain TRS. Consequently , the commenter s argued that EPA already has sufficient information to conclude that th ere is no more effective technology available for controlling pulp mill TRS emissions. The commenter s acknowledged that particulate matter ( PM ) control tec hnology has improved since the kraft p ulp m ill NSPS were promulgated, but noted that EPA has since th at time promulgated stringent PM emission limits in the MACT standards for pulp mill combustion3

sources as a surrogate for metal HAP

. The commenters noted that the se 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 BL S ) for smelt dissolving tanks (SDTs) , and 0.01 vs

. 0.067 or 0.13 gr/dc sf 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 b y the kraft pulp mill NSPS to those already regulated b y the NSPS

. According to the commenters, n othing 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 p osition: (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 Ass ociation v s . EPA, 627 F.2d 416, 426 (D.C. Cir. 1 980) (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 onl y with respect to particulate matter. ” ); (3) 70 FR 9706, 9711 (Feb. 28, 2005) (where EPA declined to set nitrogen oxide (NO X ) limits for boilers below 100 million British thermal units per hour (MM B tu/hr) heat input, based on current emission levels, available technologies, and costs). Acc ording to the commenters, before expanding the kraft p ulp m ill 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 ove r the fact that, even if the CAA required EPA to review the kraft pulp mill NSPS, the questionnaire addresse s 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 onl y pulp wastepaper. Th e 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. T he commenters argued that EPA is not under an y legal obligation to expand the current NSPS to cover other ty

pes 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 signific antl y to, air pollution which may reasonabl y 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 w ere not aware of any basis for changing that decision . The commenters noted that the emissions from those other ty pes 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 largel y disappeared

—the commenters believe there may onl y 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 informat ion to review and revise NESHAP is overstated. The commenters specificall y pointed to the FR preamble state ment that “ recent case law and legal petitions suggest the need to review the pulp and paper NESHAP ” and that EPA need ed “ to make the NESHAP consistent with CAA precedent established in recent judicial rulings. ” ( 75 FR 35,794 ) According to the commenters, these statements appear ed to be in direct conflict with the judicial review and emission standard review provisions that Congress included in the CAA. The comm enters stated that under CAA section 307, NESHAP must be challenged through a petition for review filed in the courts of appeals within 60 day s after publication of the rule. The commenters noted that n either the Subpart S nor the Subpart MM NESHAP was ch allenged 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 eff

ect 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 sy stem designed to provide certainty and clarity: anyone objecting to a rule must challenge it within 60 day s; 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 sectio n 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 an y 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 currentl y subject to Subparts S or MM. The commenters indicated that, at a minimum, the I CR needs to clearl y 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 currentl y covered by Subparts S or MM , especiall y in light of all of the other regulatory burdens facing the industry at this time (not to me ntion EPA resource constraints)

. Response: T hree 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 20015

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 devel opments 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 ye ars after NESHAP promulgation. Thus, all three of the emis sion standards listed above are due for r eview 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 ha s 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 co ntained 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 avai lable for the pulp and paper industry is nearl y 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 sy stems. The EP A is se eking additional updated information to use in the residual risk and technology

review (RTR) regulatory anal ys es 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 . A s 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 sec tion 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. Howeve r, th is 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 the6

pulp and paper industry . (The survey co llecting 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 b eing requested in th e 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 I CR. The surve y would also reveal if there have been no advances in technologies ( as the c ommenters 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 A dministrator 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 pres ent 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. W e will not know whether i f is prudent to extend the NSPS to additional pollutants until we have collected and reviewed updated information to make definitive determinations. M ills 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 mil ls 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 “s ynthetic 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.7 

### 3 .0 Burden of the Proposed ICR 3.1 Streamlining the ICR Comment: Three commenters (0009, 0010, and 0011) recommended that EPA significantl y streamline the survey. One c ommenter ( 0010 ) stated that EPA is seeking far more information

— and overl y detailed inform ation

—than is necessary , given the time period and the timing constraints that EPA feels it must address. C ommenter 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. C ommenter 0010 noted that each of the regulations addressed b y the IC R will be a follow

- up regulatory

review b y EP A 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 largel y 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 comm enter 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. C ommenters 0009 and 0011 noted that EPA currentl y 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 earl y 2011. C ommenters 0009 and 0011 estimated it will take at least 2 months for EPA to compile and anal yz e the responses and do the final round of di spersion modeling with updated emissions inventory information. According to the two commenters, this would leave little time for the new information to be gathered b y this survey to be meaningfull y considered by the technical staff in their proposal and still allow for adequate review b y 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 an y 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. I f faci lities are only required to submit d ata 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 directl y b y 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 i dentify 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 c ommenters argued that sending the questionnaire to the hundreds of other mills would impose a major reporting burden. Response: As explaine d 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 i nformation collection to gather all of the information useful for performing all of the regulatory

reviews. W e understand the concerns that the commenters have regarding the large amount of information requested of them in such a short time. We are constrained b y 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 ty pe (i.e., pulp and paper production units versus chemical recovery combustion units ) with different submittal dates as follows: Part I

- Mill Ov erview and Subpart S Data a. One

- page notification of true area source, non

- operational, or non

- applicable status (due in 20 day s) b. Completion of Part Idata submittal (due in 30 day s) Part II

- NE I Update (due in 100 day s) Part III

- Chemical Recovery Combustion Sources (180 day s) 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 appl y 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 Iand II appl y for all mills that are not exempt from the survey. Part III applies onl y for pulp mills that operate chemical recovery combustion sources.
Part Iof 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 b y 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 MM9

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 uni ts 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]). Inaddition to providing more time for completion of the NEIupdate , we streamlined the NEI update as follows:

 M ade an y NE I 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 clarifie d 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 resp ondents 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 aw aiting 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 c ommenter s ( 0009 , 0010, and 0011 ) stated that EPA un derestimated the industry burden for responding to the questionnaire and allow ed too little time ( 60 day s ) to respond to a very

lengthy questionnaire. Commenter 0011 stated that the scope of the proposed questionnaire and the time provided for responses w er e unreasonable and unnecessary

. C ommenter 0011 stated that EPA’s estimates of the time and cost to complete the survey are particularl y low for the mills in their state , given that th os e mills are larger than average. C ommenters 0009 and 0011 stated that, i f EPA goes forward with the survey content as proposed, industry

would need at least 120 day s to review the IC R, get clarification on any necessary items that are not understood, collect the information requested (assuming all of the information reques ted 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 th e information to be submitted. Commenter 0010 estim ated that 3 to 15 work months (90 to 450 work day s) for one person will be necessary to complete the survey , based on their staff’s review of the survey elements. According to commenter 0010, the ir 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 sur

vey , EPA may

inadvertentl y 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 f acility ’s survey

. C ommenters 0009 and 0011 noted that most of the time to prepare and complete the I CR is dedicated to updating the National Emissions Inventory (NEI ) data for each facilit y for 2009.10

The two commenters also noted that EPA estimate d only 1 6 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 emissi on 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 likel y not even enough to QA the data entered b y EPA for a large integrated pulp and paper facilit y. The commenters noted that EPA is also requesting additional columns of information that mills have not previously

provided (e.g., maximum hourly emissions). C ommenters 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 Act ivity 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 Ai r 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 sp readsheet 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 em ission 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 si nce 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 annual11

emissions inventory

(AEI). The two commenters provided the following subcategories and time estimates for completing the NEI portion of the survey :

 Facilit y previousl y submitted NEI for RTR and reports toxics in their AEI : 40 ho urs for preparation and 40 hours for data entry

 Facilit y previousl y submitted NEI for RTR and does not report toxics in their AEI : 120 hours for preparation and 40 hours for data entry

 Facilit y that did not submit an NEI for RTR and reports toxics in thei r AEI: 180 hours for preparation and 60 hours for data entry

 Facilit y 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: T he 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 m ore time to complete the full survey . Part I(Mill Overview and Subpart S Data) is due after 30 day s, Part II (NEI Update) is due after 100 day s, and Part III (Chemical Recovery

Combustion Sources) is due after 180 day s. We recognize that the NEIupdate is likely to be the most time consuming part of the survey , and therefore, have provided additional time beyond the proposed 60

- day s for completion of the NEI update. We have also reduced the proposed scope of the NEI update (e.g., b y making revisions/ad ditions 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 b oiler questions; only request information on a dditives 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 liste d above (NEIupdates, inventory , and the CEMS spreadsheet) are re asonable, and we are increasing these burden estimates, accordingl y. We have also adjusted the burden estimates to reflect the 3

- part streamlined survey

. Because we are requesting onl y off

- the

- shelf process flow diagrams, with respondents marking up dates 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 b y the commenters)

. Similarly , because we are onl y requesting information on a dditives with “measurable” amounts of HAP ,” with “measurable” defined in a way that should signif

icantly reduce the scope of the information request , we increased the burden estimate for this respondent ac tivity from a proposed 8 hours to 20 hours (instead of 40 hours as suggested b y 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 day s 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 e xpect 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 th ey have in progress or are planning under EPA’s GHG Tailoring Rule for T itle V and Prevention of Significant Deterioration ( PSD )

 Understanding and implementing as appropriate Industry Sector Guidance on application of Best Available Control Technologies (B ACT) for GHGs;

 Updates and addition s 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 require ments for sulfur dioxide ( SO 2 ), NO X , 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 - hazard ous 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 ( CI SWI ) rule for each boiler an d process heater onsite

. Commenters 0009 and 0011 also noted that companies may be responding to the I CR during the first part of 2011, which is a time when mill and company personnel who would be involved in responding to the I CR also are responsible for preparing numerous other reports to state and federal authorities (e.g. state annual emission inventories, T itle V permit annual compliance reports, Title III reports for the Superfund Amendments and Reauthorization Act ( SARA ) , etc.). Response: We underst and 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 hav e 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 day s, we are p roviding additional time for the industry

to complete the remainin g parts of the survey : Part II

- NEI update (100 day s) and Part III

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



### 3.4 Inventory Requirem ent 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 i nventory 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 emission s as ten times the average annual rate.

 S tartup, 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 readil y available in the format requested in the survey, i.e., facilities only

keep track of th e 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 d uring 2009. Response: Part II of the revised survey requests the following

. Field Des cription 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 em ission 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

di vided 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

. Inthe 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 hourl y emissions for purposes of risk modeling. We would14

prefer to have better site

- , process - , and /or pollutant

- specific data (where such data can be reasonabl y estimated) th an 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 ty

pes 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 r esponses “optional, ” and eliminated the malfunction fields. W e 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

me asured (e.g., with CEMS) or estimated such emissions. Again, we feel that individual mills would be in the best posit ion to provide the specific annual (tpy) and maximum hourly (lb/hr) emissions data f

or startup and shutdown periods

. Additional question s 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 fo r 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 sy stem 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 suppli ed to the Agency, it will inform our rulemaking eff orts 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 simpl y 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: C omme nters 0009 and 0011 noted that the I CR requests that each facilit y submit process flow diagrams , which EPA estimate s will only take 8 hours. According to the two commenters, s ome facilities prepared these types of diagrams for T itle V p ermit applications and renewals , but man y s tates 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 w ill be outdated, will not contain all of the information and identifiers EPA is requesting, and man y 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 tim e to prepare these documents has been underestimated. The15

commenters estimate d 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 i t is unrea sonable for EPA to specify in great detail the information that needs to be in cluded 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 un derstanding was that this I CR would not require mills to generate new information , which the commenters said would not be the case for mo st 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 ty pe 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 (thereb y eliminating the need for follow

- up calls to many of the mills ). Respondents can use whateve r diagrams they

have, and hand mark an y changes/notes if needed. Respondents can also for e go the labeling of each emission unit with IDs. We have revised the survey instructions to clarify these points. 

### 3
. 6 HAP A dditives Comment: C ommenter s 0009 and 001 1 noted that the IC R requests that each facility submit information on the HAP additives used at the paper machines. The two commenters stated that m any

facilities are constantl y changing additives and trying new additives to improve product quality

and d evelop 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 alway s willing to share their formulations because it is proprietary information, so mills would need time to contact the man y additive suppliers and request information on the amount s of the six HAP in each additive. The commenters noted that p ulp 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 an y 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 Safet y Data Sheets (MSDS) for an y carcin ogens that are present in amounts greater than 0.1 percent and an y non - carcinogens that are present in amounts greater than 1 percent

. Th e commenters indicated that th is information will be available from suppliers, and the commenters recommend ed that “ me asurable ” amounts be based on th ese criteria. The commenters also request ed 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 acknowledg e 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 we16

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 defin ition 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 hav e 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 dail y 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 necessaril y to the air), the HAP additives information would be used to evaluate work pra ctices related to additives. Therefore, a question has been added to the survey asking mills i f they

are aware of an y non - HAP substitutes for the HAP additives included in their response. Mills are also asked to indicate if any of the additive substitute s they

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

.17 

### 4 .0 NCASI Emissions Infor mation
Comment: Two c ommenter s ( 0009 and 0011 ) offered the following responses to EPA’s statement (o n page 8 of the Supporting S tatement) that NCASI ’s emissions test data may be out

of

- date and only

represent NCASImembers

. First, the commenters noted that NCASIissued updated Technical Bulletin No. 973 in February 2010 for Air Toxics emissions for Pulp and Paper Mill Sources. Acc ording to the commenters, the update included new site

- specific data and eliminat ed data that w ere old or not representative of the industry

. In addition, the commenters stated that NCASIu sed the latest statistical techniques to address both non

- detect v alues and outliers. Second, the commenters argued that, while the survey would request emissions inventory data from other non

-NCASImembers, 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) u se older NCASIemission factors if they

were previous members of the association, or (3) obtain updated NCASI data through other unapproved sources. Accordi ng to the commenters, i n 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 NC ASIfactors, and stated that it is important to note that th ese data have been recentl y updated. The commenters noted that the NCASIdatabase 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 repre sents their mill

. According to the commenters, the emissions estimates for non

-NCASImembers may be based on older facto rs and/or omit compounds detected b y 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 b e very different. The commenters argued that, as EPA examines the data and performs the risk analy ses, 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 th e 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 NCASImember mill s will likely be based on updated factors , while other mill inventorie s may not. We also recognize that different mills may use different emission factors from the same NCASIdata set. We are not prescribing how mills should estimate their emissions. We are, however, requesting that survey respondents provide their emissi ons data source in the Part II NEI update

.18 

### 5 .0 Power Boiler Information
Comment: C ommenter s 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 - c ondensable gas vents regulated under 40 CFR Part 60 Subpart BB and 40 CFR Part 63 Subpart S. While the two commenters acknowledge d that these units can be part of the compliance approach for these regulations, the commenters did not believe that EPA shoul d 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 destroye d 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 th e Boiler MACT ICR database contains detailed info rmation for each boiler . T herefore , the commenters recommended that power boiler information should not be requested again in th e pulp and paper IC R. According to the commenters, the information requested should be limited to the ty pe 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 by

passed these control devices due to their unavailability

. Response: W e 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 a pproximate 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 anal ys es for fuel

- fire d 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 mi ll

- 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 time

consuming 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 destro yed in the boiler and are subsequently

unaffected b y 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 rel yi ng on the boiler MACT data set for following reasons:19

 T he boile r data collected through the pulp and paper survey will be for the 2009 base ye ar con sistent with the remai nder of the pulp and paper data collected (including the NEI data) , as opposed to an earlier base ye ar for the Boiler MACT data set.

 T he limited fu el ty

pe 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 matc h the B oiler MACT equipment IDs with the NEI emission unit IDs provided in the pulp and paper survey ’s NEI update (and past experience with this ty pe of exercise suggests that it would be nearl y impossible to match all of the boilers)

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

### 6 .0 State

- Only Permit Limits
Comment: Commenter s 0009 and 0011 noted that the I nventory tab of the s urvey requests permit limits for each unit affected b y the I CR. The two commenters agree d that each facility should report federall y enforceable limits, but recommended that state

- onl y limits not be included. The commenters argued that state

- onl y limits on criteria pollutants and toxics derived from modeling anal ys es often do not repres ent 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 analy ses 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 m odeled rates included in permits as state

- onl y limits are often much higher than actual or potential emissions and would not give EPA an y meaningful information. According to the commenters, l imits are often on a source - by

- source basis and take up several pages in the per mit, 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 b y each part of the survey

. Mills may provide all permit l imits 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 Inve ntory 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 ty pical 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 th is same language. In addition, we added a statement in the revised survey spreadsheets stating that mills do not have to provide every li mit for pollutants with multiple limit s 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 Iand Part III survey instruction document s (like the propo sed instruction document) include a table of suggested units of measure for p ermit 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 readil y 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 subpa rts 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 specificall y state, “Please do not enter State lb/hr or tpy emi ssion 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 the ir 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: Commenter s 0009 and 0011 note d that EPA is request ing information on

“potential changes. ” Th e two commenters argued that th is information is not appropriate and recommended that th e tab be removed entirel y , for three reasons. First the commenters noted that f acilities are in a continuous cycle to determine how to improve their operations and evaluate the impact of potential regulations. The commenters stated that, d

ue to the ever

- changing market and regulatory climate, many

of these potential projects are either never seen to complet ion or are modified due to changes in regulatory requirements. The commenters argued that the information requested is constantly changing, would be out of date b y the time EPA was finished anal yz ing the information, and would change again based on the outcome of EPA’s anal ys is. Second, according to the commenters, the request for information on an y potential changes within the next eight years aggravates the problems described previously

. The commenters argued that it is mere speculation to talk about wh at 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 p arenthetical 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 p ulp and p aper 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 compani es generall y would not be willing to share such “potential projects ” in a public forum. Response: We acknowledge the issues noted b y the commenters with respect to supplying information on potential changes. The Potential changes tab was originall y inclu ded 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 wo uld be to look at the number of new sources and modifications that have occurred over the past 5 ye ars and project forward the same number of new sources and modifications for the upcoming 5 ye ars (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 ty

pe of projection.23 

### 8 .0 Technical Clarifications 8.1 Nom inal Throughput Data Comment: Two c ommenter s ( 0009 and 0011 ) indicated that the survey needs to be consistent in its terminology

. According to the two commenters, d ata requests are inconsistent in requesting either design, potential or actual data. The commenters recommend ed that EPA request no minal capacity data. Response: In response to the comme nt, 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 suff ice for market pulp and paper/paperboard for 2009. [Note: The revised survey ’s Mill tab was formerl y the information to the right of the orange line in Facility tab of the proposed survey .]

 In the Part I Equip detail tab, r eplac ed the word “throughput” with “capacity” for the causticizing area to request “Causticizing area capacity (use lime kiln tons CaO/y r)” and noted in the instruction row that lime kiln capacity is of interest.

 In the Part I Paper prod tab, added the word s “ 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 i ncluded example calculations to aid in understanding of the capacity utilization questions.

 In the Part III Equip detail tab :

o R eplac ed the words “feed rate” with “capacit y” for recovery furnaces to request

“ Spent liquor solids capacity , million lb BL S/y r (or million lb RL S/y

r for sulfite)” and noted in the instruction row that BLS/RL S feed rate capacit y is of interest.

o R eplac ed the words “feed rate” with “capacity” for semi chemical combustion units to request “ Spent liquor solids capacity , million lb/y r
. ”

o R eplaced the word “ rate ” with “capacity” for lime kilns to request “ Li me production capacity , ton/d

. ”



### 8.2 Em ission Calculation Method Code Comment: Commenter s 0009 and 0011 noted that i n the Inventory tab, the facility is asked to supply

an emission calculation method code. The two commenters rec ommend ed 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. ”24

Response: Ther e 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, w e 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 Code s apply

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### 9 .0 Other Specific Comments 9 .1 Equip Detail T

ab Comment: Two c ommenter s ( 0009 and 0011 ) offer ed the following comments on the production line, equipment capacity, and process tank questions included in the Equip Detail tab of the s urvey
. Regarding production lines, the two commenters noted that EPA is request ing that the facility designate each pulping line and then correlate the ancillary equipment to each line. The commenters w ere concerned that th is approach will lead to confusion. According to the commenters, while some mills do have straight p ulping 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 way s in the mill. For this reason, the commenters recommend ed that Column C in the Equip Detail tab be eliminated. Regarding e quipment capacity units , the two commenters noted that, f or several units, EPA requests capacity or thro ughput data in air

- dried tons of pulp ( ADTP )

. The commenters indicated that f

or 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 m any facilities do not use productio n - based emission factors for process tanks, but instead use lb/hr/tank emission factors published in NCAS I technical bulletins. The commenters also stated that s ome tanks can be used for different materials. Therefore, the commenters suggested that EPA request onl y the number of tanks that store each material. Response : Regarding the comment on production li nes, we agree with the commenters that some lines will not have dedicated equipment. Consequently , we have omitted the column referenced b y the commenters every where it appeared in the draft survey
. Regarding the comment on e quipment capacity units , the units were originally selected based on the units for emission factor s available in the literature (i.e., NCASI t echnical b ulletins) for those equipment

. However, in response to this comment, we have revised the Equip detail tab (in Part I) to ask for evap orator capacity in units of “ gal/min of weak black liquor

. ” In response to the comment on process t anks , we have revis ed the Equip detail tab (in Part I) to eliminate the request for annual tank throughput and are just request ing information on tank capaci ty

. We need tank capacit y (in gallons) to distinguish relative tank size (e.g., in case we develop subcategories) for any tanks not subject to subpart S that are determine d to have uncontrolled emissions of interest for RTR. The survey instructions for t ank capacity limit the number of tanks to be included. We are most interested in identifying an y tanks that are not already covered b y subpart S

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### 9 .2 Kraft Condensates Tab Comment: Commenter s 0009 and 0011 noted that the survey is constructed so a mill c an indicate that it treats its condensates for Subpart S either in a steam stripper or in the biological treatment sy stem. The two commenters note d that some facilities have both s ys tems and use them in combination to demonstrate compliance or have one as a back

- up s ys tem (e.g., when an operational problem with the stripper causes a decrease in collection and/or treatment). The commenters recommend ed that EPA include additional columns to note if the facility has both sy stems and if they

are used in combi nation or as a back

- up s ys tem. 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 (formerl y A, B, C, etc) with Roman numerals (I, II, III, etc) to minimize confusion with spreadsheet column numbering. 

### 9 .3 PCC Tab Comment: Commenter s 0009 and 0011 noted that EPA is request ing information on facilities that route process exhaust to a PC C plant. The two commenter s w ere unclear why this information is necessary

since these facilities are ty pically independentl y owned and operated under a s eparate air permit

. The commenters stated that the PCC plant is not part of the pulp and paper sourc e category

and requested that information on these plants not be included in th e 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 pro cess 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 pu lp 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

. W e w ant to understand th is 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 m inim ize the burden on survey respondents. 

### 9 .4 Em issions Test Data Tab Comment: Two c ommenter s ( 0009 and 0011 ) agreed with EPA’s request that each facility document the site

- specific data available and include a cop y of the most recent test reports for rev iew 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 hope d 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 burden27

of responding to this survey

. Parts I and III of the revised survey request emission s test data for the different equipment and pollutants listed in attachments to each of the instruction documents. We added acetaldeh yde and formaldeh yde to the list of HAPs for which emission test data are requested (along with methanol which has been us ed as a surrogate for these HAP) because acetaldeh yde and formaldehyde may be of particular interest for residual risk purposes. 

### 9 .5 Segregation of CBI Comment: According to commenter s 0009 and 0011 , the legitimate need to prot ect CBI from disclosure c an often considerabl y complicate the anal ys is of survey information, especially by interested members of the public. The two commenters urge d EPA to segregate those portions of the survey

that are likel y 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 anal ys is of information that likely will not be claimed as CBI b y most or all mills. As an example, the commenters indicated that the tabs in the proposed survey spreadsheet on pulp production, paper production, by products, 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 belie ve the survey already provide s sufficient mechanisms for segregation of CBI

- containing data . Specificall y, mills are requested to segregate their CBI b y shading red the CBI

- containing cells in the spreadsheet s and submitting the CBI data separatel y, as sp ecified in section C2 of each survey instructio n document . Creating additional separate spreadsheet s within Parts Iand 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 onl y 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 b y man y mills. Respondents are encouraged to consider carefully which information they

report is trul y 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 r eported publicly (e.g. , through data available for purchase from RI SI ) . 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 i nformation submitted with a confidentiality

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### 10.0 CEMS Data
Comment: Commenter s 0009 and 0011 noted that, i n the I CR , EPA requests only 30 day s of CEMS data

. T he two commenters argued that this wa s 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 request ed 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 hourl y average opacity column “ optional ” since mills ty picall y demonstrate compliance based on 6

- minute averages. The column was retained in case an y mills have data in hourly

average form (but not 6

- minute averages).

 Clarified (in the sur

vey 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.