### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 1 

# Pulp and Paper Sector Survey

Instructions for Part I II: Chemical Recovery Combustion Sources

2 / 4 /11

This survey overview document provides instructions for completing Part III the p ulp and paper survey. This

overview is organized as follows:

A. Part III Introduction

................................ ................................ ................................ ................................ ......... 2

B. Confidential Business Information (CBI)

................................ ................................ ................................ ........ 4

C. How to Submit Your Part III Survey Response

................................ ................................ ............................... 4

C1. Submitting Your Non

- CBI Response

................................ ................................ ................................ 4

C2. Submitting CBI

................................ ................................ ................................ ................................ . 5

D. How to Complete the Part III Survey

................................ ................................ ................................ .............. 5

D1. Process data (P&P survey_PIII.xls)

................................ ................................ ................................ .. 5

a. PIII Equip detail tab

................................ ................................ ................................ ................. 9

b. PIII Permit limits tab

................................ ................................ ................................ ............. 12

c. PI II Controls tab

................................ ................................ ................................ .................... 13

d. PCC tab

................................ ................................ ................................ ................................ .. 14

D2. Test data

................................ ................................ ................................ ................................ .......... 14

a. PIII Emissions test data tab

................................ ................................ ................................ ... 14

b. CEMS data spreadsheet (P&P CEMS_PIII.xls)

................................ ................................ .... 15

D3. Optional cost data

................................ ................................ ................................ ............................ 17

PART II I

- ATTACHMENT 1 Emission Units to Include in the Part III Pulp and Paper Survey Response

............. 18

PART III

- ATTACHMENT 2 Part III Emissions Test Data Request

................................ ................................ ........ 19

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 2 

## A. Part III Introduction

The pulp and paper sector information request applies for pulp and/or paper/paperboard mill s that are a major source or synthetic area source of hazardous air pollutant (HAP) emissions that: (a) Perform chemical wood pulping (kraft, sulfite, soda, or semichemical ), or (b) Perform mechanical, groundwood (e.g., thermomechanical pulping (TMP), refiner mechanical pulping (RMP)), secondary fiber, and non

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

As defined in 40 CFR Part 63, subpart A,

“ Major source ” means any stationary source or group of stationary sources located within a contiguous

area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants, unless the Administrator establishes a lesser qu antity, or in the case of radionuclides, different criteria from those specified in this sentence.

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

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

Certain mills are not required to complete the pulp and paper sector survey. If your mill meets one of the following conditions, then you should have complete d the form in Attachment 1 of the Survey Overview document and

submitted it to Bill Schrock ( EPA ) before beginning Part I of the survey. Conditions for exemption from all parts of the pulp and paper sector survey are as follows:

• Your mill is not a major source or synthetic area source of HAP emissions, or

• Your mill was not operational in 2009 (and remains closed), or

• Your mill does not produce pulp, perform bleaching, or serve as a primary manufacturer of paper or paperboard products.

Part III of t his information request applies for pulp mil ls that are a major source or synthetic area source of hazardous air pollutant (HAP) emissions that perform chemical w ood pulping (for example, with the kraft, sulfite, soda, semichemical or other pulping process).

This survey is to be completed in a Micr osoft Excel spreadsheet file that is divided into several worksheets (“tabs” within the spreadsheet file ). You must complete certain tabs of the survey spreadsheet (depending on the type of mill you operate). T a ble 1 below denotes which survey spreadshee t tabs to complete depending on mill type

. Additional spreadsheets are provided for submittal of continuous emissions monitoring system (CEMS) data or control measure cost information.

Please complete the survey for the facility listed in the Section 11 4 letter you received in the mail. If you received more than one Section 114 letter for multiple facilities, you must create a separate survey response for each facility. If you have not already received or downloaded a copy of the survey spreadsheets, the y can be downloaded here: https://icr2010.rti.org/Industries/PulpPaper.aspx

Use t he 2009 calendar year as the base year for all survey responses (e.g., 2009 emissions inventory, 2009 capac ity

, 2009 equipment configurations , etc

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

.

Part III of this survey asks questions about the chemical recovery combustion sources listed in Attachment 1 to this

docume nt. Section D, How to Complete the Part III Survey , explains how to treat various configurations of emission units (e.g., multiple emission units venting to the same stac k, etc.) for each survey tab. Attachment 2 of

this document contains a table of emis sion units and pollutants for which existing emission test data are requested

under Part III.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 3 Use the following attachments to the Survey Overview document for reference: Attachment 2: Regulatory definitions from the kraft pulp mill new source performance standards (NSPS) (40 CFR Part 60, subpart BB), chemical recovery combustion source national emissions standards for hazardous air pollutants (NESHAP) (40 CFR Part 63, subpart MM), the pulp and paper production NESHAP (40 CFR Part 63, subpart S) , and selec ted definitions from

the NSPS and NESHAP General Provisions

. Attachment 3: Acronyms and abbreviations used throughout the survey and associated spreadsheets.

Table 1. Part III Survey Spreadsheets and Tabs to Complete Spreadsheet and tab Types of mi lls that should complete this spreadsheet tab

P&P survey _PIII .xls

PIII Equip detail All mills subject to Part III

PIII Permit limits All mills subject to Part III (unless permit limit information for Part III emission units was provided in Part I)

PII I Controls Mills with add

- on air pollution controls on chemical recovery combustion sources

. PIII Emissions test data Mills operating emission units for which test data are requested in Attachment 2 to
this document. Also, any mills that postponed submi ttal of Part I emissions test

data until Part III.
P&P CEMS_PIII .xls CEMS data (separate tabs

are included for different pollutants) Mills operating CEMS on chemical recovery combustion sources. Also, any mills that postponed submittal of Part I CEMS dat a until Part III.

P&P costs OPTIONAL_PIII .xls (Completion of this spreadsheet is optional)

APCD costs Mills that installed selected air pollution controls (see section D3) Equip change costs Mills implementing selected process or equipment changes (see section D3)

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

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

.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 4 

## B. Confidential Business I nformation (CBI)

The EPA's procedures for handling confidential business information (CBI) are described in the letter (and attachments) accompanying the pulp and paper information collection request (ICR). If you believe that providing any specific information to us would reveal a trade secret, please identify this information clearly in your spreadsheet response by shading the spreadsheet cell containing the CBI with red highlight and indicat ing in the red

block at the to p of each spreadsheet tab that the tab contains CBI

. (You will find the red highlighting and red CBI block at the top of the spreadsheet helpful when you separate your CBI data from non

- CBI for submittal as indicated in section C2 below). Also, please cl early label any attachments submitted with your survey that contain CBI. However, please do not label your entire response as CBI if only a portion includes trade secrets

. The EPA is likely

to follow

- up with a request for validation of CBI claims for mil ls claiming large amounts of information as trade secret, especially information that is readily reported by other mills without such claims

.



## C. How to S ubmit Your Part III S urvey R esponse

If your response to this information collection request include s data with a claim of CBI , you should follow the instructions in this section to ensure the protection of your data. Please note that if you submit CBI, you will be separating your data into two portions and sending your data to EPA using two different m ailing addresses

.



### C 1

. Submitting Your N on

- CBI Response

Follow these instructions for the non

- CBI portions of your survey response (or for responses that are entirely non

CBI.)

After you have completed and reviewed your survey response

, sign and date the certification form in Attachment 4

of the S urvey O verview document. R emove the CBI components from your survey as instructed in section C2

, leaving only the red shading and replacing the CBI data with the letters “CBI” . Save the Excel spreadsheet (s) containing the non

- CBI portion s of your completed response, emission test reports, and any other electronic non

CBI attachments on the flash drive you were provided with your section 114 letter (or on a CD or DVD). Assemble

any non

- CBI hard copy attachmen ts to your survey (such as the signed certification form or test data). Please clearly label and m ail the non

- CBI flash drive (or disk) and any non

- CBI hard copy materials in one envelope to EPA at the address specified below by the specified response dea dline in the Section 114 letter. ( Note: If the spreadsheet/ attachments contain CBI, use the address for Mr. Morales provided in section C2 of this document .)

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

U.S. EPA M ailroom (E143

- 03)

Attn: Mr. Bill Schrock

109 TW Alexander Drive Research Triangle Park, NC 27711

EPA recommends sending your non

- CBI files via Registered U.S. Mail using return receipt requested, Federal Express, or other method for which someone must provide a signature upon receipt.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 5 C 2

. Submitting CBI

Follow these instructions for any portion of your survey response that contains CBI.

Please create and label a separate CD or DVD containing a version of your spreadsheet response with only the CB I portion of your data (i.e., only the red highlighted data in the survey spreadsheet ). Include on the disk any pages of attachments to your survey response containing CBI

, with the CBI portions of the pages clearly marked (e.g., highlighted or circled). Clearly mark the disk with the words “Confidential Business Information.” Send only these CBI files under separate cover to:

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

U.S. EPA Mailroom (C404

- 02)

Attn: Mr. Robe rto Morales, Document Control Officer

109 T.W. Alexander Drive Research Triangle Park, NC 27711

For the security of your data, EPA recommends sending your confidential files to Mr. Morales via Registered U.S. Mail using return receipt requested, Federal Express, or other method for which someone must provide a signature upon receipt.

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA. E

- mail

and facsimile are not secure forms of communication and should never be used to transmit CBI

.



## D. How to Complete the Part III S urvey

Your survey response will consist of emission test reports and completed Microsoft Excel spreadsheets. Separate Excel spreadsheet file s are provided for completion ( P&P survey_PIII.xls ; P&P CEMS_PI I I.xls ; P&P c osts
OPTIONAL _PIII .xls ). You must complete certain tabs of the P&P survey_PIII.xls spreadsheet file (depending on the type of mill you operate) as shown in Table 1 above. The P&P CEMS_PI I I.xls spreadsheet file is to be completed if you have continuous e missions monitoring data to supply. The P&P costs OPTIONAL_PIII.xls spreadsheet file is an optional spreadsheet file that can be completed to supply control measure cost information helpful for EPA’s regulatory analyses.

You will enter data into the whit e (unshaded) cells of the spreadsheets. Please do not enter data into the blue shaded area of the spreadsheet, or in the orange

- colored column headings.



### D 1

. Process data (P&P survey_PI II .xls)

In this portion of the survey you are asked to add data t o the various tabs in the P&P survey_PIII.xls spreadsheet. Many of the instructions you need for completing the survey tabs are included in the “Instruction” row of each tab in the P&P survey_PI II .xls spreadsheet. However, more detailed instructions for selected tabs are provided below to account for common situations and to provide information on how the data will be used by EPA. Each survey tab includes fields with pull

- down menus for common entries. Use these pull

- down menus whenever possible, or wri te in information if your selection is not contained in the pull

- down menu.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 6 Several IDs are requested throughout Part III of the the pulp and paper survey response spreadsheet(s), including:

• NEI Site ID

• Emission Unit ID

• Collection system ID

• APCD_ID

The NEI Site ID and Emission Unit ID should correspond with the IDs used in the NEI update (Part II of this survey) where such IDs exist. If no NEI Site ID already exists (e.g., in cases where no previous NEI data exists for your mill), then you should use “NEW_____” for the NEI Site ID where the blank is your mill’s zip code, as this will (in all likelihood) provide a unique identifier for your mill. If Emission Unit ID(s) for selected process units do not already exist in t he NEI data set, then you may use any Emission Unit ID you choose (for example, the ID used in your permit), and this same ID should be used throughout all Parts of the survey. You will specify the Collection system ID and APCD_ID in the P II I Equip detail and other spreadsheet tabs.

A Note About Identification Numbers ( IDs )

The different parts of the pulp and paper survey include the following IDs:

• NEI Site ID

• Emission Unit ID

• Collection system ID

• APCD_ID

It is imperative that you use the same IDs to describe the same facility, equipment/emission unit, and emission release point throughout all parts of this survey. These ID codes will be used to link the various pulp and paper data base tables together into a functiona l an d informative data base to be used for regulatory analyses . You may choose your own IDs (e.g., based on Emission Unit IDs already included in the NEI, IDs from existing process flow diagrams, IDs in your air permit, etc.), but the IDs you choose must be c onsistent throughout your survey response. If you wish to avoid

follow

- up calls regarding your survey data, please make every effort to ensure that your IDs match throughout the spreadsheet (s) and in each part of your survey response. For example, any Emission Unit ID or APCD_ID you create/specify in Part I should also be used when referring to the same piece of equipment in Parts II and III for this survey response.

Also, please be sure that no extra spaces or characters are included in th e ID cells

. For example,

Emission Unit ID “DIG1” is not read the same as “DIG

- 1” or “DIG

- 1_” by data base software. Why does EPA need process data ? Facility and equipment details are being request ed to inform the technological review of the pulp and paper NE SHAP and NSPS and to provide information on means of reducing residual risk . While the

N EI update (requested in Part II of this survey) provides EPA with data related to emissions release points (e.g., mass emission rate and stack exit parameters used for risk analysis and tracking nationwide trends), the technological review of the NESHAP an d NSPS standards considers emission unit and control equipment details specific to the processes employed and matches these details to emissions levels that are achieved (e.g., emission concentrations). A pplicability of the NESHAP and NSPS compliance opti ons depend s on the specific process equipment.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 7 What if I have difficulty pairing emission units wit h corresponding Emission Unit ID s in the NEI?

Having Emission Unit IDs in Part I/III and the NEI matching as closely as possible will help tremendously as EPA analyzes the survey data (for those instances where we need to link the NEI and Part I/III data). However, we realize that information may be presented in the NEI differently than we are requesting it in the Equip detail tabs of Parts I/III of the pu lp and paper survey. The Equip detail tabs and the NEI serve two different purposes, so this is to be expected. Instructions for handling difficult matches between the NEI and Part I/III are below:

1. When there is no corresponding Emission Unit ID in the NEI, then you should make one up (6 text characters or less) to use in Part I and/or Part III. If you add the emission unit to the NEI in P art II, then use the Emission Unit ID you made up for Parts I/III.

2. In some cases there may not be a one

- to

- one correspondence between an existing NEI Emission Unit ID and the equipment listing requested in the Part I /III Equip detail tab.

Example 1 : An existing Emission Unit ID in the NEI may represent a grouping of equipment (e.g., “PSC” for 4 pulp storage chests), but these equipment need to be listed separately in the Equip detail tab. In this case, you should make up a similar Emission Unit ID for the Equip detail tabs of Parts I and III (e.g., PSC

- 1, PSC

- 2, PSC

- 3, PSC

- 4), and then add a note in the Equ ip detail tab “Process notes (optional)” column to indicate the corresponding NEI Emission Unit ID of PSC as shown below:

Emission Unit ID Process notes (optional)

PSC

- 1 NEI Emission Unit ID (covering 4 tanks) = PSC

PSC

- 2 NEI Emission Unit ID (cover ing 4 tanks) = PSC

PSC

- 3 NEI Emission Unit ID (covering 4 tanks) = PSC

PSC

- 4 NEI Emission Unit ID (covering 4 tanks) = PSC

Example 2 : Suppose the NEI contains 2 or more Emission Unit IDs for a given piece of equipment (such as a single paper ma chine’s forming section {SN23} and burners {SN24}). In this case you need to pick a single representative Emission Unit ID (e.g., SN23) to use in the Part I/III response.

Example 3 : Suppose a single NEI Emission Unit ID is provided for many pieces of u nrelated equipment at the mill, but the NEI Process ID varies for the equipment (e.g., NEI Emission Unit ID = 001 for all equipment at the mill, but each emission unit has a unique Process ID {01, 02, 03....}). This is not common, but is the case for at lea st one mill. In this situa tion, it is suggested that the Emission Unit ID used for Part I/III be 001_01 for NEI Process ID 01; 001_02 for NEI Process ID 02, 001_03 for

NEI Process ID 03 etc.

3. If respondents unfamiliar with their pre

- populated NEI dat a are unable to match one or more NEI Emission

Unit IDs with emissions unit ( s ) at their mill (using the SCCs as a guide) , then it is suggested that the respondent flag the unmatchable NEI data for deletion in Part II, and replace it with revised NEI data f or identifiable

emission units. Include the identifiable Emission Unit IDs in Parts I/III.

Other tips:

• The NEI requires Emission Unit IDs to be limited to 6 characters.

• You may use the “Process notes (optional)” column in the Part I/III Equip detail tab s to clarify any matching discrepancies with the Part II NEI. These notes will assist EPA in analyzing the data and prevent confusion.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 8 In several parts of the survey, the agency requests “nominal daily throughput capacity.” These values are typical operating rates for the process or emission unit and can be used by the agen cy to compare the relative size of the unit. You may use the pulping line nominal capacity (throughput) for all equipment in the pulping line. You may specify the nominal liquor solids or lime kiln throughput for equipment in the chemical recovery loop. The EPA is interested in capacity values that would be used for estimating emissions (for example, values used in your permit application). We are not interested in maximum capacity values for each piece of equipment outside of the

constra ints of the pul ping/ chemical recovery process within which it is located.

Follow the instructions below and in the “Instruction” rows of the spreadsheet to complete the survey tabs. Refer to Table 1 of this document to determine which tabs you must complete, depending on the type of mill you operate.

What if I do not know or have the information to answ er a survey question?

There may be survey questions that you do not know the answer to, or for which information is not readily available. The following codes may be used:

Unknown (UK): If you do not have the requested information, cannot obtain the information without extraordinary effort, and cannot provide a reasonable estimate, then you may enter

“UK” for unknown.

Not Applicable (NA): If a question is not applicable to your operations, then you may enter “NA” for not applicable.

Survey respo ndents are reminded that their certification of the accuracy of their response includes a certification that any identification of information as "unknown" or "not applicable" is accurate. Further, survey respondents providing an excessive number of respo nses as “UK or “NA” are likely to receive scrutiny and follow

- up inquiries from EPA related to their survey response.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 9 a

. PIII Equip detail tab

All mills covered by Part III are asked to complete the PIII Equip detail tab. This tab asks for information for each

individual emission unit. The purpose of this tab is to provide EPA with equipment

- specific details needed for the Agency to review the technology

- based standards (i.e., nationwide numbers of equipment, configuration of controls, pertinent equipment details, and regulatory compliance options used ).

T he types of emission units listed in Attachment 1 that you operate should be included in the PIII Equip detail tab. Columns A through A M ask generic questions for all emission units. The c olumns to the right of column AM request design and operating details for specific types of emission units (e.g ., recovery furnaces, etc.). The table below summarizes the different types of equipment for which specific questions are included in the PIII Equip detail

tab.

PIII Equip detail

tab columns Description of information requested

A

- A M Equipment, exhaust flow rate, controls, and Federal rule applicability for each emission unit and collection system. Complete these columns for all emission units

.

AN Black liquor gasification

AO

- AT Black liquor ox idation systems

AU

- BH Recovery furnaces and recovery furnace ESPs

BI

- BN Semichemical combustion units (at stand

- alone semichemical pulp mills)

BO

- BT Smelt/ash dissolving tanks

BU

- CB Lime kilns (including rotary lime kilns and fluidized bed calciners)

CC Fuel

- fired equipment

CD

- C E Equipment incinerating NCG or SOG

CF

- DN Primary and supplemental fuels

DO

- DU Emission unit startup and shutdown

DV Comments

Data are requested for each emission unit (and need not be broken out by individual emission po ints for a given

emission unit unless different collection or control measures apply for the different emission points from an emissions unit) or the characteristics of the emission points are different

. Specify the Emission Unit ID and Collection system ID (if applicable), and APCD_ID(s) by following the directions in the “ Instruction ” row of the PIII Equip detail tab. Some common configurations of emission units are addressed below.

Multiple emission units ducted to a single release point. L ist each e mission unit separately in the PIII Equip detail tab even if the exhaust from the emission unit is ducted to a common conveyance. For multiple emission units ducted through a common conveyance to the same release point, list each Emission

Unit ID separate ly and provide the same Collection s ystem ID for the different Emission Unit ID s.

Single emission unit with multiple release points

. In the PIII Equip detail tab, EPA is most interested in learning how (or if) your emission unit is controlled and what F ederal regulation compliance options are in

use as indicated in columns A through AM

. If the different release points (vents or stacks) have different controls or different NSPS/NESHAP applicability then you will need to list each vent (or group of vents with the same controls) on separate rows. Repeat the Emission Unit ID on separate rows and distinguish the release points using the “Emission unit description” column in as many rows as needed to reflect all of the release points associated with the emiss ion unit in the P II I Equip detail tab.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 10 For example , Emission Unit ID 001 (EU001) is vented to two stacks with different controls

. Split EU001 to EU001a and EU001b on separate rows of the P II I Equip detail tab, and then indicate in

the “Emission unit d es cription” column that EU001a and EU001b vent through separate stacks. Enter details associated with emission release (exhaust flow, APCD information and NSPS/NESHAP compliance options) in each row. Enter equipment details (year installed, hours

per year [hr/yr], combustion controls, fuel data, equipment design and other operating parameters) in only 1 row, leaving all other rows associated with the Emission Unit ID blank.

Emission units vented into the building. Include emissions units that vent into a building in the PIII Equip

detail tab, and enter “BLDG” in the “Configuration if not emitted through a conveyance” column.

Emission units that are not vented . Include emissions units that are not vented in the PIII Equip detail tab,

and enter “NV” in the “Configuration if not emitted through a conveyance” column.

Emission units with fugitive emissions . Include emissions units with fugitive emissions in the P II I Equip

detail tab, and enter “FUGITIVE” in the “Configuration if not emitted through a conveya nce” column. If an emission unit produces both fugitive emissions and emissions that are emitted though a conveyance, then you need to either: (1) specify the fugitive emissions on a separate row in the P II I Equip detail tab (e.g., as a “Single emission un it with multiple release points” as described in the instructions immediately

above for the P II I Equip detail tab), or (2) if you know the volume percent of exhaust flow captured from the emission unit (e.g., 60%), you could use only one row to represent t he emission unit and note 60% capture in the “Control capture efficiency” column without specifying vent

- by

- vent details.

Bypass stacks used only during certain times

. Do not include data for bypass stacks or control system bypasses in the PIII Equip d etail tab.

Air pollution control devices (APCD s )

. In the APCD columns, enter primary air pollution control devices (APCDs) (i.e., the pollution control used most frequently) in the sequence in which they are used to control

emissions from each emission u nit (or collection system) identified in the Emission Unit ID column. Enter a description of the APCD in the APCD “type” column and an ID code in the APCD_ID column. The ID you enter into the APCD_ID field will correspond with the APCD_ID you enter in th e Controls tab. For example,

I f you use an electrostatic precipitator ( ESP ) ( ESP1) followed by a scrubber (WSa), you would enter APCD1 type = ESP and APCD2 type = scrubber, and APCD1_ID = ESP1 and
APCD2_ID = WSa.

Complete the applicable equipment

- specif ic details requested in columns A N through DU for each type of emission

unit in the PIII Equip detail tab by following the directions in the “ Instruction ” row of the tab. Additional specific instructions are provided below for e quipment requiring instruct ions beyond what could be explained in the

“ Instruction ” row. Leave columns that do not apply for a given emission unit blank rather than entering

“NA”.

What averaging period should be used in responding to process detail questions?

Several questions in the P II I Equip detail and other su rvey tabs ask for process parameters such as exhaust flow rate (acfm), percent solids, temperature, etc. Unless otherwise speci fied, typical values are requested, and are subject to the respondent’s discretion. For example, if you measure a particular pa rameter with an online meter and you have data available for most operating hours of the year, then you may choose to supply an annual average for the parameter. However, if the parameter is only measured periodically, then you may want to provide the mos t recent measurement.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 11 All emission units listed in Attachment 1 . Comple te columns A throug h A M . These columns ask generic questions for all emission units related to how the emission units are vented and controlled, and related to Federal rule applicability . Additional questions in columns A N through D U may also apply for selected emission un it types.

Mills using the PM bubble compliance option

. I f your mill is using the PM bubble compliance option under MACT subpart MM, please identify process equipment and controls included in the bubble and submit separately your most
recent bubble calcu lations used for compliance demonstration. Please include the following in your calculation submittal: CaO production rate (ton/day), average volumetric gas flow (dscf/min), and average BLS firing rate (ton/day).

Recovery furnaces and semi chemical combus tion units

. Questions pertaining to recovery furnaces have been combined for kraft, kraft with co

- located semichemical, soda, and sulfite pulps. The equipment

- specific details will provide post

- MACT recovery furnace and semi chemical combustion unit confi gurations. Capacities and other design parameters are requested for purposes of impacts analyses. Conversion years (e.g., year DCE converted to NDCE, or year of wet

- to dry

- bottom ESP conversion) allow EPA to identify mills that might have relatively rec ent cost and other information related to equipment conversions. The combustion unit hottest temperature is requested

for semichemical combustion units in order to characterize the different types of semichemical combustion units.

Smelt dissolving tanks and lime kilns . These questions will characterize the population of smelt dissolving tanks and lime kilns following subpart MM compliance. Capacities and other design parameters are requested for purposes of impacts analyses.

Primary and s upplemental fu els

. Fuel types are requested for fuel

- fired equipment because fuel type can have an

effect on emissions . The EPA may consider fuel types and perform calculations based on fuel firi ng rates for various nationwide impact analyses. Because the types and a mounts of fuels fired can vary throughout the year

, EPA is requesting the approximate percent of annual heat input capacity in million British thermal units per year (MMBtu/yr) supplied by each fuel.

Primary fuel information is requested for fuel

- fi red eq uipment su ch as li me kilns . Prima ry fuels are not requested for recovery furnaces or semi chemical c ombustion units because black liquor (or red liquor) is assumed to be th e primary material combusted in these units. Non

- condens a ble gases (NCG) and stripp er off gases ( SOG ) are not considered to be either primary o r supplemental fuels for purposes of this survey. Supplemental and other fuel information is requested for recovery furnaces and semi che mical combustion units in addition to other fuel

- f ired equi pment such as lime kilns and thermal oxidizers. Information for s econdary and additional fuels used routinely

for multifuel

- fired equipment may be indicated in the supplemental and other fuel columns.

Emission unit s tartup and shutdown

. Complete the st artup and shutdown questions for all emission units currently subject to Federal or State emission limits or monitoring requirements. Questions pertaining to emission unit 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. The EPA is considering standards that c ould 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. The startup and shutdown questions would also identif y pulp and paper emission unit types for which startup and shutdown are not already

addressed with the current emission standards. You are asked to s upply information for routine startup and

shutdown events associated with planned process or mill downtime . (Do not provide information for unplanned startup/shutdown events associated with equipment malfunctions

. ) The st artup and shutdown data in the PIII Equip

detail tab are being sought for regulatory development purposes and will not be used for enforcem ent purposes.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 12 b

. PI II Permit limits tab

Permit limits for each emission unit/point listed in Attachment 1 of this document are requested. You do not need to complete this section if you provided the Part III emission unit permit limits in your resp onse to Part I (simply mark the box that appears in cell F3 of the PIII Permit limits tab to indicate permit limits were submitted under Part I)

.

If available in the permit, provide limits in terms consistent with the suggested units shown in Table 2 belo w. These suggested units were taken from existing Federal limits codified in 40 CFR P art 60

, subpart BB or 40 CFR Part 63

, subparts S or MM. Specify permit limits as written in the permit if the suggested units are not included in the permit. You do not need to convert limits to the suggested units. You may specify limits for a given pollutant in multiple units/formats (e.g., ppmdv and/or % reduction) if the permit is written to include multiple compliance options. However, you do not need to provide e very unit/format for pollutants with multiple limits in different units of measure or formats (e.g. , only provide ppmdv and lb/MMbtu at specified % oxygen ( O 2 ) for a combustion unit

SO 2 limit specified in the permit in terms of ppmdv, l b/hr, lb/day, and t py, lb/MMBtu at specified % O 2 , etc. ). The survey spreadsheet allows for up to five different permit limit formats for the same pollutant. Permit limits of most interest to EPA are 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. EPA will use the permit limit information you supply in comparing permit limits across simi lar emission units nationwide. Please be as specific as possible when entering permit limit units. Include any oxygen correction factors (% O 2 ). Be sure to note if ppm values are on a dry (d) or volume (v) or weight (w) basis if specified this way in yo ur perm it (ppmdv, ppmdw, ppmv, ppmw). Please note:

State Mass

- based Limits : Mass emission rate limits (lb/hr or tpy), or limits based on state

- only required modeling, are not being requested unless this is the only way in which limits are specified in t he permit. The EPA is most interested in state permit limits that are more stringent than those limits in federal rules (e.g., PSD Avoidance or BACT limit s ).

Permits restating NESHAP and NSPS limits . Your permit may simply restate the emission limits contained in Federal rules such as NESHAP subparts S a nd MM . 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 Fed eral 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. If your permit contains additional State limits in terms other than the Federal limit, please indicate these limits in the appropriate column (e.g., Column G for permit limit 1, Column J for permit limit 2, etc.) Please do not enter State lb/hr or tpy emission limits in addition to the Federal limits.

Opacity . The opacity l imits of most interest to EPA are those for fuel fired equipment such as recovery furnaces, semi chemical combust ion units and lime kilns

. You do not need to include State opacity limits for every emission unit (only the fuel

- fired units).

Alternative to submit permit copy : The facility may also opt to send a pdf copy of their permit with the

survey. While we would prefer to receive data in the P II I Permit limits tab, we will accept a copy of your operating permit (e.g., title V operating permit) instead of the completed P II I Permit limits tab. Other complete and up

- to

- date summaries of permit limits

, such as a mill

- specific summary of permit limits or compliance matrix

, would be acceptable as well.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 13 Table 2. Suggested Units of Measure for Permit Lim its

Pollutant Suggested units

PM 1 Recovery furnaces/chemical recovery combustion units: gr/dscf @ 8% O 2 SDT: lb/ton BLS LK: gr/dscf @10% O 2 Other processes: lb/ton of throughput, lb/MMBtu, gr/dscf, g/dscm, or specify PM 10 1

PM 2.5 1

Opacity % (provid e averaging time)

TRS RF/combustion units: ppmdv @ 8% O 2 SDT: lb/ton BLS (as H 2 S) LK: ppmdv @ 10% O 2 Other processes: lb/ADT pulp and/or ppmdv

SO 2 lb/MMBtu and/or ppmdv or limits on fuel S content

NO X lb/MMBtu (as NO 2 ) or ppmdv

CO lb/MMBtu or ppmdv

Pb or other HAP metals Specify units

VOC lb/{production}, specify if as propane, etc. or ppmdv

THC Report as carbon.

RF/combustion units: l b/ton BLS

HCl ppmdv and/or % reduction

Methanol and gaseous organic

HAP chemical recovery combustion sources: l b/ton BLS process sources: ppmv @ 10% O 2 , lb/ton ODP, and/or percent reduction

Chlorine and chlorinated HAP ppmv, lb/ton ODP, and/or percent reduction Other speciated HAP (specify...) Specify units

1 Specify filterable and/or condensable if your permit li mits distinguish between the filterable and condensable PM

fractions.

c

. P II I Controls tab

Complete the PIII Controls tab by following the instructions in the “ Instruction ” row for add

- on APCD s used to

control the Part III pulp and paper emission uni ts listed in Attachment 1

. The data requested in the PIII Controls tab include pertinent control device design parameters that will be used by EPA to distinguish among control devices (e.g., pressure drop and L/G ratio can be used to identify high

- vs. lo w

- efficiency wet scrubbers) and to understand

the non

- air environmental impacts associated with the control devices (e.g., amount of wastewater or solid waste generated and methods for handling).

Actual c ontrol efficiency

. Actual control efficiencies a re requested for PM, TRS, HCl, SO 2 , and other HAP. This information will be used in determining the capability of different control devices for reducing emissions. If you have data from inlet/outlet emissions testing used to determine a percentage reduct ion in the requested pollutant across the control device, then you would enter this test result as the “actual” control efficiency. You may l eave the control efficiency columns blank (rather than marking as “NA”) if actual control efficiency is not known (or not applicable for a given pollutant).

Thermal oxidizers . Complete the q uestions pertaining to thermal oxidizers for thermal oxidizers or regenerative

thermal oxidizers used to contr ol Part III chemical recovery combustion units (e.g., semi

- che mical recovery units).

Control device s tartup and shutdown

. 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 control device startup and shutdown are asked in order to provide EPA with an understanding of the duration and definition of startup and shutdown events for the types of control devices used at pulp and paper mills. The EPA is seeking information on the integral nature of startup and shutdown events for the

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 14 different combinations of emission units and control devices used in the pulp a nd paper industry

. In addition, because Federal NSPS and NESHAP require continuous monitoring of emissions or control device operating parameters, information is requested to inform EPA of particular pulp and paper NSPS or NESHAP control device

parameter limits that cannot feasibly be met during startup and shutdown events. Certain parameters may be

"instant on" while others are more transient in nature (i.e., changing as startup or shutdown progresses) . Examples could include control device temperature that must heat up to a set point, or pressure drop that cannot be achieved due to low exhaust gas flow from the emission unit. The EPA will use this information to evaluate which existing control device parameter limits may remain in effect during startup and shutdown events, and which parameter limits may need to be replaced with another requirement during startup and shutdown. In all of the control device startup and shutdown questions, y ou are asked to s upply information for routine startup and shutdow n events associated with planned equipment or mill downtime. (Do not provide information for unplanned startup/shutdown

events associated with equipment malfunctions

. ) The startup and shutdown data in the PIII Controls tab are being sought for regulatory development purposes, and will not be used for enforcement purposes.

d

. PCC tab

Mills that route lime kiln, boiler, or other process exhaust to a precipitated calcium carbonate (PCC) plant should complete the PCC tab. Information regarding the pulp and paper emission units involved, time, controls, and portion of pulp and paper process exhaust routed to the PCC plant are requested. Questions regarding land ownership and permitting are also asked. This information would help regulation writers under stand the nature of this process and the relationship between pulp and paper mills and PCC plants

, should routing of exhaust to an onsite PCC plant need to be mentioned (e.g., with a special provision, exemption, etc.) in a regulation.

Complete the PCC ta b by following the instructions in the “ Instruction” row.



### D 2

. Test data

Attachment 2 of this Part III survey contains a table of emission units and pollutants for which existing emission s data are requested. Emissions data are being requested in the f orm of emissions test reports or continuous emissions monitoring data , whichever may be available. You are not required to conduct any new emissions testing or continuous emissions monitoring to respond to this survey

. Follow the instructions below for t he “ PIII Emissions test data tab” for emissions test reports. Follow the instructions for completing the “ CEMS data spreadsheet ( P&P
CEMS_PI I I.xls ) ” if you have continuous emissions monitoring system (CEMS) data instead of emission test reports for a give n emission unit and pollutant combination. The emissions test data collected will provide valuable information on current emissions levels and will allow EPA to consider variability in emissions from mill to mill (and over time for a given emission unit a nd pollutant) in reviewing and setting emission standards

. When submitting test data, EPA is requesting full test reports with field and lab data sheets and example calculations, not just summary reports.

Be sure to include any emissions test data or CEM S data required under Part I that was postponed until Part III for

submittal.

a. PIII Emissions test data tab

Attachment 2 of this survey contains a table of emission units and pollutants for which existing emission test data are requested. You are no t required to conduct any new emissions testing to respond to this survey. The EPA is only requesting existing emission test reports at this time as they may already be available

.

Review the test data request table in Attachment 2 of this survey. Loc ate any existing emissions test reports in your

files that match the test method and other criteria for each emission unit and pollutant combination requested. Emissions test data representative of your current operations are requested. You are not requi red to supply emissions data that are no longer representative of the current emission unit and control system configuration. For example, if you have installed controls or made significant process changes expected to change emissions

, then you

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 15 need no t s upply emissions data for the prior configuration. However, you may voluntarily supply emission s da ta for prior configurations, as such information would be useful to EPA in characterizing emissions in general (for non

site

- specific uses) , but we request t hat you identify that such data are no longer representative in the PIII Emissions

test data tab.

C utoff dates are provided in Attachment 2 for certain emission unit and pollutant combinations. More recent cutoff

dates (e.g., 2001 or date of MACT complia nce) are specified for emission unit and pollutant combinations expected to be widely available. Longer cutoff dates (e.g., dating back to 1990) are included for emission unit and pollutant combinations for which data are likely to be sparse. Test d ata p rior to the cutoff dates are requested only if necessary to obtain results of at least one representative test for a given process unit and pollutant.

Provide available test data for multiple years dating back to the cutoff date. Multiple years of test d ata will allow EPA to examine and account for variability in emissions in setting emissions standards

.

Supply both APCD inlet and outlet data if available.

As noted above, s ubmit full and complete copies of the emission test reports , to include field and lab data sheets and example calculations, meeting the criteria in Attachment 2 with your survey response. Electronic (pdf) or hard copies are acceptable. Include the summary portion of the report and any appendices showing run

- by

- run test
parameters , method detection limits, laboratory data, production data, example calculations, etc. EPA will extract the test data from the emission test reports for use in nationwide regulatory analyses.

Complete the PIII Emission s test dat a tab to identify the spe cific emission units and control systems for which

emission te st reports are being submitted, the pollutant tested, and the test method. The PIII Emission s test data tab will be used by EPA as the starting point for development of the emissions test data base that EPA intends to

construct based on the emission s test data received through this survey.

b. CEMS data spreadsheet ( P&P CEMS_PI I I.xls )

The EPA is requesting existin g CEMS data an d/or continuous opacity monitoring system (COMS) data for calendar year 2009 (CY2009) operations from facilities that have installed continuous monitoring systems. You are not required to install or operate any new CEMS or COMS to respond to this survey.

CEMS data that are representative of your current operations are requested. You are not required to supply CEMS data that are no longer representative of the current emission unit and control system configuration.

A separate Microsoft Excel spreadsheet file ( P&P CEMS_PII I .xls ) i s provided for submittal of the re ques ted CEMS data. The spreadsheet file contains individual worksheets (tabs) designed specifically for TRS (12

- hour block average), TRS (hourly), Opacity, and other pollutants ( NOx, SO 2 , CO, Methanol, HCl , and PM ) . Each worksheet is designed to accommodate data from one CEMS (including oxygen data) . If you have multiple CEMS (e.g., two

TRS CEMS on different emission units ), then you must copy the relevant worksheet in order to enter data for the

additional CEMS.

A brief introduction to each of the CEMS wor ksheets follows. Additional, field

- specific instructions are included on

each worksheet. An “EXAMPLE” completed worksheet is also provided as a separate tab within the P&P
CEMS_PI I I.xls spreadsheet file

.

TRS (12

- Hour Average) . This worksheet is designe d for recovery furnaces, smelt dissolv ing tanks, lime

kilns subject to the TRS monitoring requirements in NSPS subpart BB , but can be used for any emission

units with TRS CEMS (e.g., for compliance with State emissions standards which may be based on the T RS emissions guidelines) . Respondents are re quested to specify the Emission Unit ID (or C ollection system ID)

, the APCD_ID, and report the 12

- hour averages of CEM S concentration data for TRS for CY2009 operations

. In addition, respondents are asked to pro vide the highest single 12

- hour average TRS concentration recorded

in CY2009: (a) under normal operating conditions, (b) under conditions of startup or shutdown, and (c) under

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 16 m alfunction conditions

. [ Note: The reported concentrations of TRS should be cor rected to 8% O 2 for recovery furnaces and 10% O 2 for lime kilns and other equipment.]

TRS (1

- Hour Average) . Same as above, except that this worksheet is designed to accept the 1

- hour average

TRS data for the same time period as provided for the 12

- hour a verages.

Opacity . This worksheet is designed for recovery furnaces or lime kilns equipped with COMS but may be used for other equipment . Respondents are re quested to specify the Emission Unit ID (or C ollection system ID) and the APCD_ID, and report the 6

- minute average opacity for CY 2009 operations

. An optional column is also included for hourly average opacity for mills that calculate an hourly average. In addition, respondents are asked to provide the highe st single 6

- minute average opacity recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or shutdown, and (c) under m alfunction

conditions

.

Other pollutants (such as NOx, SO 2 , CO , total HAP, methanol, HCl, or PM)

. This worksheet is designed for any emissions unit equipped with a CEMS. Specify the continuously monitored pollutant at the top of the

worksheet. Respondents are requested to specify the Emission Unit ID (or C ollection system ID) and the APCD_ID (or type of combustion controls used), and report th e 1

- hour averages of the CEMS data for CY2009 operations. In addition, respondents are asked to provide the highest single 1

- hour average concentration recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or shutdown, and (c) under m alfunction conditions

.

OPTIONAL

- CEMS cost . Completion of this worksheet is OPTIONAL. This worksheet requests equipment cost data for CEMS or COMS installed within the past 10 years. EPA can use these data to estimate costs of

CEMS o r COMS when evaluating monitoring options.

What if my data are not in a form that can be inserted into P&P CEMS_PIII.xls ?

It is very helpful for EPA’s data ana lysis purposes if data are entered into the P&P CEMS_PIII.xls template provided. However, we understand that some CEMS software may not be configured to provide output that can be easily converted to our preferred spreadsheet

format. We also understand t hat, in some cases, the hourly production data requested in the CEMS spreadsheet may not be coupled with the CEMS data or may not be available in a manner to be easily linked to the CEMS data. If you face these or related issues, please note

that EPA is n ot asking you to hand enter hard copy CEMS data into the spreadsheet. You may provide CEMS data in an alternative format if you are unable to convert it to our spreadsheet format within the timeframe for this survey. We request that you provide CEMS data in a form suitable for analysis if possible (e.g., spreadsheet or data base format is preferred over read

- only pdf format). We’d accept more recent CEMS data (e.g., from the most recent 6 months) if 2009 CEMS data are no longer in electronic form due to company records retention policies. Further, you may omit the production data if they cannot reasonably be included in your CEMS spreadsheet. Estimates of production data are acceptable (e.g., if you have a daily production rates, you may divide by 24 op erating hours in a day to estimate hourly production).

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 17 D3

. Optional cost dat a

The EPA requests information related to the capital and operating costs of selected air pollution controls or process/equipment changes. Providing this co st information to EPA is optional at this time

. The Agency wishes to receive enough cost information on a voluntary basis to perform regulatory analyses. However, should additional cost information be needed, EPA reserves the right to follow up with mill s that have installed equipment or implemented process changes of interest to request cost information under CAA section 114 authority.

The spreadsheet entitled “P&P costs OPTIONAL _PIII .xls” can be completed to provide cost information. This spreadsheet contains two tabs ( APCD costs and Equip change costs ). The EPA recognizes that cost information can

be sensitive. The “P&P costs OPTIONAL _PIII .xls” spreadsheet contains a red block at the top of each tab where you can indicate if the tab contains CBI, o r if the entire tab should be treated as CBI

. Responses containing CBI should be submitted according to the instructions in section C 2 of this document.

Any cost information that you provide would be very useful to EPA for purposes of evaluating the cost s of control measures that may be considered as regulatory options. These cost data will be used by EPA to estimate the

nationwide costs of any regulatory options based on the control measure indicated. Cost information from within

the last 10

- 12 years i s requested (e .g., costs dating back to 1998). The c ost information could come from vendor quotes for APCD or equipment changes that either have been implemented or were explored but not implemented.

For Part III, t he EPA is particularly interested in costs of the following APCD s . Please supply this informati on using the APCD costs tab:

- Recovery furnace scrubbers, dry sorbent injection/fabric filter (DI/FF), selective catalytic reduction (SCR), or

selective non

- catalytic reduction (SNCR)

- Black liquor oxidizer incinerators or thermal oxidizers

- Lime kiln ESP

The EPA is particularly interested in costs of the following process changes or equipment changes/upgrades. Please supply this information using the Equip change costs tab

.

- Changing from a direct contact evaporator (DCE) to non

- direct contact evaporator (NDCE) recovery furnace

- Changing from a wet bottom ESP to a dry bottom ESP

- Changing from a wet PM return system to a d ry PM return system for your ESP

- Addi ng chambers/fields to an existing ESP

- Installation of quater nary air ports in the recovery furnace to improve combustion efficiency

- Process changes to improve lime mud washing or to control makeup water quality in the causticizing area

- R eplacing a recovery furnace with a black liquor gasification system

Complete the APCD costs and Equip change costs tabs by following the instructions in the “ Instruction ” rows of those tabs. You may also submit information in an alternative format (e.g., as a n attachment to your response) if

needed. Because the cost data will be used by EPA to estimate the nationwide costs , please note if you believe that any portion of the cost information that you supply would be completely unrepresentative of costs th at other mills may face for similar control projects (e.g., if your project capital cost included installation of extra buildings, land purchases, etc. that may n ot be required for other mills)

.

### Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 18 PART III

- ATTACHMENT 1

Emission Units to Includ e in the Part III Pulp and Paper Survey Response

Include the following types of equipment (emission units) in your P art III survey response. You may not operate all

of the emission units listed below. Only include equipmen t operated at your mill.

Chemic al Recovery Combustion Equipment

R ecovery furnace

Semic hemical combustion unit

B lack liquor oxidation system

S melt or ash dissolving tank

Salt cake mix tank

L ime kiln or calciner

B lack liquor gasification system

Sulfur burnerPart III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 19 PART III

- ATTACHMENT 2

Part III E missions Test Data Request

(Note: Test Reports submitted should be full and complete copies of the emission test reports, to include field and lab data sheets and example calculations

. )Part III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 20 Part III

- Attachme nt 2. Pulp and Paper E mission U nits and P ollutants for W hich E xisting R epresentative E mission T est D ata A re R equested Note: Emissions test data representative of your current operations are requested as described in the survey instructions.

Emission Unit Particulate

matter (PM) 1 Speciated

HAP

metals 2 PM 2.5 (fil.) PM 2.5 (cond. ) Hydrochloric acid (HCl) Acetaldehyde, Formaldehyde,

Methanol 1 Total hydrocarbon

(THC) as

carbon CDD/CDF

and

POM/PAH Total reduced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

d ioxide (SO 2 ) 1 Carbon

monoxide

(CO) 1

Test methods 4 M5, M29,

M17

PM CEMS,

COMS M29 EPA

OTM 27 EPA

OTM 28 M26 or 26A Methanol:

Method 308

(part 63) ; Methanol

CEMS ; or

Other applicable

methods M25 or

M25A M23 M16 (or variants such as 16A, 16B, 16C) or TRS CEMS

Provide total TRS data. Also provide speciated TRS data,

if available. M7 (or variants such as 7E)

CEMS M6 (or variants such as 6C)

CEMS M10

CEMS

Recovery furnaces (NDCE and DCE) Supply data

from 2001

and more

recent following subpart MM

MACT compliance Supply data

from 1990 or

more recent Supply

most

recent
data Supply data

from 1990 or

more recent Supply any CDD or

POM data

and note if equipment config. has

changed Supply most recent

data

Black liquor oxidizer (BLO)

Note: The BLO

ve nt is included

in definition of DCE, but listed separately in case

data are available for only the BLO) Not requested Supply data

from 1990 or

more recent Not requested Supply most recent

data Not requested

Chemical

recovery combustion units

- sul fite Supply data

from 2001

and more

recent following subpart MM

MACT compliance Supply data

from 1990 or

more recent Supply

most

recent
data Supply data

from 1990 or

more recent Not requested Supply most

recent dataPart III Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 21 Emission Unit Particulate

matter (PM) 1 Speciated

HAP

metals 2 PM 2.5 (fil.) PM 2.5 (cond. ) Hydrochloric acid (HCl) Acetaldehyde, Formaldehyde,

Methanol 1 Total hydrocarbon

(THC) as

carbon CDD/CDF

and

POM/PAH Total reduced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

d ioxide (SO 2 ) 1 Carbon

monoxide

(CO) 1

Chemical

recovery combustion uni ts

- stand alone

semichemical Supply data

from 1990

or more

recent Supply

most

recent
data Supply data

from 1990 or

more recent Not requested Supply most

recent data

Smelt dissolving tanks (SDT) or ash dissolving

tanks Supply data

from 2001

and mo re

recent following subpart MM

MACT compliance Supply data

from 1990 or

more recent Supply

most

recent
data Supply data

from 1990 or

more recent Supply most recent

data Not requested

Lime

kilns/fluidized

bed calciners Supply data

from 2001

and more

recent following subpart MM

MACT compliance Supply data

from 1990 or

more recent Supply

most

recent
data Supply data

from 1990 or

more recent Supply most recent

data

Black liquor gasification

systems Supply

most recent
data Supply most

recent da ta

1 If your emission unit is equipped with a continuous emissions monitoring system (CEMS) or continuous opacity monitoring syste m (COMS), supply the CEMS data using the CEMS data spreadsheet ( P&P
CEMS_PI I I.xls ) . Synthetic area sources should sup ply the most recent data (if data are available).

2 The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and seleniu m. Include chromium VI (Cr +6 ) and speciated mercury (Hg) test data if

availab le.

3 Speciated TRS would include: hydrogen sulfide (H 2 S), methyl mercaptan, dimethyl sulfide, and dimethyl disulfide.

4 M = method (e.g., M5 is EPA Method 5). EPA Methods 5, 6, 7, 10, 16, 17, 23, 25/25A, 26/26A appear in 40 CFR Part 60, Appendix A. EPA Method 308 appears in Part 63, Appendix A. The “ OTM ” test methods can be found at http://www.epa.gov/ttn/emc/prelim.html