NEI23 Form Approved 02/17/2011

339 OMB Control No. 2060-0656

Approval Expires 02/28/2014

February 22, 2011

Martin Weller

Halltown Paperboard Co.

Halltown Rd, Old Rte 340

Halltown, WV 25423-0010

Dear Mr. Weller:

Pursuant to section 114 of the Clean Air Act (CAA), the U.S. Environmental Protection 

Agency (EPA) is requesting that you complete the Pulp and Paper Sector Survey for the 

following mill:

Ox Paperboard LLC (Halltown Mill)

What is the Pulp and Paper Sector Survey?

The pulp and paper sector survey is a three-part Information Collection Request (ICR) 

(see Enclosure 1), with each part due on a different date. Part I of the survey requests 

information on the pulp and paper production process addressed under the 40 CFR part 63 

subpart S national emissions standards for hazardous air pollutants (NESHAP) and 40 CFR part 

60 subpart BB new source performance standards (NSPS) and will be due by March 17, 2011. 

Part II requests new or updated National Emissions Inventory (NEI) data and will be due by 

June 6, 2011. Part III requests information on chemical recovery combustion sources addressed 

under the 40 CFR part 63 subpart MM NESHAP and 40 CFR part 60 subpart BB NSPS and will 

be due by August 24, 2011. In addition to process data, we are also asking you to provide 

process flow diagrams, emissions data (in the form of emissions test reports and/or continuous 

emissions monitoring system (CEMS) data), and control measure cost information (optional). 

You will also need to certify that all of the information provided in your survey response is true, 

accurate, and complete. To facilitate preparation and submittal of the survey data, we are 

providing a USB flash drive with electronic copies of the survey forms. The electronic survey is 

a series of Microsoft Excel®spreadsheet files, each of which is divided into a series of 

worksheets (“tabs” within the spreadsheet file). In addition to the survey forms, Enclosure 1 also 

contains specific instructions for each part of the survey to assist you in completing your 

response and a copy of the survey certification form. Additional copies of the survey 

spreadsheets, instructions, and certification form can be downloaded here: 

https://icr2010.rti.org/Industries/PulpPaper.aspx.
2

This information request applies to pulp and/or paper/paperboard mills that are a major 

source

1

or synthetic area source2of hazardous air pollutant (HAP) emissions that: (1) perform 

chemical wood pulping (kraft, sulfite, soda, or semi-chemical); (2) perform mechanical, 

groundwood, secondary fiber, and non-wood pulping; (3) perform bleaching; or (4) manufacture 

paper or paperboard products.

Are Any Mills Exempt from the Pulp and Paper Sector Survey?

Certain mills are not required to complete the pulp and paper sector survey. If your mill 

(1) is not a major source” or synthetic area source of HAP emissions; (2) was not operational in 

2009 (and remains closed); or (3) does not produce pulp, perform bleaching, or serve as a 

primary manufacturer of paper or paperboard products, then you should complete the exemption 

form in Enclosure 1 of this letter (see the Pulp and Paper Sector Survey Overview, 

Attachment 1). Please e-mail (or fax) the exemption form to Mr. Bill Schrock of EPA by 

March 17, 2011. (Contact information is provided on the form.) Otherwise, you will need to 

complete the pulp and paper sector survey provided in Enclosure 1. 

Why is EPA Conducting this ICR?

This ICR is being conducted by the EPA Office of Air and Radiation (OAR) to assist the 

EPA Administrator in conducting her review obligations pursuant to CAA sections 111(b)(1)(B), 

112(d)(6), and 112(f)(2) with respect to the pulp and paper production source category. On 

February 23, 1978, the EPA issued NSPS for kraft pulp mills (40 CFR part 60, subpart BB) 

under section 111 of the CAA. As required under CAA section 111(b)(1)(B), EPA must review 

and, if appropriate, revise existing NSPS at least every 8 years. The EPA last reviewed the 

NSPS on May 20, 1986, and another review of the kraft pulp mill NSPS is required under the 

CAA. The EPA issued NESHAP for the pulp and paper industry (40 CFR part 63, subpart S) on 

April 15, 1998, and for chemical recovery combustion sources at kraft, soda, sulfite, and standalone semichemical pulp mills (40 CFR part 63, subpart MM) on January 12, 2001, under the 

authority of section 112 of the CAA. As required under CAA section 112(d)(6), EPA must

review, and, if appropriate, revise existing NESHAP, taking into account developments in 

practices, processes, and control technologies. The section 112(d)(6) technology review is to be 

done at least every 8 years. In addition, under section 112(f)(2), EPA must consider whether 

residual risks remain that warrant more stringent standards than achieved through the NESHAP,

specifically whether more stringent standards are required to provide an ample margin of safety 

to protect public health or to prevent an adverse environmental effect. The section 112(f)(2) 

residual risk review is also to be done 8 years after promulgation. The EPA is working to fulfill 

its obligations under CAA sections 112(f)(2) and (d)(6) to review residual risk and perform a 

 

1 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 quantity, or in the case of radionuclides, different 

criteria from those specified in this sentence.

2 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.
3

technology review of the subpart S and subpart MM NESHAP. Emissions data sets provided by 

the individual pulp and paper mills will be used for EPA’s residual risk and technology review 

(RTR). 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 to the CAA-required reviews, recent case law, a legal petition, and a notice of 

intent (NOI) to sue suggest the need to review the two pulp and paper NESHAP and the kraft 

pulp mill NSPS. On December 19, 2008, the U.S. Court of Appeals for the D.C. Circuit vacated 

the startup, shutdown, and malfunction (SSM) provisions contained in the NESHAP General 

Provisions that apply to pulp and paper mills. On January 14, 2009, EPA received a petition for 

rulemaking 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. On July 21, 2010, EPA received a NOI from Californians 

for Alternatives to Toxics (CATs) and the Center for Biological Diversity (CBD), contending 

that EPA failed to review the NSPS for kraft pulp mills within the statutory deadline under CAA 

section 111(b)(1)(B). To the extent that these legal actions need to be addressed in the pulp and 

paper NESHAP and NSPS, EPA intends to investigate potential rule revisions at the same time 

as the CAA statutory reviews are conducted.

Under What Authority is EPA Conducting this ICR?

EPA’s legal authority to obtain the information requested in the pulp and paper sector 

survey is contained in section 114 of the CAA, as amended (42 U.S.C. §7414). Enclosure 2

contains a summary of this authority. 

Pursuant to the Paperwork Reduction Act (44 U.S.C. 3501 et seq.), EPA sought 

comments on this ICR on June 23, 2010 (75 FR 35792). After addressing these comments, EPA 

submitted the ICR to the U.S. Office of Management and Budget (OMB) for review and 

approval on December 7, 2010 (75 FR 76005). Public comments on the ICR that were received 

during the comment period beginning December 7, 2010, were addressed, and the ICR received 

OMB approval.

How Will Confidential Information Be Handled?

If you believe that providing any specific information to us would reveal a trade secret, or 

would compromise confidential business information (CBI), please identify this information 

clearly in your response. The instruction documents in Enclosure 1 specify procedures for 

identifying and submitting pulp and paper sector survey CBI. Any information EPA 

subsequently determines to constitute CBI or a trade secret under EPA’s CBI regulations at 

40 CFR part 2, subpart B, will be protected pursuant to those regulations and, for trade secrets, 

under 18 U.S.C. 1905. If no claim of confidentiality accompanies the information when it is 

received by EPA, it may be made available to the public by EPA without further notice pursuant 

to EPA regulations at 40 CFR 2.203. 

Because CAA section 114(c) exempts emissions data from claims of confidentiality, the 

emissions data you provide will be made available to the public notwithstanding any claims of 
4

confidentiality. A clarification of what the EPA considers to be emissions data is contained in 

Enclosure 3.

What is RTI’s Role?

We have contracted Research Triangle Institute (RTI) to help us gather information, to 

conduct the survey, and analyze the survey data, and emissions results. As noted in Enclosure 4,

we have designated RTI to be our authorized representative. Therefore, RTI has the same rights 

discussed above and in Enclosure 3. This means that RTI will have access to all information 

provided to us in your completed survey, sampling results, and emissions test results. As a 

designated representative of the Agency, RTI is subject to the provisions of 42 U.S.C. §7414(c) 

respecting confidentiality of methods or processes entitled to protection as trade secrets.

Enclosure 5 summarizes our policies and procedures for handling trade secret 

(confidential) information and describes how our contractor also is required to use the same 

procedures as we do. Because our contractors or other authorized representatives are required to 

follow the requirements in Enclosure 5, we believe that we can ensure your rights and protect 

any privileged information you submit to us.

How Do I Submit My Survey Response(s)?

The survey instruction documents for Parts I, II, and III of the ICR provide detailed 

information on how to submit your survey response. You should note that there are different 

submittal procedures for each part of the survey and different mailing addresses for confidential 

and non-confidential survey responses. Pre-printed return mailing labels for your responses to 

Parts I and III of the survey are provided with the enclosed survey materials. The Part II 

response is based on publicly available NEI data (non-confidential emissions data) and may be 

returned electronically (e.g., via e-mail or posted to an FTP site) by following the instructions for 

Part II. 

When Are My Response(s) Due?

Each part of the pulp and paper sector survey has a different due date, as specified below.

Part Short Description Deadline

I Mill Overview and Subpart S Data

a. Notification of true area source, non-operational, 

or non-applicable status

March 17, 2011

b. Completion of Part I data submittal March 28, 20111,2

II NEI Update June 6, 20111

III Chemical Recovery Combustion Sources August 24, 20111

1. Postmarked date.

2. An additional 15 days (until April 11, 2011) is provided for up to 40 percent of the mills owned by pulp and 

paper companies operating multiple (more than two) mills. 
5

Who Do I Contact With Questions?

If you have questions regarding this information request you may:

 Contact Mr. Bill Schrock (EPA) at (919) 541-5032 or schrock.bill@epa.gov

 View frequently asked questions and/or submit questions through the pulp and paper 

sector survey website: https://icr2010.rti.org/Industries/PulpPaper.aspx

 Send an e-mail to: ppsurvey@rti.org

 Contact the toll-free pulp and paper survey hotline (staffed by RTI during normal 

business hours, Eastern Standard Time): 1-877-834-7065 

In addition, EPA intends to host a Webinar to provide an overview of the pulp and paper 

sector survey shortly after you receive this letter. Please look for an announcement of the 

specific date and time of the Webinar and registration details on the pulp and paper survey 

website (https://icr2010.rti.org/Industries/PulpPaper.aspx) if you are interested in attending.

I am sure you understand how vital it is for the EPA to use the very best information 

available to develop the most meaningful standards. Your help in providing this information is 

greatly appreciated.

Thank you for your assistance in this effort.

Sincerely,

Peter Tsirigotis

Director

Sector Policies and Programs Division

5 Enclosures

Enclosure 1: Pulp and Paper Sector Survey Instructions and Spreadsheets

Enclosure 2: EPA’s information gathering authority (section 114 of the CAA)

Enclosure 3: Clarification of what EPA considers to be emissions data

Enclosure 4: Summary of contractor’s authority as representative of EPA

Enclosure 5: Procedures for safeguarding CBI under the CAA

cc: John Benedict, West Virginia Department of Environmental Protection (without 

enclosures)

Diana Esher, US EPA, Region 3 (without enclosures)
Enclosure 1 

Pulp and Paper Sector Survey Instructions and Spreadsheets

This enclosure contains four documents: 

Pulp and Paper Sector Survey Overview 

Pulp and Paper Sector Survey Instructions for Part I: Mill Overview and Subpart S Data 

Pulp and Paper Sector Survey Instructions for Part II: NEI Update 

Pulp and Paper Sector Survey Instructions for Part III: Chemical Recovery Combustion Sources 

In additon to the four instruction documents listed above, the pulp and paper survey spreadsheets 

are provided on the USB flash drive enclosed in the disk mailer envelope. You may return the 

flash drive in the disk mailer envelope to EPA with your completed Part I or Part III response. 

Pre-printed return mailing labels for Parts I and III are also provided for your convenience. 
Survey Overview Document Form Approved 02/17/2011 

OMB Control No. 2060-0656 

 Approval Expires 02/28/2014 

Pulp and Paper Sector Survey 

Overview 

Survey coverage. The pulp and paper sector survey is a three-part information request that applies for 

pulp and/or paper/paperboard mills 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 semi-chemical), 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 quantity, 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. 

Mills exempt from the pulp and paper sector survey. If your mill is not a major source or synthetic 

area source of HAP emissions, then you should complete the form in Attachment 1 and email (or fax) it to 

Bill Schrock of the U.S. Environmental Protection Agency (EPA) at schrock.bill@epa.gov. If your mill 

is a true area source, then your operating permit should reflect that your mill is not subject to either of the 

pulp and paper national emissions standards for hazardous air pollutants (NESHAP) (40 CFR Part 63, 

subpart S or MM). You are not required to complete any part of the pulp and paper sector survey if you 

submit valid documentation of true area source status.

If your mill is a major source or synthetic area source, but was not operational in 2009 (and remains 

closed) or does not produce pulp, perform bleaching, or manufacture paper or paperboard products, then 

you should complete the form in Attachment 1 and email (or fax) it to Bill Schrock of EPA at 

schrock.bill@epa.gov explaining the status of your mill. You are not required to complete any part of the 

pulp and paper sector survey. 

Survey structure and due dates. The pulp and paper sector survey is to be completed in a series of 

Microsoft Excel spreadsheet files that are divided into several worksheets (“tabs” within each 

spreadsheet). You must complete certain portions of the survey, depending on the type of mill you 

operate. Part I applies for all mills, except true area source and non-operational mills, as noted above. 

Part II requests an NEI update for all emissions units and applies for all major source mills. Synthetic area 

source mills are not required to complete Part II. Part III applies for major and synthetic area source mills 

operating chemical recovery combustion sources. Parts I and III request process data for the emissions 

units listed in Attachment 1 of the instructions for each part. Additional spreadsheets are provided for 

submittal of continuous emissions monitoring system (CEMS) data or control measure cost information 

(for Part I and Part III). 

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Survey Overview Document Form Approved 02/17/2011 

OMB Control No. 2060-0656 

 Approval Expires 02/28/2014 

The pulp and paper sector survey is divided into three parts, each with different due dates as specified in 

Table 1 below. 

Table 1. Components of the Three-Part Pulp and Paper Survey 

Part Short Description Deadline1 Contents of Data Submittal 

I Mill Overview and Subpart S Data 

a. Notification of true area source, non-operational, or 

non-applicable status

20 days -Attachment 1 of survey overview 

b. Completion of Part I data submittal 30 days2 -P&P survey_PI.xls 

-P&P CEMS _PI.xls3

-P&P costs OPTIONAL_PI.xls 

-Flow diagrams 

-Test reports3

-Water modeling 

II NEI Update 

[Part II is not required for synthetic area sources.] 

100 days -P&P NEI update.xls 

 or 

-P&P NEI blank.xls 

III Chemical Recovery Combustion Sources 180 days -P&P CEMS _PIII.xls 

-P&P costs OPTIONAL_PIII.xls 

-P&P survey_PIII.xls 

-Test reports 

-PM bubble calculations 1

 The deadlines indicated are in terms of calendar days following the date stamped on the Section 114 letter 

accompanying this survey. Specific dates are specified in the letter. 2 An additional 15 days is provided for up to 40 percent of the mills owned by pulp and paper companies operating 

multiple (more than two) mills. For example, for a company owning 10 pulp and paper mills, the Part I survey 

response deadline for 4 of these mills may be extended until 45 days following the date stamped on the Section 114 

letter. 

3

 Mills required to complete Part III may postpone until the deadline for Part III submittal of emissions test data and 

CEMS data required for the emission units listed in Part I Attachment 1 for the following pollutants: PM, PM2.5, 

TRS, NOx, SO2, and CO. 

Please complete the survey for the facility listed in the Section 114 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, they can be downloaded here: https://icr2010.rti.org/Industries/PulpPaper.aspx

Base year for survey data. Use the 2009 calendar year as the base year for all survey responses (e.g., 

2009 emissions inventory, 2009 capacity, 2009 equipment configurations, etc.), unless another year is 

specified in the instructions (e.g., for emissions test data). 

Definitions. For reference, Attachment 2 to this overview contains the regulatory definitions from the 

kraft pulp mill new source performance standards (NSPS) (40 CFR Part 60, subpart BB), chemical 

recovery combustion source NESHAP (40 CFR Part 63, subpart MM), and pulp and paper production 

NESHAP (40 CFR Part 63, subpart S), and selected definitions from the NSPS and NESHAP General 

Provisions. 

Acronyms/abbreviations. Attachment 3 to this overview contains acronyms and abbreviations used 

throughout the survey instruction documents and associated spreadsheets. 

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3 

Certification form. Attachment 4 to this overview contains a certification form that you must complete, 

sign, date, and submit separately with each completed part of the survey, certifying that the statements 

and information provided in your responses to Part I, Part II, and Part III of the survey are (to the best of 

your knowledge) true, accurate, and complete. 

Who do I contact with questions? 

Should you have a question while completing the pulp and paper survey that you believe is not 

addressed in the survey instructions, you have some options: 

1. (Preferred) Email your question to: ppsurvey@rti.org

2. Contact the pulp and paper survey hotline: 1-877-834-7065 

 (Hotline is staffed by RTI during normal business hours, Eastern Standard Time) 

3. Contact Bill Schrock of EPA at schrock.bill@epa.gov (919-541-5032). 

Under options 1 and 2, RTI staff assisting EPA with the pulp and paper survey will consult with EPA 

as needed to obtain a response for your question. Frequently asked questions (FAQs) will be posted on 

the survey webpage: https://icr2010.rti.org/Industries/PulpPaper.aspx 
Survey Overview Document Form Approved 02/17/2011 

OMB Control No. 2060-0656 

 Approval Expires 02/28/2014 

ATTACHMENT 1 

DOCUMENTATION OF TRUE AREA SOURCE, NON-OPERATIONAL, OR 

NON-APPLICABLE STATUS

Facility Name on the 

Letter from EPA: 

Corrected Facility 

Name (if applicable): 

Address: 

Check an explanation below: 

□ I certify that the facility listed above is not a major source or synthetic area source of 

hazardous air pollutant emissions (HAP) emissions. The facility is a true area source of 

HAP emissions. Documentation (such as a valid operating permit) confirming the true 

area source status is attached. 

□ I certify that that facility listed above was not operational in 2009 (the base year for the 

pulp and paper sector survey), and that the facility remains non-operational (closed). A 

brief explanation is provided in the area below: 

□ I certify that the facility listed above does not produce pulp, perform bleaching, or 

manufacture paper or paperboard products. A brief explanation is provided in the area 

below:

Signature: ____________________________________________ 

Printed name: _________________________________________ 

Email and/or fax completed form to: Bill Schrock (USEPA) 

schrock.bill@epa.gov 

Fax: (919) 541-3470

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ATTACHMENT 2 

NSPS and NESHAP Definitions 

NSPS Subpart BB Definitions (40 CFR Part 60, § 60.281): 

 (a) Kraft pulp mill means any stationary source which produces pulp from wood by cooking (digesting) wood chips 

in a water solution of sodium hydroxide and sodium sulfide (white liquor) at high temperature and pressure. 

Regeneration of the cooking chemicals through a recovery process is also considered part of the kraft pulp mill. 

(b) Neutral sulfite semichemical pulping operation means any operation in which pulp is produced from wood by 

cooking (digesting) wood chips in a solution of sodium sulfite and sodium bicarbonate, followed by mechanical 

defibrating (grinding). 

(c) Total reduced sulfur (TRS) means the sum of the sulfur compounds hydrogen sulfide, methyl mercaptan, 

dimethyl sulfide, and dimethyl disulfide, that are released during the kraft pulping operation and measured by 

Method 16. 

(d) Digester system means each continuous digester or each batch digester used for the cooking of wood in white 

liquor, and associated flash tank(s), blow tank(s), chip steamer(s), and condenser(s). 

(e) Brown stock washer system means brown stock washers and associated knotters, vacuum pumps, and filtrate 

tanks used to wash the pulp following the digester system. Diffusion washers are excluded from this definition. 

(f) Multiple-effect evaporator system means the multiple-effect evaporators and associated condenser(s) and 

hotwell(s) used to concentrate the spent cooking liquid that is separated from the pulp (black liquor). 

(g) Black liquor oxidation system means the vessels used to oxidize, with air or oxygen, the black liquor, and 

associated storage tank(s). 

(h) Recovery furnace means either a straight kraft recovery furnace or a cross recovery furnace, and includes the 

direct-contact evaporator for a direct-contact furnace. 

(i) Straight kraft recovery furnace means a furnace used to recover chemicals consisting primarily of sodium and 

sulfur compounds by burning black liquor which on a quarterly basis contains 7 weight percent or less of the total 

pulp solids from the neutral sulfite semichemical process or has green liquor sulfidity of 28 percent or less. 

(j) Cross recovery furnace means a furnace used to recover chemicals consisting primarily of sodium and sulfur 

compounds by burning black liquor which on a quarterly basis contains more than 7 weight percent of the total 

pulp solids from the neutral sulfite semichemical process and has a green liquor sulfidity of more than 28 percent. 

(k) Black liquor solids means the dry weight of the solids which enter the recovery furnace in the black liquor. 

(l) Green liquor sulfidity means the sulfidity of the liquor which leaves the smelt dissolving tank. 

(m) Smelt dissolving tank means a vessel used for dissolving the smelt collected from the recovery furnace. 

(n) Lime kiln means a unit used to calcine lime mud, which consists primarily of calcium carbonate, into quicklime, 

which is calcium oxide. 

(o) Condensate stripper system means a column, and associated condensers, used to strip, with air or steam, TRS 

compounds from condensate streams from various processes within a kraft pulp mill. 

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NESHAP Subpart MM Definitions (40 CFR Part 63, § 63.861): 

Bag leak detection system means an instrument that is capable of monitoring PM loadings in the exhaust of a fabric 

filter in order to detect bag failures. A bag leak detection system includes, but is not limited to, an instrument that 

operates on triboelectric, light scattering, light transmittance, or other principle to monitor relative PM loadings. 

Black liquor means spent cooking liquor that has been separated from the pulp produced by the kraft, soda, or 

semichemical pulping process. 

Black liquor gasification means the thermochemical conversion of black liquor into a combustible gaseous product. 

Black liquor oxidation (BLO) system means the vessels used to oxidize the black liquor, with air or oxygen, and the 

associated storage tank(s). 

Black liquor solids (BLS) means the dry weight of the solids in the black liquor that enters the recovery furnace or 

semichemical combustion unit. 

Black liquor solids firing rate means the rate at which black liquor solids are fed to the recovery furnace or the 

semichemical combustion unit. 

Chemical recovery combustion source means any source in the chemical recovery area of a kraft, soda, sulfite or 

stand-alone semichemical pulp mill that is an NDCE recovery furnace, a DCE recovery furnace system, a smelt 

dissolving tank, a lime kiln, a sulfite combustion unit, or a semichemical combustion unit. 

Chemical recovery system means all existing DCE and NDCE recovery furnaces, smelt dissolving tanks, and lime 

kilns at a kraft or soda pulp mill. Each existing recovery furnace, smelt dissolving tank, or lime kiln is considered 

a process unit within a chemical recovery system. 

Direct contact evaporator (DCE) recovery furnace means a kraft or soda recovery furnace equipped with a direct 

contact evaporator that concentrates strong black liquor by direct contact between the hot recovery furnace 

exhaust gases and the strong black liquor. 

Direct contact evaporator (DCE) recovery furnace system means a direct contact evaporator recovery furnace and 

any black liquor oxidation system, if present, at the pulp mill. 

Dry electrostatic precipitator (ESP) system means an electrostatic precipitator with a dry bottom (i.e., no black 

liquor, water, or other fluid is used in the ESP bottom) and a dry particulate matter return system (i.e., no black 

liquor, water, or other fluid is used to transport the collected PM to the mix tank). 

Fabric filter means an air pollution control device used to capture PM by filtering a gas stream through filter media; 

also known as a baghouse. 

Hazardous air pollutants (HAP) metals means the sum of all emissions of antimony, arsenic, beryllium, cadmium, 

chromium, cobalt, lead, manganese, mercury, nickel, and selenium as measured by EPA Method 29 (40 CFR part 

60, appendix A) and with all nondetect data treated as one-half of the method detection limit. 

Hog fuel dryer means the equipment that combusts fine particles of wood waste (hog fuel) in a fluidized bed and 

directs the heated exhaust stream to a rotary dryer containing wet hog fuel to be dried prior to combustion in the 

hog fuel boiler at Weyerhaeuser Paper Company’s Cosmopolis, Washington facility. The hog fuel dryer at 

Weyerhaeuser Paper Company’s Cosmopolis, Washington facility is Emission Unit no. HD–14. 

Kraft pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a 

solution of sodium hydroxide and sodium sulfide. The recovery process used to regenerate cooking chemicals is 

also considered part of the kraft pulp mill. 

Kraft recovery furnace means a recovery furnace that is used to burn black liquor produced by the kraft pulping 

process, as well as any recovery furnace that burns black liquor produced from both the kraft and semichemical 

pulping processes, and includes the direct contact evaporator, if applicable. Includes black liquor gasification. 

Lime kiln means the combustion unit (e.g., rotary lime kiln or fluidized-bed calciner) used at a kraft or soda pulp 

mill to calcine lime mud, which consists primarily of calcium carbonate, into quicklime, which is calcium oxide 

(CaO). 

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Lime production rate means the rate at which dry lime, measured as CaO, is produced in the lime kiln. 

Method detection limit means the minimum concentration of an analyte that can be determined with 99 percent 

confidence that the true value is greater than zero. 

Modification means, for the purposes of § 63.862(a)(1)(ii)(E)(1), any physical change (excluding any routine part 

replacement or maintenance) or operational change (excluding any operational change that occurs during a startup, shutdown, or malfunction) that is made to the air pollution control device that could result in an increase in 

PM emissions. 

Nondetect data means, for the purposes of this subpart, any value that is below the method detection limit. 

Nondirect contact evaporator (NDCE) recovery furnace means a kraft or soda recovery furnace that burns black 

liquor that has been concentrated by indirect contact with steam. 

Particulate matter (PM) means total particulate matter as measured by EPA Method 5, EPA Method 17 (§ 

63.865(b)(1)), or EPA Method 29 (40 CFR part 60, appendix A). 

Process unit means an existing DCE or NDCE recovery furnace, smelt dissolving tank, or lime kiln in a chemical 

recovery system at a kraft or soda mill. 

Recovery furnace means an enclosed combustion device where concentrated black liquor produced by the kraft or 

soda pulping process is burned to recover pulping chemicals and produce steam. Includes black liquor 

gasification. 

Regenerative thermal oxidizer (RTO) means a thermal oxidizer that transfers heat from the exhaust gas stream to the 

inlet gas stream by passing the exhaust stream through a bed of ceramic stoneware or other heat-absorbing 

medium before releasing it to the atmosphere, then reversing the gas flow so the inlet gas stream passes through 

the heated bed, raising the temperature of the inlet stream close to or at its ignition temperature. 

Semichemical combustion unit means any equipment used to combust or pyrolyze black liquor at stand-alone 

semichemical pulp mills for the purpose of chemical recovery. Includes black liquor gasification. 

Similar process units means all existing DCE and NDCE recovery furnaces, smelt dissolving tanks, or lime kilns at 

a kraft or soda pulp mill. 

Smelt dissolving tanks (SDT) means vessels used for dissolving the smelt collected from a kraft or soda recovery 

furnace. 

Soda pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a 

sodium hydroxide solution. The recovery process used to regenerate cooking chemicals is also considered part of 

the soda pulp mill. 

Soda recovery furnace means a recovery furnace used to burn black liquor produced by the soda pulping process 

and includes the direct contact evaporator, if applicable. Includes black liquor gasification. 

Stand-alone semichemical pulp mill means any stationary source that produces pulp from wood by partially 

digesting wood chips in a chemical solution followed by mechanical defibrating (grinding), and has an onsite 

chemical recovery process that is not integrated with a kraft pulp mill. 

Startup means, for the chemical recovery system employing black liquor gasification at Georgia-Pacific’s facility in 

Big Island, Virginia only, the end of the gasification system commissioning phase. Commissioning is that period 

of time in which each part of the new gasification system will be checked and operated on its own to make sure it 

is installed and functions properly. Commissioning will conclude with the successful completion of the 

gasification technology supplier’s performance warranty demonstration, which proves the technology and 

equipment are performing to warranted levels and the system is ready to be placed in active service. For all other 

affected sources under this subpart, startup has the meaning given in § 63.2. 

Sulfite combustion unit means a combustion device, such as a recovery furnace or fluidized-bed reactor, where spent 

liquor from the sulfite pulping process (i.e., red liquor) is burned to recover pulping chemicals. 

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Sulfite pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a 

solution of sulfurous acid and bisulfite ions. The recovery process used to regenerate cooking chemicals is also 

considered part of the sulfite pulp mill. 

Total hydrocarbons (THC) means the sum of organic compounds measured as carbon using EPA Method 25A (40 

CFR part 60, appendix A). 

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NESHAP Subpart S Definitions (40 CFR Part 63, § 63.441): 

Acid condensate storage tank means any storage tank containing cooking acid following the sulfur dioxide gas 

fortification process. 

Black liquor means spent cooking liquor that has been separated from the pulp produced by the kraft, soda, or semichemical pulping process. 

Bleaching means brightening of pulp by the addition of oxidizing chemicals or reducing chemicals. 

Bleaching line means a group of bleaching stages arranged in series such that bleaching of the pulp progresses as the 

pulp moves from one stage to the next. 

Bleaching stage means all process equipment associated with a discrete step of chemical application and removal in 

the bleaching process including chemical and steam mixers, bleaching towers, washers, seal (filtrate) tanks, 

vacuum pumps, and any other equipment serving the same function as those previously listed. 

Bleaching system means all process equipment after high-density pulp storage prior to the first application of 

oxidizing chemicals or reducing chemicals following the pulping system, up to and including the final bleaching 

stage. 

Boiler means any enclosed combustion device that extracts useful energy in the form of steam. A boiler is not 

considered a thermal oxidizer. 

Chip steamer means a vessel used for the purpose of preheating or pretreating wood chips prior to the digester, using 

flash steam from the digester or live steam. 

Closed-vent system means a system that is not open to the atmosphere and is composed of piping, ductwork, 

connections, and, if necessary, flow-inducing devices that transport gas or vapor from an emission point to a 

control device. 

Combustion device means an individual unit of equipment, including but not limited to, a thermal oxidizer, lime 

kiln, recovery furnace, process heater, or boiler, used for the thermal oxidation of organic hazardous air pollutant 

vapors. 

Decker system means all equipment used to thicken the pulp slurry or reduce its liquid content after the pulp 

washing system and prior to high-density pulp storage. The decker system includes decker vents, filtrate tanks, 

associated vacuum pumps, and any other equipment serving the same function as those previously listed. 

Digester system means each continuous digester or each batch digester used for the chemical treatment of wood or 

non-wood fibers. The digester system equipment includes associated flash tank(s), blow tank(s), chip steamer( s) 

not using fresh steam, blow heat recovery accumulator(s), relief gas condenser(s), prehydrolysis unit(s) preceding 

the pulp washing system, and any other equipment serving the same function as those previously listed. The 

digester system includes any of the liquid streams or condensates associated with batch or continuous digester 

relief, blow, or flash steam processes. 

Emission point means any part of a stationary source that emits hazardous air pollutants regulated under this subpart, 

including emissions from individual process vents, stacks, open pieces of process equipment, equipment leaks, 

wastewater and condensate collection and treatment system units, and those emissions that could reasonably be 

conveyed through a stack, chimney, or duct where such emissions first reach the environment. 

Evaporator system means all equipment associated with increasing the solids content and/or concentrating spent 

cooking liquor from the pulp washing system including pre-evaporators, multi-effect evaporators, concentrators, 

and vacuum systems, as well as associated condensers, hotwells, and condensate streams, and any other 

equipment serving the same function as those previously listed. 

Flow indicator means any device that indicates gas or liquid flow in an enclosed system. 

HAP means a hazardous air pollutant as defined in § 63.2 of subpart A of this part. 

High volume, low concentration or HVLC collection system means the gas collection and transport system used to 

convey gases from the HVLC system to a control device. 

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High volume, low concentration or HVLC system means the collection of equipment including the pulp washing, 

knotter, screen, decker, and oxygen delignification systems, weak liquor storage tanks, and any other equipment 

serving the same function as those previously listed. 

Knotter system means equipment where knots, oversized material, or pieces of uncooked wood are removed from 

the pulp slurry after the digester system and prior to the pulp washing system. The knotter system equipment 

includes the knotter, knot drainer tanks, ancillary tanks, and any other equipment serving the same function as 

those previously listed. 

Kraft pulping means a chemical pulping process that uses a mixture of sodium hydroxide and sodium sulfide as the 

cooking liquor. 

Lime kiln means an enclosed combustion device used to calcine lime mud, which consists primarily of calcium 

carbonate, into calcium oxide. 

Low volume, high concentration or LVHC collection system means the gas collection and transport system used to 

convey gases from the LVHC system to a control device. 

Low volume, high concentration or LVHC system means the collection of equipment including the digester, 

turpentine recovery, evaporator, steam stripper systems, and any other equipment serving the same function as 

those previously listed. 

Mechanical pulping means a pulping process that only uses mechanical and thermo-mechanical processes to reduce 

wood to a fibrous mass. The mechanical pulping processes include, but are not limited to, stone groundwood, 

pressurized groundwood, refiner mechanical, thermal refiner mechanical, thermo-mechanical, and tandem 

thermomechanical. 

Non-wood pulping means the production of pulp from fiber sources other than trees. The non-wood fiber sources 

include, but are not limited to, bagasse, cereal straw, cotton, flax straw, hemp, jute, kenaf, and leaf fibers. 

Oven-dried pulp or ODP means a pulp sample at zero percent moisture content by weight. Pulp samples for 

applicability or compliance determinations for both the pulping and bleaching systems shall be unbleached pulp. 

For purposes of complying with mass emission limits in this subpart, megagram of ODP shall be measured to 

represent the amount of pulp entering and processed by the equipment system under the specified mass limit. For 

equipment that does not process pulp, megagram of ODP shall be measured to represent the amount of pulp that 

was processed to produce the gas and liquid streams. 

Oxygen delignification system means the equipment that uses oxygen to remove lignin from pulp after high-density 

stock storage and prior to the bleaching system. The oxygen delignification system equipment includes the blow 

tank, washers, filtrate tanks, any interstage pulp storage tanks, and any other equipment serving the same function 

as those previously listed. 

Primary fuel means the fuel that provides the principal heat input to the combustion device. To be considered 

primary, the fuel must be able to sustain operation of the combustion de without the addition of other fuels. 

Process wastewater treatment system means a collection of equipment, a process, or specific technique that removes 

or destroys the HAPs in a process wastewater stream. Examples include, but are not limited to, a steam stripping 

unit, wastewater thermal oxidizer, or biological treatment unit. 

Pulp washing system means all equipment used to wash pulp and separate spent cooking chemicals following the 

digester system and prior to the bleaching system, oxygen delignification system, or paper machine system (at 

unbleached mills). The pulp washing system equipment includes vacuum drum washers, diffusion washers, 

rotary pressure washers, horizontal belt filters, intermediate stock chests, and their associated vacuum pumps, 

filtrate tanks, foam breakers or tanks, and any other equipment serving the same function as those previously 

listed. The pulp washing system does not include deckers, screens, knotters, stock chests, or pulp storage tanks 

following the last stage of pulp washing. 

Pulping line means a group of equipment arranged in series such that the wood chips are digested and the resulting 

pulp progresses through a sequence of steps that may include knotting, refining, washing, thickening, blending, 

storing, oxygen delignification, and any other equipment serving the same function as those previously listed. 

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Pulping process condensates means any HAP-containing liquid that results from contact of water with organic 

compounds in the pulping process. Examples of process condensates include digester system condensates, 

turpentine recovery system condensates, evaporator system condensates, LVHC system condensates, HVLC 

system condensates, and any other condensates from equipment serving the same function as those previously 

listed. Liquid streams that are intended for byproduct recovery are not considered process condensate streams. 

Pulping system means all process equipment, beginning with the digester system, and up to and including the last 

piece of pulp conditioning equipment prior to the bleaching system, including treatment with ozone, oxygen, or 

peroxide before the first application of a chemical bleaching agent intended to brighten pulp. The pulping system 

includes pulping process condensates and can include multiple pulping lines. 

Recovery furnace means an enclosed combustion device where concentrated spent liquor is burned to recover 

sodium and sulfur, produce steam, and dispose of unwanted dissolved wood components in the liquor. 

Screen system means equipment in which oversized particles are removed from the pulp slurry prior to the bleaching 

or papermaking system washed stock storage. 

Secondary fiber pulping means a pulping process that converts a fibrous material, that has previously undergone a 

manufacturing process, into pulp stock through the addition of water and mechanical energy. The mill then uses 

that pulp as the raw material in another manufactured product. These mills may also utilize chemical, heat, and 

mechanical processes to remove ink particles from the fiber stock. 

Semi-chemical pulping means a pulping process that combines both chemical and mechanical pulping processes. 

The semi-chemical pulping process produces intermediate yields ranging from 55 to 90 percent. 

Soda pulping means a chemical pulping process that uses sodium hydroxide as the active chemical in the cooking 

liquor. 

Spent liquor means process liquid generated from the separation of cooking liquor from pulp by the pulp washing 

system containing dissolved organic wood materials and residual cooking compounds. 

Steam stripper system means a column (including associated stripper feed tanks, condensers, or heat exchangers) 

used to remove compounds from wastewater or condensates using steam. The steam stripper system also contains 

all equipment associated with a methanol rectification process including rectifiers, condensers, decanters, storage 

tanks, and any other equipment serving the same function as those previously listed. 

Strong liquor storage tanks means all storage tanks containing liquor that has been concentrated in preparation for 

combustion or oxidation in the recovery process. 

Sulfite pulping means a chemical pulping process that uses a mixture of sulfurous acid and bisulfite ion as the 

cooking liquor. 

Temperature monitoring device means a piece of equipment used to monitor temperature and having an accuracy of 

±1.0 percent of the temperature being monitored expressed in degrees Celsius or ±0.5 degrees Celsius (C), 

whichever is greater. 

Thermal oxidizer means an enclosed device that destroys organic compounds by thermal oxidation. 

Turpentine recovery system means all equipment associated with recovering turpentine from digester system gases 

including condensers, decanters, storage tanks, and any other equipment serving the same function as those 

previously listed. The turpentine recovery system includes any liquid streams associated with the turpentine 

recovery process such as turpentine decanter underflow. Liquid streams that are intended for byproduct recovery 

are not considered turpentine recovery system condensate streams. 

Weak liquor storage tank means any storage tank except washer filtrate tanks containing spent liquor recovered 

from the pulping process and prior to the evaporator system. 

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Selected definitions from 40 CFR Part 60 subpart A (NSPS General Provisions): 

Commenced means, with respect to the definition of new source in section 111(a)(2) of the Act, that an owner or 

operator has undertaken a continuous program of construction or modification or that an owner or operator has 

entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program 

of construction or modification. [§60.2]

Construction means fabrication, erection, or installation of an affected facility. [§60.2]

Modification means any physical change in, or change in the method of operation of, an existing facility which 

increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by that facility 

or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not 

previously emitted. [§60.2]

Reconstruction means the replacement of components of an existing facility to such an extent that: (1) The fixed 

capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to 

construct a comparable entirely new facility, and (2) It is technologically and economically feasible to meet the 

applicable standards set forth in this part. [§60.15(b)]

Selected definitions from 40 CFR Part 63 subpart A (NESHAP General Provisions): 

Commenced means, with respect to construction or reconstruction of an affected source, that an owner or operator 

has undertaken a continuous program of construction or reconstruction or that an owner or operator has entered 

into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of 

construction or reconstruction. [§63.2] 

Construction means the on-site fabrication, erection, or installation of an affected source. Construction does not 

include the removal of all equipment comprising an affected source from an existing location and reinstallation of 

such equipment at a new location. The owner or operator of an existing affected source that is relocated may elect 

not to reinstall minor ancillary equipment including, but not limited to, piping, ductwork, and valves. However, 

removal and reinstallation of an affected source will be construed as reconstruction if it satisfies the criteria for 

reconstruction as defined in this section. The costs of replacing minor ancillary equipment must be considered in 

determining whether the existing affected source is reconstructed. [§63.2] 

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 quantity, or in the case of radionuclides, different criteria from those 

specified in this sentence. [§63.2] 

Reconstruction, unless otherwise defined in a relevant standard, means the replacement of components of an 

affected or a previously nonaffected source to such an extent that: (1) The fixed capital cost of the new 

components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable new 

source; and (2) It is technologically and economically feasible for the reconstructed source to meet the relevant 

standard(s) established by the Administrator (or a State) pursuant to section 112 of the Act. Upon reconstruction, 

an affected source, or a stationary source that becomes an affected source, is subject to relevant standards for new 

sources, including compliance dates, irrespective of any change in emissions of hazardous air pollutants from that 

source. [§63.2] 

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13 

ATTACHMENT 3 

Acronyms and Abbreviations 

acfm actual cubic foot (feet) per minute 

ADT ash dissolving tank(s) 

ADTBP air-dried ton(s) of bleached pulp 

ADTFP air-dried ton(s) of finished paper 

ADTP air-dried ton(s) of pulp 

APCD air pollution control device(s) 

As arsenic 

AS activated sludge 

ASB aerated stabilization basin(s) 

atm atmosphere(s) 

Be beryllium 

BLDG building 

BLO black liquor oxidation 

BLS black liquor solids 

BOD biochemical oxygen demand 

BOD5 5-day BOD 

Btu British thermal unit(s) 

°C degrees Celsius 

Ca calcium 

CAA Clean Air Act 

CaO calcium oxide (lime) 

CAP criteria air pollutant(s) 

CBI confidential business information 

CCA Clean Condensate Alternative 

Cd cadmium 

CD compact disc 

CDD chlorinated dibenzo-p-dioxin 

CDF chlorinated dibenzofuran 

CEMS continuous emissions monitoring system(s) 

CERCLA Comprehensive Environmental Response, 

Compensation, & Liability Act 

cfm cubic feet per minute 

CFR Code of Federal Regulations 

Cl2 chlorine 

ClO2 chlorine dioxide 

Co cobalt 

CO carbon monoxide 

CO2 carbon dioxide 

COMS continuous opacity monitoring system(s) 

Cr chromium 

CTMP chemi-thermomechanical pulp 

cu ft cubic foot (feet) 

cu yd cubic yard(s) 

CY calendar year 

d day(s) 

DAS data acquisition system(s) 

DCE direct contact evaporator 

DI dry injection 

dscf dry standard cubic foot (feet) 

dscfm dry standard cubic feet per minute 

DVD digital versatile disc 

ECF elemental chlorine free 

EIS Emissions Inventory System 

EPA U.S. Environmental Protection Agency 

ESP electrostatic precipitator(s) 

EU emission unit 

EVAP evaporator 

°F degrees Fahrenheit 

FF fabric filter 

ft foot (feet) 

ft2

 square foot (feet) 

FTP file transfer protocol 

g gram(s) 

gal gallon(s) 

gpm gallon(s) per minute 

gr grain(s) 

GW groundwood 

H2O water 

H2O2 hydrogen peroxide 

H2S hydrogen sulfide 

HAP hazardous air pollutant(s) 

HCl hydrochloric acid 

HF hydrogen fluoride 

Hg mercury 

HHV higher heating value 

hr hour(s) 

HVLC high-volume low-concentration 

HW hardwood 

ICR information collection request 

ID identification 

in. inch(es) 

ISIS Industrial Sector Integrated Solutions 

kg kilogram(s) 

KMNO4 potassium permanganate 

KOH potassium hydroxide 

kW kilowatt 

kWh kilowatt-hour(s) 

l liter(s) 

lb pound(s) 

LK lime kiln(s) 

LVHC low-volume high-concentration 

MACT maximum achievable control technology 

MDL method detection limit 

MEE multiple-effect evaporator(s) 

MEK methyl ethyl ketone 

MeOH methanol 

mg milligram(s) 

Mg megagram(s); magnesium 

MLVSS mixed liquor volatile suspended solids 

MMBtu million Btu 

mmscf million standard cubic feet 

Mn manganese 

MSDS material safety data sheet(s) 

NA Not Applicable 
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Na2S2O4 sodium hydrosulfite

NaClO sodium hypochlorite 

NAD North American Dictum 

NAICS North American Industry Classification 

System 

NaOH sodium hydroxide 

NATA National-Scale Air Toxics Assessment 

NCASI National Council of the Paper Industry for 

Air and Stream Improvement 

NCG noncondensable gas(es) 

NDCE nondirect contact evaporator 

NEC Not Elsewhere Classified 

NEI National Emissions Inventory 

NESHAP National emissions standard(s) for 

hazardous air pollutants 

NH3 ammonia 

Ni nickel 

No. number 

NO2 nitrogen dioxide

NOX nitrogen oxides 

NSPS new source performance standard(s) 

NSSC neutral sulfite semichemical 

NV not vented 

O2 oxygen 

O3 ozone 

OCC Old Corrugated Container 

ODP oven-dried pulp 

ODT oven dried ton(s) 

OMB Office of Management and Budget 

ONP Old News Print 

OSHA Occupational Safety and Health 

Administration 

OTM Other Test Method 

P & P pulp and paper 

PAH polycyclic aromatic hydrocarbons 

Pb lead 

PCC precipitated calcium carbonate 

PCF processed chlorine free 

PGW pressurized groundwoood 

PLC programmable logic controller 

PM particulate matter 

PM10 PM with an aerodynamic diameter of up to 

10 μm 

PM2.5 PM with an aerodynamic diameter of up to 

2.5 μm 

POM polycyclic organic matter 

POTW publicly owned treatment works 

ppm part(s) per million 

ppmdv part(s) per million dry volume 

ppmdw part(s) per million dry weight 

ppmv part(s) per million by volume 

ppmw part(s) per million by weight 

PTFE polytetrafluoroethylene 

RF recovery furnace(s) 

RMP refiner mechanical pulping 

RTO regenerative thermal oxidizer(s) 

RTR residual risk and technology review 

Sb antimony 

SBT stock blend tank(s) 

SCA specific collecting area 

SCC Source Classification Code 

scf standard cubic foot (feet) 

scfm standard cubic feet per minute 

SCR selective catalytic reduction 

SDT smelt dissolving tank(s) 

Se selenium 

sec second(s) 

SGW stone groundwood 

SIC Standard Industrial Classification 

SNCR selective noncatalytic reduction 

SO2 sulfur dioxide 

SOG stripper offgas(es) 

SSM startup, shutdown, and malfunction 

st short ton(s) 

SVT save-all tank(s) 

SW softwood 

TBD To Be Determined 

TCF totally chlorine free 

TCDD tetrachlorodibenzo-p-dioxin 

TCI total capital investment 

TEQ 2,3,7,8-TCDD toxic equivalent 

THC total hydrocarbon 

TMP thermomechanical pulping 

TO thermal oxidizer 

ton ton(s) 

tph ton(s) per hour 

tpy ton(s) per year 

TRI Toxics Release Inventory 

TRS total reduced sulfur 

UK Unknown 

UNOX oxygen activated sludge treatment 

U.S. United States 

VOC volatile organic compound 

WESP wet ESP(s) 

WS wet scrubber(s) 

Wt% weight-percent 

WW wastewater 

WWT wastewater treatment 

WWTP wastewater treatment plant 

Y/N yes/no 

yr year(s) 

μg microgram(s)

μm micrometer(s)

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ATTACHMENT 4 

SIGNED CERTIFICATION FORM 

Instructions: Submit a hard (or electronic) copy of this completed form with each part of 

your survey response (Part I, Part II, and Part III). 

Check the appropriate certification statement below for the part of the survey being 

submitted: 

□ Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information provided in my response to Part I of this survey are (to the 

best of my knowledge) true, accurate, and complete. 

□ Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information provided in my response to Part II of this survey are (to the 

best of my knowledge) true, accurate, and complete.

□ Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information provided in my response to Part III of this survey are (to the 

best of my knowledge) true, accurate, and complete.

Signature: ____________________________________________ 

Printed name: _________________________________________ 

Title: _________________________________________________ 

Company: _____________________________________________ 

Date signed: ___________________________________________ 

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 

intent 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.

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Pulp and Paper Sector Survey 

Instructions for Part I: 

Mill Overview and Subpart S Data 

2/4/11 

This survey overview document provides instructions for completing Part I of the pulp and paper survey. This 

overview is organized as follows: 

A. Part I Introduction ........................................................................................................................................... 2

B. Confidential Business Information (CBI)........................................................................................................ 4

C. How to Submit Your Part I Survey Response ................................................................................................. 4

C1. Submitting Your Non-CBI Response ................................................................................................ 4

C2. Submitting CBI ................................................................................................................................. 4

D. How to Complete the Part I Survey ................................................................................................................. 5

D1. Flow diagrams ................................................................................................................................... 5

D2. Process data (P&P survey_PI.xls) ..................................................................................................... 6

a. Mill tab .................................................................................................................................... 9

b. PI Equip detail tab ................................................................................................................. 11

c. PI Permit limits tab ................................................................................................................ 15

d. PI Controls tab ....................................................................................................................... 17

e. Pulp prod tab ......................................................................................................................... 18

f. Byproducts tab ....................................................................................................................... 19

g. Kraft condensates tab ............................................................................................................ 19

h. CCA tab ................................................................................................................................. 20

i. Bleaching tab ......................................................................................................................... 21

j. Paper prod tab ........................................................................................................................ 22

k. HAP additives tab .................................................................................................................. 22

l. WW tab.................................................................................................................................. 23

D3. Test data .......................................................................................................................................... 23

a. PI Emissions test data tab ...................................................................................................... 24

b. CEMS data spreadsheet (P&P CEMS_PI.xls) ....................................................................... 24

D4. Optional cost data............................................................................................................................ 26

PART I - ATTACHMENT 1 Emission Units to Include in the Part I Pulp and Paper Survey Response .................. 28

PART I - ATTACHMENT 2 Small Business Size Standards .................................................................................... 30

PART I - ATTACHMENT 3 Part I Emissions Test Data Request ............................................................................. 31

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A. Part I Introduction 

The pulp and paper sector information request applies for pulp and/or paper/paperboard mills 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 semi-chemical), 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 quantity, 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 complete the form in Attachment 1 of the Survey Overview document and email (or fax) 

it to Bill Schrock at EPA (contact information is provided on the form). 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. 

You are required to complete Part I of the pulp and paper sector survey unless you meet one of the three criteria 

listed above for exemption from the survey. 

This survey is to be completed in a Microsoft Excel spreadsheet file that is divided into several worksheets (“tabs” 

within the spreadsheet). You must complete certain tabs of the survey spreadsheet (depending on the type of mill 

you operate). Table 1 below denotes which survey spreadsheet 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 114 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, they can be downloaded here: 

https://icr2010.rti.org/Industries/PulpPaper.aspx

Use the 2009 calendar year as the base year for all survey responses (e.g., 2009 emissions inventory, 2009 capacity, 

2009 equipment configurations, etc.), unless another year is specified in the instructions (e.g., for emissions test 

data). 

Part I of this survey asks questions about the emission units listed in Attachment 1 to this document. Part I covers 

essentially all emission units except for chemical recovery combustion sources (which are covered in Part III). 

Section D, How to Complete the Part I Survey, explains how to treat various configurations of emission units (e.g., 

multiple emission units venting to the same stack, etc.) for each survey tab. Attachment 2 contains a listing of small 

business size standards for North American Industry Classification System (NAICS) code Subsector 322, Paper 

Manufacturing. Finally, Attachment 3 of this survey contains a table of emission units and pollutants for which 

existing emission test data are requested under Part I. 

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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 processing NESHAP (40 CFR Part 63, subpart S), and selected definitions from 

the NSPS and NESHAP General Provisions. 

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

Table 1. Part I Survey Spreadsheets and Tabs to Complete 

Spreadsheet and tab Types of mills that should complete this spreadsheet tab 

P&P survey_PI.xls 

Mill All mills 

PI Equip detail All mills 

PI Permit limits All mills 

PI Controls Mills with add-on air pollution controls on pulping emission units, bleaching 

emission units, or papermaking emission units. 

Pulp prod Mills that produce any type of pulp (including chemical, mechanical/groundwood, 

secondary fiber, including non-wood pulp) 

Byproducts Mills that produce turpentine or tall oil byproducts from pulping processes 

Kraft condensates2 Mills that perform kraft pulping 

CCA2 Mills that perform kraft pulping and use the clean condensate compliance 

alternative (CCA) 

Bleaching Mills that perform bleaching 

Paper prod Mills that produce paper or paperboard products 

HAP additives Mills that produce paper or paperboard products 

WW Mills with onsite wastewater treatment plants 

PI Emissions test data Mills operating emission units for which test data are requested in Attachment 3 to 

this document. 

P&P CEMS_PI.xls 

CEMS data1 Mills operating CEMS on emission units listed in Attachment 1 to this document. 

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

APCD costs Mills that installed selected air pollution controls (see section D4) 

Equip change costs Mills implementing selected process or equipment changes (see section D4) 1

Separate tabs are included for different pollutants and for CEMS cost. 

2

This tab does not apply for synthetic area sources. 

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 

intent 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. 

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B. Confidential Business Information (CBI) 

The U.S. Environmental Protection Agency’s (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 indicating in the red block at the top 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 clearly label any flow diagrams or other 

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 mills claiming large amounts of information as trade secrets, especially information that is readily reported by 

other mills without such claims. 

C. How to Submit Your Part I Survey Response 

If your response to this information collection request includes 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 mailing addresses. 

C1. Submitting Your Non-CBI Response 

Follow these instructions for the non-CBI portions of your survey response (or for responses that are entirely nonCBI.) 

After you have completed and reviewed your survey response, sign and date the certification form in Attachment 4 

of the Survey Overview document. Remove 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 portions of your completed response, non-CBI flow diagrams, 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 attachments to your survey (such as the signed certification form, hard 

copy flow diagrams, test data, wastewater emissions modeling reports, etc.). Please clearly label and mail the nonCBI 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 deadline in the Section 114 letter. (Note: If the spreadsheet/diagrams/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 Mailroom (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. 

C2. 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 CBI 

portion of your data (i.e., only the red highlighted data in the survey spreadsheet). Include on the disk any flow 

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diagrams or pages of other attachments to your survey response containing CBI, with the CBI portions of the 

diagrams/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. Roberto 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 I Survey 

Your survey response will consist of flow diagrams, test reports, and completed Microsoft Excel spreadsheets. 

Separate Excel spreadsheet files are provided for completion (P&P survey_PI.xls; P&P CEMS_PI.xls; P&P costs 

OPTIONAL_PI.xls). You must complete certain tabs of the P&P survey_PI.xls spreadsheet file (depending on the 

type of mill you operate) as shown in Table 1 above. The P&P CEMS_PI.xls spreadsheet file is to be completed if 

you have continuous emissions monitoring data to supply. The P&P costs OPTIONAL_PI.xls spreadsheet file is an 

optional spreadsheet file that can be completed to supply control measure cost information helpful for EPA’s 

regulatory analyses. One additional file, Boiler MACT Code Lookup.xls, is provided for your convenience and to 

reduce survey effort in case you wish to locate and supply your Boiler MACT survey ID codes when completing 

P&P survey_PI.xls. 

You will enter data into the white (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. 

D1. Flow diagrams 

Please provide a process flow diagram (or diagrams) showing the equipment listed in Attachment 1 (to both survey 

Parts I and III). No additional diagrams are requested in Part III, so please include chemical recovery combustion 

sources in the diagrams submitted in response to Part I. 

Readily available block flow diagrams (e.g., such as those used for permit applications) will suffice. Electronic or 

hard copies are acceptable. You need not prepare any new flow diagrams. It is acceptable to hand-mark changes on 

an older diagram that may no longer be completely reflective of current operations. Examples of diagrams that 

would be helpful for EPA are as follows: 

Chemical recovery area. A diagram showing each chemical recovery furnace/combustion unit, black 

liquor oxidizer (if used), smelt or ash dissolving tank, causticizing equipment, lime kiln/calciner, and liquor 

storage tanks or ponds would be helpful. 

Pulping process. A diagram showing the equipment in all pulping lines, including the digester area, pulp 

washing lines, evaporator lines, and oxygen delignification systems, would be useful. The diagram could 

show any brown stock washers, hoods, filtrate tanks, vacuum pumps, screens, knotters, deckers, stock 

chests (including open stock chests, pulp storage tanks), thickeners, and weak black liquor storage tanks. 

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Deckers, screens, knotters, stock chests, and pulp storage tanks following the last stage of pulp washing 

and/or those located prior to the paper machines are also of interest. 

Black liquor gasification. If black liquor gasification is used, a diagram and description of the system, 

including any combustion controls or add-on controls used to reduce air pollutants, would be helpful. 

Wastewater treatment plant (WWTP). A flow diagram of each WWTP showing each wastewater 

handling/treatment unit would be useful. 

How detailed must my diagram(s) be? 

The EPA will use the diagram(s) to aid in understanding the general mill flow and any unique 

characteristics in the mill layout. It is not necessary to show every single vent of every emission unit 

on the diagrams. However, the diagram should provide enough information so it is clear how 

emissions are collected and controlled. For example, if all digester vents are routed to a low-volume, 

high-concentration (LVHC) collection system, then it is not necessary to show each individual 

digester vent when one line drawn from a digester “block” to the LVHC collection system is 

informative.

D2. Process data (P&P survey_PI.xls) 

In this portion of the survey, you are asked to add data to the various tabs in the P&P survey_PI.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.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 write 

in information if your selection is not contained in the pull-down menu. 

Why does EPA need process data? 

Facility and equipment details are being requested to inform the technology review of the pulp and 

paper NESHAP and NSPS and to provide information on means of reducing residual risk. While the 

NEI 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 technology review of the NESHAP and NSPS 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). Applicability of the NESHAP and NSPS 

compliance options depends on the specific process equipment. 

Several IDs are requested throughout the pulp and paper survey response spreadsheet(s), including: 

• NEI Site ID 

• Emission Unit ID 

• Boiler MACT survey IDs: FacilityID and UnitID [Optional] 

• Collection system ID 

• Bleaching line ID (if needed) 

• 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 

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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 the 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. Note that Emission Units IDs 

are limited to 6 text characters in the NEI. You will specify the Collection system ID and APCD_ID in the PI Equip 

detail and other spreadsheet tabs. The Bleaching line ID would be used in the Bleaching tab, if needed, for plants 

with multiple bleaching lines. 

A “comments” column is included to the right of each spreadsheet should you wish to supply any comments on the 

information provided. 

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 functional and 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 consistent 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 the ID cells. For example, 

Emission Unit ID “DIG1” is not read the same as “DIG-1” or “DIG-1_” by data base software. 

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What if I have difficulty pairing emission units with corresponding Emission Unit IDs 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 pulp 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 Part 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 Equip 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 (covering 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 machine’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 unrelated 

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 least one mill. In this situation, 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 data 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 for 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 tabs to clarify any 

matching discrepancies with the Part II NEI. These notes will assist EPA in analyzing the data and 

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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. 

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 agency 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. Likewise, for 

papermaking equipment you may use the nominal paper throughput capacity. 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 constraints of the 

pulping/papermaking/chemical recovery process within which it is located. 

What if I do not know or have the information to answer 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 respondents 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 responses as “UK or “NA” are likely 

to receive scrutiny and follow-up inquiries from EPA related to their survey response. 

a. Mill tab 

Complete the columns following the instructions provided in the “Instruction” row. Your response in the Mill tab 

will consist of one row of data. These data will be used by EPA to characterize your facility and identify applicable 

regulations. 

Size of entity. Attachment 2 to this document contains a listing of North American Industry Classification 

System (NAICS) codes and small business size standards for NAICS subsector 322. For private 

businesses, small entity is defined for each NAICS code of the owning entity based on number of 

employees and/or company revenue. The parent company number of employees is used for the pulp and 

paper subsector (322). Note that the “number of employees” is calculated according to the Small Business 

Size Regulations codified at 12 CFR 121.06, where all individuals employed on a full-time, part-time, or 

other (e.g., temporary) basis are counted equally. 

Paper or paperboard processes/products. Enter the total number of operable paper machines located at the 

mill in 2009 (including any machines that were temporarily idle due to economic conditions in 2009) in the 

“Total number of paper machines” column. Enter the total paper/paperboard machine nominal daily 

production capacity as of 2009 in the "2009 nominal daily production capacity total for paper/paperboard 

(air dried short tons/day)” column. Note that nominal daily production capacity represents the 

paper/paperboard production capability of the operable machines and may be greater than 2009 actual 

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production. Next, indicate the types of paper grades the facility is capable of producing across all paper 

machines (again, including machines temporarily idle in 2009). 

Paper/paperboard capacity utilization. You are asked to provide the decimal percentage utilization for 

paper/paperboard nominal daily production capacity at your mill for the survey base year (2009). In 

addition, because 2009 was characterized by short-term production curtailments at many mills due to the 

U.S. economic situation, you are asked to provide a 5-year average nominal daily production capacity 

utilization. For example, suppose a mill has 3 paper machines but one of these machines was shut down 

due to economic reasons for half of 2009. The capacity utilization could be figured as follows: 

A B C D E F 

Paper 

machine 

Nominal 

daily 

production 

capacity 

(air dried 

st/day) 

Maximum 

production 

days/yr 

Actual 

production 

days/yr 

2009 nominal 

production 

capacity, air 

dried st/yr 

(= A x B) 

2009 actual 

production, air 

dried st/yr* 

(= A x C) 

2009 decimal 

percent 

utilization* 

(= E / D) 

#1 400 360 340 144,000 136,000 

#2 500 360 355 180,000 177,500 

#3 200 360 175 72,000 35,000 

TOTAL 1,100 396,000 348,500 0.88 

st = short tons (1 st = 2000 pounds) 

*The EPA recognizes the potential for actual production or actual utilization by machine to be considered 

as sensitive information (e.g., to be CBI). Therefore, EPA is asking that you report the overall decimal 

percent utilization aggregated across all machines instead of utilization for each machine. 

It should be noted that the owner may not have production data back to 2005 if the facility was purchased 

after January 1, 2005. If this is the case, the facility should average the years that are available and note as 

such in the “comments” column. 

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b. PI Equip detail tab 

All mills are asked to complete the PI 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). 

The types of emission units listed in Attachment 1 that you operate should be included in the PI Equip detail tab. 

Essentially, you are requested to provide information for most of the equipment at your mill in Part I (except for 

chemical recovery combustion sources such as recovery furnaces, semi-chemical liquor combustors, smelters, smelt 

dissolving tanks, lime kilns, calciners, and black liquor oxidation systems which are covered in Part III). However, 

if you operate chemical recovery combustion sources or power boilers that burn pulp mill non-condensable gases 

(NCGs) or stripper off gases (SOG), then you will need to identify these combustion sources as the air pollution 

control device (APCD) in the PI Equip detail tab. Boilers are a special case. Specific instructions pertaining to 

boilers are included in “Boilers, thermal oxidizers, and direct-fired dryers” below. 

Columns A through AR of the PI Equip detail tab ask generic questions for all emission units listed in Attachment 

1. The columns to the right of column AR request design and operating details for specific types of emission units 

(e.g., digesters, strippers, etc.). The table below summarizes the different types of equipment for which specific 

questions are included in the PI Equip detail tab. 

PI Equip detail tab 

columns 

Description of information requested 

A-AR Equipment, exhaust flow rate, controls, and Federal rule applicability for each emission 

unit and collection system. 

AS-AU Digesters 

AV-AZ Pulp washers 

BA-BB Knotters, screens, and deckers 

BC-BE Evaporators 

BF-BH Oxygen delignification 

BI-BR Strippers 

BS-BV Pulp storage and liquor storage 

BW-BZ Liquor storage ponds 

CA-CD Causticizing equipment 

CE Fuel-fired equipment (e.g., boilers*, thermal oxidizers, direct-fired dryers, etc.) 

CF-CG Equipment incinerating NCG or SOG 

CH-DP Primary and supplemental fuels for fuel-fired equipment (e.g., for boilers*, thermal 

oxidizers, direct-fired dryers, etc.) 

DQ-DW Emission unit startup and shutdown. 

DX Comments 

*Not required for boilers if Boiler MACT survey IDs are specified. 

Data are requested for each emission unit (and need not be broken out by individual emission points 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 PI 

Equip detail tab. Some common configurations of emission units are addressed below. 

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Multiple emission units ducted to a single release point. Unless the emission units are numerous and share 

similar design/operation (see exception below), then you should list each emission unit separately in the PI 

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 separately and provide the same Collection system ID for the different Emission Unit IDs. 

For example, an LVHC collection system (Collection system ID LVHC01) may collect emissions 

from multiple emission points associated with digesters 1, 2, and 3 and an evaporator (Emission 

Unit IDs D1, D2, D3 and EVAP1). You should list digesters 1, 2, and 3 and the evaporator on 

four separate rows in the PI Equip detail tab (with 4 separate Emission Unit IDs, as shown above) 

and provide the data requested for each emission unit, indicating for each entry that the emissions 

are collected by the LVHC collection system (Collection system ID LVHC01). You should also 

list the LVHC collection system in the Emission Unit ID column (using the Collection system ID = 

LVHC01 as the Emission Unit ID = LVHC01) so you can provide control information and 

equipment details for the LVHC collection system. 

Exception: If the multiple emission units ducted to a single release point are numerous and identical in 

design/operation (for example – 20 batch digesters all ducted to LVHC control and processing softwood), 

then you may lump the emission units together on one row and note their total capacity. Note how many 

emission units are lumped together in the “Emission unit description” column (e.g., digester (20 units)) 

Single emission unit with multiple release points. In the PI Equip detail tab, EPA is most interested in 

learning how (or if) your emission unit is controlled and what Federal regulation compliance options are in 

use as indicated in columns A through AR. 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 emission unit in the PI Equip detail tab. 

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 PI Equip detail tab, and then indicate in 

the “Emission unit description” 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. 

If the different release points (vents or stacks) are uncontrolled, have the same control, and have the same 

NSPS/NESHAP applicability then you should list the emission unit on only one row. 

For example, consider Emission Unit ID (OXDLIG), an oxygen delignification system with 6 

uncontrolled vents. You would list this OXDLIG system in only one row. In the “Emission unit 

exhaust parameters (if emitted through a conveyance)” columns, you would enter the total flow 

from all vents combined and note in column Q stating "multiple vents combined.” You would 

specify the emission release details (exhaust flow, APCD information and NSPS/NESHAP 

compliance options) and any requested equipment information (year installed, hr/yr, etc) in the 

single row. 

If an emission unit has some groups of release points (vents or stacks) that are controlled and some that are 

uncontrolled (or if NSPS/NESHAP applicability varies for different groups of release points) then you 

should list the emission unit on multiple rows for each group of release points with similar controls or rule 

applicability. 

For example, consider Emission Unit ID (OXDLIG), an oxygen delignification system with 3 

uncontrolled vents (under the CCA compliance option) and 3 thermal oxidizer-controlled vents. 

You would list this OXDLIG system in two separate rows and distinguish the groups of release 

points using the “Emission unit description” column. In the “Emission unit exhaust parameters (if 

emitted through a conveyance)” columns, you would enter the total flow from all vents combined 

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for each group of vents and note in column Q "multiple vents combined” on each row. 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 PI 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 PI 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 PI Equip 

detail tab, and enter “FUGITIVE” in the “Configuration if not emitted through a conveyance” 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 PI Equip detail tab (e.g., 

as a “Single emission unit with multiple release points” as described in the instructions immediately above 

for the PI 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 the 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 PI Equip detail tab, except as specified for alternate (backup) controls below. 

Air pollution control devices (APCDs). In the APCD columns, enter primary APCDs (i.e., the pollution 

control used most frequently) in the sequence in which they are used to control emissions from each 

emission unit (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 the Controls tab. For example, 

If 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. 

If a white liquor scrubber (identified as WLIQSBR) is used to scrub SOG prior to burning of the 

SOG in a lime kiln (Emission Unit ID = LK2), then APCD1_ID = WLIQSBR and APCD2_ID 

= LK2. 

Emission units routed to a boiler, lime kiln, or recovery furnace for emissions control. Enter the Emission 

Unit IDs for each emission unit (e.g., digester) in the Emission Unit ID column. Use the boiler, lime kiln, 

or recovery furnace’s Emission Unit ID as the APCD_ID in the APCD columns. The same Emission Unit 

ID (e.g., for the lime kiln or recovery furnace) should be used in Part III when equipment-specific details 

are provided for these equipment. (Note that process details for lime kilns and recovery furnaces are not 

required in Part I, but would be entered in Part III. You would only identify the lime kiln or recovery 

furnace in Part I if it serves as the APCD for a Part I emission unit.) 

Alternate controls. Alternate (or backup) controls include alternative controls used when flow from an 

emission source (e.g., high-volume, low-concentration (HVLC) or LVHC collection system) is diverted 

from the primary control device to a less frequently used control device. For example, the primary LVHC 

control may be lime kiln 1 and the backup control may be a boiler when lime kiln 1 is not operating. Enter 

alternate controls in the “Alternate method of control” column of the PI Equip detail tab. Do not include 

alternate controls in the columns for APCD1 through APCD4. 

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Complete the applicable equipment-specific details requested in columns AS through DU for each type of emission 

unit in the PI Equip detail tab by following the directions in the “Instruction” row of the tab. Additional specific 

instructions are provided below for equipment requiring instructions 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”. 

All emission units listed in Attachment 1. Complete columns A through AR. 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 AS through DU may also apply for selected emission unit types. 

Pulp processing equipment. Information pertaining to pulp processing equipment such as digesters, pulp washers, 

knotters, screens, deckers, evaporators, and oxygen delignification is requested so EPA can determine the population 

and characteristics of these emission units following subpart S MACT compliance. Capacities are requested so EPA 

can estimate emissions and perform impacts analyses. 

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

Several questions in the PI Equip detail and other survey tabs ask for process parameters such as 

exhaust flow rate (acfm), temperature, etc. Unless otherwise specified, typical values are requested, 

and are subject to the respondent’s discretion. For example, if you measure a particular parameter 

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 most recent measurement. 

Strippers. Information related to strippers is requested to provide an understanding of the number and characteristics 

of strippers in use at pulp and paper mills following subpart S compliance. 

Pulp storage and liquor storage, and liquor ponds. HAP emissions may be associated with pulp and cooking liquor 

storage tanks, and liquor storage ponds. Questions pertaining to pulp and liquor storage are asked to provide an 

inventory of storage equipment and to characterize any storage processes that may require further analysis for 

subpart S residual risk purposes. 

Causticizing equipment. Limited questions are asked for equipment in the causticizing loop of mills that perform 

kraft or soda pulping. Information on causticizing operations provides inventory detail and process rates for 

purposes of emission calculations, and can inform EPA of practices that could be used to reduce emissions from the 

lime kiln or from other causticizing equipment. 

Boilers, thermal oxidizers, and direct-fired dryers. The EPA is requesting limited information on boilers (and other 

fuel-fired equipment such as thermal oxidizers and dryers) in the PI Equip detail tab. Many pulp and paper mills 

use boilers for primary or backup control of organics from pulping process, and some mills use thermal oxidizers for 

this purpose. Boilers (and other fuel-fired equipment) currently contribute to the facility-wide risk levels at pulp and 

paper mills. 

Boilers are a special case. Many pulp and paper mills completed EPA’s 2008 Boiler MACT survey that provides 

greater detail than are requested in the pulp and paper sector survey. You are asked to first list all boilers at your 

facility in the Emission Unit ID column of PI Equip detail. First, you should either (1) enter the Boiler MACT 

survey IDs requested for each boiler, or (2) complete all of the details requested in PI Equip detail for the boilers. If 

you enter the Boiler MACT survey IDs (FacilityID and UnitID) in the initial columns of PI Equip detail: 

• You do not need to complete following portions of PI Equip detail for your boilers: year installed, 

operating hr/yr, emission unit exhaust parameters, combustion modifications/controls, process controls, air 

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pollution controls, fuel-fired equipment, primary fuels, supplemental fuels, or emission unit 

startup/shutdown. 

• You are required to complete the Subpart BB and Subpart S applicability columns and “equipment 

incinerating NCG or SOG” columns for boilers burning pulp mill NCG or SOG. 

• Boilers burning NCG/SOG (and the boiler’s APCDs) must be indicated as the air pollution control on the 

rows for the Emission Unit IDs controlled by the boiler. 

Thermal oxidizers may be used to control emissions from Part I or Part III emission units. For example, LVHC 

thermal oxidizers are covered under Part I, and semi-chemical liquor combustor thermal oxidizers are covered under 

Part III). You will only enter the thermal oxidizers that control emissions from Part I emissions units (listed in 

Attachment 1 of this document) in Part I of the survey. 

Wastewater handling/treatment units. Complete the generic questions in Columns A through AR of the PI Equip 

detail tab for any wastewater handling/treatment units that are closed and/or vent through a conveyance. 

Primary and supplemental fuels. 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 firing rates for 

various nationwide impact analyses. Because the types and amounts 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 and supplemental fuel information is requested for fuel-fired equipment such as boilers, thermal oxidizers 

controlling Part I emission sources, and direct-fired dryers (e.g., pulp dryers or paper machine dryers). NCG and 

SOG are not considered to be either primary or supplemental fuels for purposes of this survey. Information for 

secondary and additional fuels used routinely for multifuel-fired equipment may be indicated in the supplemental 

and other fuel columns. 

Emission unit startup and shutdown. Complete the startup 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 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. The startup and shutdown 

questions would also identify pulp and paper emission unit types for which startup and shutdown are not already 

addressed with the current emission standards. You are asked to supply 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 startup and shutdown data in the PI Equip 

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

c. PI Permit limits tab

Permit limits for each emission unit/point listed in Attachment 1 of this document are requested with one exception 

(boilers). You do not need to provide permit limits for boilers. You are only asked to include permit limits for the 

emission units listed in Part I Attachment 1 at this time. However, you may also include permit limits for the 

chemical recovery combustion source emission units listed in Part III Attachment 1 (and, therefore, would not need 

to include these limits in Part III). 

If available in the permit, provide limits in terms consistent with the suggested units shown in Table 2 below. These 

suggested units were taken from existing Federal limits codified in 40 CFR Part 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 

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options. However, you do not need to provide every 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 (O2) for a combustion unit 

sulfur dioxide (SO2) limit specified in the permit in terms of ppmdv, lb/hr, lb/day, and tpy, lb/MMBtu at specified 

% O2, 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 similar emission units nationwide. Please be as specific as possible when entering permit limit 

units. Include any oxygen correction factors (% O2). Be sure to note if ppm values are on a dry (d) or volume (v) or 

weight (w) basis if specified this way in your permit (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 the 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 limits). 

Permits restating NESHAP and NSPS limits. Your permit may simply restate the emission limits contained 

in Federal rules such as NESHAP subparts S and 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 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. 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 limits of most interest to EPA are those for fuel-fired equipment such as recovery 

furnaces, semichemical combustion units, lime kilns, and thermal oxidizers. 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 PI Permit limits tab, we will accept a copy of your 

operating permit (e.g., title V operating permit) instead of the completed PI 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. 

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Table 2. Suggested Units of Measure for Permit Limits 

Pollutant Suggested units 

PM1 Recovery furnaces/chemical recovery combustion units: gr/dscf @ 8% O2

SDT: lb/ton BLS 

LK: gr/dscf @10% O2

PM101 Other processes: lb/ton of throughput, lb/MMBtu, gr/dscf, g/dscm, or specify 

PM2.51

Opacity % (provide averaging time) 

TRS RF/combustion units: ppmdv @ 8% O2

SDT: lb/ton BLS (as H2S) 

LK: ppmdv @ 10% O2

Other processes: lb/ADT pulp and/or ppmdv 

SO2 lb/MMBtu and/or ppmdv or limits on fuel S content 

NOX lb/MMBtu (as NO2) 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: lb/ton BLS 

HCl ppmdv and/or % reduction 

Methanol and gaseous organic 

HAP 

chemical recovery combustion sources: lb/ton BLS 

process sources: ppmv @ 10% O2, 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 limits distinguish between the filterable and condensable PM 

fractions. 

d. PI Controls tab 

Complete the PI Controls tab by following the instructions in the “Instruction” row for add-on APCDs used to 

control pulp and paper emission units. The data requested in the PI 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. low-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). 

Baghouses, cyclones, and other material handling equipment. The EPA is most interested in details for control 

systems used to reduce HAP emissions (for equipment in the NESHAP source categories) and criteria air pollutant 

emissions from equipment in the NSPS subpart BB source category. You do not need to include the specific details 

requested in the PI Controls tab for control devices used solely for wood/material handling operations (e.g., 

baghouses or cyclones on pneumatic wood handling systems; and particulate controls on lime, starch, or coal 

handling etc. need not be included). 

Boilers. You do not need to include details for APCDs used to control boilers in the PI Controls tab. 

Actual control efficiency. Actual control efficiencies are requested for PM, TRS, HCl, SO2, 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 reduction in the requested pollutant 

across the control device, then you would enter this test result as the “actual” control efficiency. You may leave the 

control efficiency columns blank (rather than marking as “NA”) if actual control efficiency is not known (or not 

applicable for a given pollutant). 

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Strippers. Specific information for strippers used to reduce air emissions from process liquid or wastewater streams 

is requested in the PI Equip detail tab rather than in the PI Controls tab.

Thermal oxidizers. Questions pertaining to thermal oxidizers controlling Part I emission sources are included in 

both the PI Controls and PI Equip detail tabs. The PI Equip detail tab contains questions about heat input capacity, 

equipment incinerating NCG or SOG, and primary or supplemental fuels. 

Control device startup 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 

different combinations of emission units and control devices used in the pulp and 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, you are asked to supply information for routine startup and shutdown 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 PI Controls tab are being 

sought for regulatory development purposes, and will not be used for enforcement purposes. 

e. Pulp prod tab

The Pulp prod tab is to be completed by all mills that produce pulp onsite using chemical, semichemical, 

mechanical, non-wood, and secondary fiber pulping processes. This tab is arranged in a way to accommodate 

multiple pulping processes or pulping lines (if applicable) and each pulping process/line should occupy only one 

row (e.g., a mill that co-produces kraft and mechanical pulps should use two rows). Some data fields apply for 

specific types of pulp (e.g., mechanical pulp, non-wood pulp). If a data field does not apply to a particular type of 

pulping line, you may simply leave the field blank rather than marking it “NA”. Provide data for the 2009 operating 

year. 

The pulp capacity data will be used by EPA to understand the general mill flow and in estimation of impacts and 

economic analyses. In the Pulp prod tab, the 2009 pulp capacity (ADTP/d) and capacity utilization refer to 

unbleached pulps (i.e., pulp exiting the pulping line prior to any brightening or bleaching). [Note: Capacity of 

bleached pulp (e.g., pulp exiting the bleaching/brightening line) is requested in the Bleaching tab.] An example of 

how to calculate the pulp capacity utilization percentage requested in the Pulp prod tab is as follows: 

A B C D E F 

Pulping 

process 

Pulp nominal 

daily 

production 

capacity 

ADTP/d in 

2009 

Max. 

d/yr 

Actual 2009 

operating d/yr 

when pulp was 

produced 

2009 nominal 

production 

capacity, 

ADTP/yr 

(= A x B) 

2009 actual 

production, 

ADTP/yr* 

(= A x C) 

Pulp capacity 

utilization decimal 

percentage in 2009 

(= E / D) 

kraft 950 365 340 346,750 323,000 0.93 

mechanical 300 365 250 109,500 75,000 0.68 

ADTP/d = air dried tons of pulp per day. *The 2009 actual pulp production could be determined by multiplying 

columns A x C or by other means. The EPA is not asking that you report the 2009 actual production. 

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In the Pulp prod tab, EPA asks questions regarding how various pulps are used by the mill in order to understand the 

mill flow for purposes of economic modeling. With these questions, EPA seeks the amount of unbleached pulp 

from the pulping line that typically: 

• goes to an onsite bleaching/brightening line (if applicable) 

• is sold (or transferred to another mill within the same company) as unbleached market pulp 

• is used onsite to manufacture unbleached paper/paperboard 

Complete the Pulp prod tab by following the instructions in the “Instruction” row. 

f. Byproducts tab

Mills that recover turpentine or tall oil from pulping processes should complete the Byproducts tab. Basic turpentine 

and tall oil production information are requested (hr/yr, gal/yr, and equipment supplying byproduct production). 

Turpentine recovery systems are covered under subpart S. Tall oil production may be considered in the review of 

pulp and paper regulations. The information requested may be used to estimate emissions and in economic 

calculations. 

Complete the Byproducts tab by following the instructions in the “Instruction” row. 

g. Kraft condensates tab

Complete the Kraft condensates tab by following the instructions in the “Instruction” row. The kraft condensate 

standards in subpart S apply to certain “named” condensate streams originating from the following equipment: 

• Digester systems 

• Turpentine recovery systems 

• Evaporator systems 

• HVLC collection systems 

• LVHC collection systems 

• Combined systems (i.e., a combination of any of the above named systems) 

The kraft condensate streams are "named" in §63.446(b). In the kraft condensates tab, you are asked to list (select 

from menu) each kraft condensate stream (or combination of streams) named in subpart S. Next you are asked to 

enter the Emission Unit IDs or Collection system IDs associated with each kraft condensate stream, and indicate 

whether the condensate stream is treated (or partially treated) according to subpart S. 

You do not need to list every single condensate stream separately. If condensates from multiple systems are 

combined for treatment, then you may select menu choice “Combined systems” and then enter the Emission Unit 

IDs or Collection system IDs for the combination of systems (grouped according to the treatment method). 

In some cases mills may have complied with the subpart S kraft condensate standards through implementation of an 

equivalency-by-permit project involving other condensate systems not named above. If you are controlling 

condensate streams other than those named in subpart S for purposes of subpart S compliance, then you are asked to 

list these “un-named” condensate sources as menu choice “Other systems” and then describe the streams being 

controlled (e.g., Other systems – foul water collection). 

Uncontrolled/uncollected streams (table heading II). Mills may either collect/control all "named" kraft pulping 

condensates (according to §63.446(c)(1)), or employ one of the volume reduction options are specified in subpart S 

at §63.446(c)(2) or (3). Mills may also comply with subpart S through equivalency-by-permit. For “named” 

condensate streams that are uncollected/uncontrolled, you are asked to complete the question in table heading II to 

describe why the stream “named” in subpart S is not collected/controlled (e.g., because you meet one of the volume 

reduction options; or use equivalency-by-permit to control un-named streams in lieu of the named streams). 

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Recycled streams (table heading III). Indicate if subpart S compliance is achieved by recycling the condensate to 

equipment meeting the kraft pulping system vent standards. Specify the equipment Emission Unit ID receiving 

recycled condensates. 

Condensate treatment (table headings IV-VII). Specify the treatment methods and provide compliance test results 

under table headings IV-VII for each condensate stream treated/controlled for purposes of subpart S compliance. 

The kraft condensate control options are summarized as follows. This table corresponds with the pull down menu 

options for condensates treated by steam strippers, biological treatment, or other means. 

Control option Applicability Rule reference 

92% total HAP reduction (by weight) §63.446(e)(3) 

Remove 6.6 pounds/ton ODP Mills that do not bleach §63.446(e)(4) 

210 ppmw at the outlet of the control 

device Mills that do not bleach §63.446(e)(4) 

Remove 10.2 pounds/ton ODP Mills that bleach §63.446(e)(5) 

330 ppmw at the outlet of the control 

device Mills that bleach §63.446(e)(5) 

Remove prorated mass of ___ pounds/ton 

ODP. {Respondent should specify limit in 

blank} 

Mills producing a 

mixture of bleached and 

unbleached pulp §63.446(i) 

If your mill uses multiple treatment methods for a given kraft condensate stream, please answer the questions for 

each treatment method (under table headings III, IV, V, and/or VI) and the question in table heading VII. For 

example, if your mill normally treats condensates with a steam stripper but relies on biological treatment when the 

stripper is down, then you would respond to the questions under table headings IV (stripping), V (biological 

treatment), and VII (multiple treatment methods). 

Comments. Should you have comments regarding the kraft condensate data you supply, please enter these 

comments in column S. 

h. CCA tab

The CCA tab is divided into two portions: (1) Emission Balance to the left of the orange vertical line (column H), 

and (2) CCA Equipment List on the right of the orange vertical line. You will enter one row of data for the 

Emissions Balance and multiple rows of data for the CCA Equipment List. This information is being requested to 

inform EPA of the mill-specific emission units involved in CCA compliance calculations. 

The CCA tab must be completed once for each set of CCA compliance calculations used by your mill. Add another 

CCA tab if you need to provide more than one set of CCA calculations. As an alternative to completing the CCA 

tab, you may attach separate documentation of your CCA calculations used for purposes of showing compliance. 

Sources eligible for inclusion in the CCA as credit generators include (but are not limited to): pulping systems, 

bleaching systems, causticizing systems, wastewater systems, and papermaking systems. Debit generating sources 

can include equipment from the kraft mill HVLC system, including: pulp washing systems, knotter systems, screen 

systems, decker systems, O2 delignification systems, and weak liquor storage tanks. Refer to the system definitions 

in subpart S at §§63.441 and 63.447(a). If equipment other than that listed above is included in your CCA 

calculations (e.g., equivalency-by-permit facilities), please include that equipment in the CCA tab. EPA is 

interested in identifying which mills are using the CCA option and the mill-specific equipment used in CCA 

calculations. EPA is not requesting detailed calculations used to show compliance with the CCA at this time. 

However, EPA reserves the right to request additional detail if needed as a follow-up to this survey. 

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Complete the CCA tab by following the instructions in the “Instruction” row. 

i. Bleaching tab 

All mills that perform bleaching or brightening of chemical, mechanical, secondary fiber, or non-wood pulps should 

complete the portion of the Bleaching tab to the left of the orange vertical line (column M) to describe the bleaching 

(or brightening) systems used at your mill. Note that, for brevity, the terms “bleaching” and “brightening” are used 

interchangeably in the Bleaching tab (e.g., the word “bleaching” can be read to mean “brightening” if that is the 

process your mill uses). 

Your response in the Bleaching tab will consist of one row for each bleaching/brightening line located at your mill. 

Most mills will have only one or two bleaching line rows. For example, a mill that produces bleached chemical 

pulp, bleached secondary fiber pulp, and brightened mechanical pulp could include three rows (one for each type of 

pulp that is bleached/brightened using separate bleaching/brightening processes). 

If your mill does not have a bleaching “line” (e.g., a TMP mill with only one emission unit for mixing brightening 

chemicals with pulp), the you need only to list the Emission Unit ID for the bleaching/brightening emission unit and 

answer the questions to the left of the orange vertical line (entering “NA” for questions that are not applicable. 

If your bleaching system includes any stages that use chlorine or chlorinated compounds, then you must complete 

the portion of this tab to the right of the orange vertical line. Extraction or other bleaching stages that do not use 

chlorine or chlorinated compounds are not covered by subpart S and should be reported in the Bleaching tab with 

“NA (no chlorine or chlorinated compounds used in this stage)” indicated. 

When specifying controls used for the various bleaching stages, enter not applicable “NA” for stages without 

control. Enter the APCD_ID used in the PI Equip detail and PI Controls tabs when referring to any control device. 

Each bleaching stage includes several vents: the tower vent, washer hood, seal tank vent, chemical and steam 

mixers, and vacuum pumps. If all vents from a particular bleaching stage are not routed to the control device 

indicated for that stage, then you should describe the control system configuration in the control methods column. 

Responses to these bleaching questions will be used to characterize mills according to bleaching processes used, 

estimate nationwide emissions, and identify subpart S compliance options commonly used (e.g., to determine if any 

remaining residual risk is associated only with bleaching at mills meeting certain compliance options). Information 

on how the mill uses the pulp exiting the bleach plant may be used for economic modeling and in characterization of 

potential emissions from paper machines (e.g., use of bleached/unbleached pulp produced onsite, use of purchased 

pulp, effects of bleaching process on paper machine emissions, etc.).

Complete the Bleaching tab by following the instructions in the “Instruction” row.

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j. Paper prod tab 

All mills that produce paper should complete the Paper prod tab. Report information for all operable paper 

machines (including idle machines that are capable of operating in the future). Do not include pulp dryers in the 

Paper prod tab. Complete the Paper prod tab by following the instructions in the “Instruction” row.

If multiple paper grades are produced on the same paper machine (e.g., coated free sheet produced some of the time, 

and uncoated freesheet produced at other times), then you will need to include paper machine information on 

separate rows. Given the numerous specific grades of paper and paper characteristics, EPA requests that you 

distinguish among a relatively short list of generalized paper grades, including: 

coated free sheet kraft packaging 

uncoated free sheet linerboard 

coated groundwood corrugating medium 

uncoated groundwood solid bleached board 

tissue & sanitary recycled board 

specialty packaging & industrial construction paper and board 

other * 

*Respondents are asked to specify a general paper grade in the event that one of the 

 general grades listed above is not representative. 

 

Information on pulp type is requested because it is possible that pulp type may have an effect on emissions 

(particularly for bleached versus unbleached pulps). Should EPA consider paper machines for residual risk 

rulemaking, information such as pulp type, whether the pulp is bleached or unbleached, paper grade, stock 

consistency, and liquid HAP concentration may be useful for purposes of subcategorizing paper machines. 

You are asked to specify the approximate makeup of each paper machine furnish - specifically the approximate 

percentage of each pulp type. We recognize that the percentage can vary throughout the operating year and within 

paper grades (due to specific product variations), and therefore, a specific percentage is not being requested. It will 

be sufficient to round to the nearest 5 or 10 percent. 

k. HAP additives tab

Complete the HAP additives tab for any stock preparation and paper machine additives that contain “measurable” 

concentrations of one or more of the following HAP: formaldehyde, acetaldehyde, napthalene, methylene chloride, 

acrylamide, or benzene. Only include in this tab additives with measurable quantities of HAP as reported on the 

material safety data sheet (MSDS) for the additive. For purposes of this survey, “measurable” is defined consistent 

with OSHA requirements that chemical suppliers provide specific constituent amounts in Material Safety Data 

Sheets for any carcinogens that are present in amounts greater than 0.1 percent and any non-carcinogens that are 

present in amounts greater than 1 percent. Information on lesser quantities of HAP ingredients is voluntary but not 

required. Although it is unclear whether paper machine additives contribute significantly to paper machine 

emissions (e.g., because additives may partition to the paper product or white water, and not necessarily to the air), 

EPA is requesting information for paper machine additives that contain HAP of significance for purposes of residual 

risk. EPA is not requesting information for other paper machine additives (many of which contain no HAP), except 

in determining any non-HAP substitutes for the additives. The HAP additives information would be used (e.g., 

along with emissions data for paper machines) to identify HAP-containing additives that may contribute 

significantly to paper machine HAP emissions or residual risk, and to evaluate work practices related to additives. 

Complete the HAP additives tab by following the instructions in the “Instruction” row. 

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l. WW tab

All mills with onsite wastewater treatment plants (WWTP) should complete the WW tab columns to the left of the 

orange vertical line (column AA). The first questions in the WW tab ask if your mill outsources wastewater 

treatment to a publicly owned treatment works (POTW) or other separate entity such as a privately held entity that 

may be owned and operated by your same company or a different company. The purpose of the WW tab is to 

provide EPA with information regarding the status of permitting requirements and emissions measurement for pulp 

and paper mill wastewater treatment plants. This information will be used by EPA for purposes of reviewing the 

pulp and paper regulations (e.g., NSPS and/or NESHAP subpart S). Use the WW tab to specify any 

Federal/State/local requirements, permit limits, fence-line monitoring, measurement methods (such as ambient 

measurements), or modeling methods that apply for measurement or estimation of HAP and TRS (including H2S) air 

emissions associated with the wastewater treatment system. 

In addition to questions about measurement and permitting status, mills are requested to submit a flow diagram of 

the WWTP (see section D1 of these instructions) and to complete some basic questions regarding WWTP capacity, 

the sequence of wastewater treatment units, and upstream controls/practices that reduce air emissions from the 

WWTP. Mills are also asked to identify any wastewater treatment units that are closed to limit emissions to the 

atmosphere, or equipped with a closed-vent collection system and APCD. If any wastewater treatment units are 

equipped with a closed-vent collection system and APCD, then you should also include the wastewater treatment 

unit in the Emission Unit ID column of the PI Equip detail and PI Control tabs and indicate the APCD information 

in those tabs. 

The series of questions seeking an approximate volume percentage of WWTP capacity from various mill areas will 

inform EPA of the overall nature of the wastewaters generated by pulp and paper mills for treatment. Mills are 

encouraged to complete this series of questions to the extent this information is known (or can reasonably be 

estimated). Otherwise, mills may enter “UK” for unknown. If the WWTP is outsourced to a joint treatment facility 

that treats process wastewater from several mills owned by the same company, then the volume percentage 

questions should be answered for each individual pulp and paper mill in their survey response considering the total 

volume of wastewater sent to the WWTP by that mill. 

Mills with wastewater treatment plants that serve as the biological treatment system for the subpart S kraft 

condensate standards must complete the questions to the right of the orange vertical line in the WW tab. These 

questions request the subpart S quarterly biological treatment system compliance testing results for the four quarters 

of calendar year 2009. This information will inform EPA of the performance of biological treatment systems in 

destroying HAP. 

Complete the WW tab by following the instructions in the “Instruction” row. 

D3. Test data 

Attachment 3 of this Part I survey contains a table of emission units and pollutants for which existing emissions data 

are requested. Emissions data are being requested in the form 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 the “PI Emissions test 

data tab” for emissions test reports. Follow the instructions for completing the “CEMS data spreadsheet (P&P 

CEMS_PI.xls)” if you have continuous emissions monitoring system (CEMS) data instead of emission test reports 

for a given 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 and 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. 

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Mills required to complete Part III may postpone until the deadline for Part III submittal of emissions test data and 

CEMS data required for the emission units listed in Part I Attachment 1 for the following pollutants: PM, PM2.5, 

TRS, NOx, SO2, and CO. 

a. PI Emissions test data tab 

Attachment 3 of this survey contains a table of emission units and pollutants for which existing emission test data 

are requested. You are not 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. 

Emissions test data are not requested for power boilers unless the power boiler is used to control NCGs or SOGs (in 

which case the test data requested are for the pulping systems controlled by the power boiler, assuming these 

emissions points have been tested). 

Review the test data request table in Attachment 3 of this survey. Locate 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 required 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 

need not supply emissions data for the prior configuration. However, you may voluntarily supply emissions data for 

prior configurations, as such information would be useful to EPA in characterizing emissions in general (for nonsite-specific uses), but we request that you identify that such data are no longer representative in the PI Emissions 

test data tab. 

Cutoff dates are provided in Attachment 3 for certain emission unit and pollutant combinations. More recent cutoff 

dates (e.g., 2001 or date of MACT compliance) 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 data prior 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 data 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, submit full and complete copies of the emission test reports, to include field and lab data sheets and 

example calculations, meeting the criteria in Attachment 3 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 PI Emissions test data tab to identify the specific emission units and control systems for which 

emission test reports are being submitted, the pollutant tested, and the test method. The PI Emissions 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 emissions test data received through this survey. 

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

The EPA is requesting existing CEMS data and/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. 

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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. 

You do not need to supply CEMS data for power boilers unless the boiler has a CEMS installed to show compliance 

with a NESHAP subpart S or NSPS subpart BB emission limit. 

A separate Microsoft Excel spreadsheet file (P&P CEMS_PI.xls) is provided for submittal of the requested CEMS 

data. The spreadsheet file contains individual worksheets (tabs) designed specifically for TRS (12-hour block 

average), TRS (hourly), Opacity, and other pollutants (NOx, SO2, CO, Methanol, Chlorine, 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 worksheets 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.xls spreadsheet file. 

TRS (12-Hour Average). This worksheet is designed for recovery furnaces, smelt dissolving tanks, lime 

kilns, digester systems, brown stock washer systems, multiple effect evaporator systems, and condensate 

stripper systems 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 TRS emissions guidelines). Respondents are requested to specify the Emission Unit ID (or Collection 

system ID), the APCD_ID, and report the 12-hour averages of CEMS concentration data for TRS for 

CY2009 operations. In addition, respondents are asked to provide 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 malfunction conditions. [Note: The reported concentrations of TRS should be 

corrected to 8% O2 for recovery furnaces and 10% O2 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 averages. 

Opacity. This worksheet is designed for recovery furnaces or lime kilns equipped with COMS but may be 

used for thermal oxidizers and other equipment. Respondents are requested to specify the Emission Unit ID 

(or Collection system ID) and the APCD_ID, and report the 6-minute average opacity for CY2009 

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 highest single 6-minute average opacity recorded 

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

malfunction conditions. 

Other pollutants (such as NOx, SO2, CO, total HAP, methanol, total chlorinated HAP, chlorine, 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 Collection system ID) and the APCD_ID (or type of combustion controls used), and report the 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 malfunction 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 or COMS when evaluating monitoring options. 

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

It is very helpful for EPA’s data analysis purposes if data are entered into the P&P CEMS_PI.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 that, 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 not 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 operating hours in a 

day to estimate hourly production). 

D4. Optional cost data 

The EPA requests information related to the capital and operating costs of selected air pollution controls or 

process/equipment changes. Providing this cost 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 mills 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_PI.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_PI.xls” spreadsheet contains a red block at the top of each tab where you 

can indicate if the tab contains CBI, or if the entire tab should be treated as CBI. Responses containing CBI should 

be submitted according to the instructions in section C2 of this document. 

Any cost information that you provide would be very useful to EPA for purposes of evaluating the costs 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 is requested (e.g., costs dating back to 1998). The cost information could come from vendor 

quotes for APCD or equipment changes that either have been implemented or were explored but not implemented. 

For Part I, the EPA is particularly interested in costs of the following APCDs. Please supply this information using 

the APCD costs tab: 

 - Paper machine HAP control devices 

 - Controls that reduce HAP emissions from wastewater handling and treatment systems 

 - Bleach plant CO control devices 

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. 

 - Process changes that reduce HAP emissions from wastewater handling and treatment systems 

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

 - Process changes that reduce paper machine HAP emissions 

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 an attachment to your response) if 

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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 that 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 not be required for other mills). 

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PART I - ATTACHMENT 1 

Emission Units to Include in the Part I Pulp and Paper Survey Response 

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

of the emission units listed below. Only include equipment operated at your mill. The purpose of the detailed list 

below is to ensure all emission points are represented. You may aggregate the equipment listed below into larger 

systems as appropriate in your survey response (e.g., you may list “bleaching stage 1” as an emission unit instead of 

every pump, tank, and hood vent within bleaching stage 1 as long as “bleaching stage 1” represents all of the 

emission points associated with that system). [Note: Chemical recovery combustion units are included in Part III.] 

Causticizing Equipment

Green liquor clarifier 

Green liquor storage tank 

Green liquor surge tank 

Slaker 

Causticizers 

White liquor clarifier 

White liquor storage tank 

White liquor pressure filter tank 

White liquor/weak wash pressure filter 

Weak wash storage tank 

Dregs washer 

Dregs filter exhaust 

Lime mud washer 

Lime mud filter system 

Digester Area Equipment

Digester 

Chip bin 

Chip steaming vessel 

Flash tank 

Blow tank 

Condenser 

Turpentine decanter 

Pulp Washing, Thickening, and Storage Equipment

Brown stock washers 

Hoods 

Filtrate tanks 

Vacuum pumps 

Screens 

Knotters 

Decker 

Stock chests (including open stock chests) 

Pulp storage tanks 

Thickeners 

Evaporators 

Black liquor storage tanks 

Evaporator hot wells 

Condensers 

Boilout tanks 

Soap storage tanks 

Soap skimmer tanks 

Other emission points associated with evaporators. 

Oxygen Delignification Equipment

Oxygen delignification reactor 

Oxygen delignification blow tank 

Oxygen delignification washer 

Post-oxygen washer filtrate tank 

Pulp storage tanks 

Other oxygen delignification system emission points. 

Non-condensable Gas (NCG) Collection

LVHC system 

HVLC system 

Stripper System Equipment 

Stripper feed tanks 

Condensers 

Heat exchangers 

Methanol Rectification Equipment

Rectifiers 

Condensers 

Decanters 

Storage tanks 

Storage Tanks

Weak liquor storage tanks 

Strong liquor storage tanks 

Liquor storage ponds 

Acid condensate storage tanks (at sulfite mills) 
Part I Form Approved 02/17/2011 

OMB Control No. 2060-0656 

Approval Expires 02/28/2014 

Tall Oil Production Equipment

Tall oil acidulation reactor 

Storage tank 

Dehydrator 

Brine storage tank 

Screen 

Centrifuge tank 

Other tall oil production vents 

Bleaching Equipment 

Tower vents 

Washer hoods 

Seal tank vents 

Chemical and steam mixers 

Vacuum pumps 

Mechanical Pulping Equipment

Stone grinder 

Refiner 

Chip pre-steaming vessel 

Chip cooker 

Screen 

Decker 

Brightening/bleaching tower 

Non-wood Pulping Equipment

Secondary Fiber Pulping Equipment

Paper Making Equipment

Paper machines 

Pulp dryers 

Machine chest 

Repulpers 

Stock blending and storage tanks 

Broke tanks 

Savealls 

White water storage tanks

Wastewater Treatment System Units

Clarifiers 

Settling ponds 

Aerated stabilization basins 

Activated sludge systems 

UNOX systems 

Wastewater tanks 

Other wastewater handling and treatment units 

Power Boilers – PI Equip detail tab only

Thermal Oxidizers/Incinerators controlling Part I 

emission sources

Woodyard Operations

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PART I - ATTACHMENT 2 

Small Business Size Standards 

Small Business Size Standards for NAICS Subsector 322 – Paper Manufacturing 

NAICS 

Codes

NAICS U.S. industry title Size 

standards in 

number of 

employees

322110 Pulp Mills 750 

322121 Paper (except Newsprint) Mills 750 

322122 Newsprint Mills 750 

322130 Paperboard Mills 750 

322211 Corrugated and Solid Fiber Box Manufacturing 500 

322212 Folding Paperboard Box Manufacturing 750 

322213 Setup Paperboard Box Manufacturing 500 

322214 Fiber Can, Tube, Drum, and Similar Products Manufacturing 500 

322215 Non-Folding Sanitary Food Container Manufacturing 750 

322221 Coated and Laminated Packaging Paper Manufacturing 500 

322222 Coated and Laminated Paper Manufacturing 500 

322223 Coated Paper Bag and Pouch Manufacturing 500 

322224 Uncoated Paper and Multiwall Bag Manufacturing 500 

322225 Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses 500 

322226 Surface-Coated Paperboard Manufacturing 500 

322231 Die-Cut Paper and Paperboard Office Supplies Manufacturing 500 

322232 Envelope Manufacturing 500 

322233 Stationery, Tablet, and Related Product Manufacturing 500 

322291 Sanitary Paper Product Manufacturing 500 

322299 All Other Converted Paper Product Manufacturing 500 

Source: U. S. Small Business Administration Table of Small Business Size Standards Matched to North American 

Industry Classification System Codes, Effective August 22, 2008. Accessed June 16, 2009 at: 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf 

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PART I - ATTACHMENT 3 

Part I Emissions 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 I 

Part I - Attachment 3. Pulp and Paper Emission Units and Pollutants for Which Existing Representative Emissio

Note: Emissions test data representative of your current operations are requested as described in the survey instructions. Mills required to complete P

for Part III submittal of emissions test data and CEMS data required for the emission units listed in Part I Attachment 1 for the following pollutants: 

Emission Unit Particulate 

matter (PM)1

Speciated HAP 

metals2

PM2.5 

(fil.) 

PM2.5 

(cond.) 

Chlorinated 

HAP (Cl)1

Acetaldehyde, 

Formaldehyde, 

and Methanol1

Total 

hydrocarbon 

(THC) as 

carbon 

Total reduced 

sulfur (TRS)1,3

Test methods4 M5, M29, 

M17 

PM CEMS, 

COMS 

M29 EPA 

OTM 27 

EPA 

OTM 28 

Chlorine (Cl2) via 

M26A with 

modifications 

described in 

subpart S 

Cl2 CEMS 

Methanol: Method 

308 (part 63) or 

Methanol CEMS 

Other methods 

(e.g., for 

acetaldehyde & 

formaldehyde) 

M25 or M25A M16 

(or variants 

such as 16A, 

16B, 16C) or 

TRS CEMS 

Provide total 

TRS data. Also 

provide 

speciated TRS 

data, if 

available. 

Thermal oxidizers 

controlling Part I 

emission sources 

Supply most 

recent data Not requested 

Digesters, Pulp 

washers, 

Evaporators, 

Turpentine recovery, 

Strippers, O2

delignification, 

Knotters and 

screens, Deckers 

(high density 

storage), and Weak 

and strong liquor 

storage tanks (or 

their associated 

LVHC and/or HVLC 

collection systems) 

Not requested 

Supply most recent 

data following 

MACT compliance 

Supply most 

recent data 

following 

MACT 

compliance 

Sulfite pulping 

sources Not requested 

Supply most recent 

data following 

MACT compliance 

32
Part I 

33

Emission Unit Particulate 

matter (PM)1

Speciated HAP 

metals2

PM2.5 

(fil.) 

PM2.5 

(cond.) 

Chlorinated 

HAP (Cl)1

Acetaldehyde, 

Formaldehyde, 

and Methanol1

Total 

hydrocarbon 

(THC) as 

carbon 

Total reduced 

sulfur (TRS)1,3

Wastewater 

treatment systems Not requested 

Supply most recent 

modeling or 

measurement data 

(as requested in 

WW tab) 

Supply most 

recent modeling 

or measurement 

data (as 

requested in 

WW tab) 

Bleaching systems 

subject to subpart S Not requested 

Supply most 

recent data 

following MACT 

compliance 

Paper machine 

emission points Not requested Supply most recent data 

Causticizing area 

sources Not requested Supply most recent data 

Stand alone 

semichemical, 

mechanical, 

nonwood, and 

secondary fiber 

pulping 

Not requested Supply most recent data 

1 If your emission unit is equipped with a continuous emissions monitoring system (CEMS) or continuous opacity monitoring system (COMS), supply the CEMS and 

spreadsheet (P&P CEMS_PI.xls). Synthetic area sources should supply the most recent data (if data are available). 

2 The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chromium VI (Cr+6) a

available. 

3 Speciated TRS would include: hydrogen sulfide (H2S), 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 i

methods can be found at http://www.epa.gov/ttn/emc/prelim.html 
Part II Form Approved 02/17/2011 

OMB Control No. 2060-0656 

Approval Expires 02/28/2014 

Pulp and Paper Sector Survey 

Instructions for Part II: NEI Update 

2/4/11 

This document provides instructions for completing Part II of the pulp and paper sector survey. This document is 

organized as follows: 

A. Part II Introduction .......................................................................................................................................... 2

B. How to Submit Your NEI Update ................................................................................................................... 3

C. How to Complete the NEI Update ................................................................................................................... 4

C1. Updating pre-populated NEI data ................................................................................................... 12

C2. Completing the NEI update if not pre-populated by EPA ............................................................... 15

PART II - ATTACHMENT 1 Emission Units to Include in the NEI Update

PART II - ATTACHMENT 2 Resources for Estimating Emissions

PART II - ATTACHMENT 3 Instructions for Accessing the Pulp and Paper NEI Update FTP Site

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A. Part II Introduction 

Part II of the pulp and paper sector information request applies for pulp and/or paper/paperboard mills that are a 

major source of hazardous air pollutant (HAP) emissions that: 

(a) Perform chemical wood pulping (kraft, sulfite, soda, or semi-chemical), 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. 

Synthetic area source mills are not required to complete Part II of the pulp and paper sector survey. 

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 quantity, 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 complete the form in Attachment 1 of the Survey Overview document and email (or fax) 

it to Bill Schrock at the U.S. Environmental Protection Agency (EPA) (contact information is provided on the form). 

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. 

You are required to complete Part II of the pulp and paper sector survey unless: (1) you meet one of the three criteria 

listed above for exemption from the survey; or (2) your mill is a synthetic area source for HAP emissions. 

Please complete the survey for the facility listed in the Section 114 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, they can be downloaded here: 

https://icr2010.rti.org/Industries/PulpPaper.aspx

Use the 2009 calendar year as the base year for your National Emissions Inventory (NEI) update, except as 

described in section C1 for those mills that already recently provided NEI updates to EPA.

Part II of this survey asks questions about the emission units listed in Attachment 1 to this document. All of the 

emission units included in both Parts I and III of the pulp and paper sector survey are listed in Attachment 1 for 

inclusion in your Part II NEI update. Section C of this document, How to Complete the NEI Update, explains how 

to treat various configurations of emission units. Attachment 2 to this document identifies resources that might be 

useful for estimating emissions for your NEI update. For convenience, a spreadsheet file entitled Lookups for P&P 

survey.xls accompanies Part II of the survey. This spreadsheet file consolidates and provides the various codes 

associated with the NEI data set you are requested to update. 

 

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 

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and paper processing NESHAP (40 CFR Part 63, subpart S), and selected definitions from 

the NSPS and NESHAP General Provisions. 

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

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 

intent 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.

B. How to Submit Your NEI Update 

Submit your NEI update on or before the date specified in the section 114 letter accompanying these instructions. 

After you have completed and reviewed your NEI update, sign and date the certification form in Attachment 4 of the 

Survey Overview document. Save your NEI update file as “P&P NEI update_______.xls” or “P&P NEI 

blank________.xls” where the blank is your NEI Site ID number (so your file will be submitted to EPA with a 

unique filename that identifies your facility). Then, transmit your certification form and NEI update file to EPA 

using one of the following methods: 

(1) Email it to: ppsurvey@rti.org

(2) Post it to the pulp and paper survey FTP site (https://ftp.rti.org/) using the password and detailed the instructions 

provided in Attachment 3 of this document. 

(3) Save it on a CD or DVD and mail it to: 

U.S. Environmental Protection Agency 

 Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (E143-03) 

Attn: Mr. Bill Schrock 

109 TW Alexander Drive 

 Research Triangle Park, NC 27711 

If you mail your certification form and NEI update, EPA recommends using Registered U.S. Mail with return 

receipt requested, Federal Express, or other method for which someone must provide a signature upon receipt. 

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C. How to Complete the NEI Update

The U.S. EPA is working to fulfill its obligation under Clean Air Act (CAA) sections 112(f)(2) and 112(d)(6) to 

review residual risk and perform a technology review of the pulp and paper industry NESHAP subparts S and MM. 

Data sets derived from the EPA’s 2005 National Scale Air Toxics Assessment (NATA) National Emissions 

Inventory (NEI) will be used for EPA’s residual risk and technology review (RTR). The RTR data sets have been 

developed for mills in the 2005 NATA NEI identified as having emission units with the following NEI maximum 

achievable control technology (MACT) codes: 

1626-1 Pulp & Paper Production - Pulping and Bleaching Systems at Kraft, Soda, Sulfite, and 

Semichemical Pulping Mills (Subpart S) and Papermaking Systems at all mills. 

1626-2 Pulp & Paper Production - Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, 

and Stand-alone Semichemical Pulping Mills (Subpart MM) 

1626-3 Pulp and Paper Production - NonMACT Facilities 

The 2005 NATA NEI data sets were compiled based on prior versions of the NEI, updated with data collected by 

EPA’s Office of Air Quality Planning and Standards.1

 Many pulp and paper mills have voluntarily updated their 

NEI data sets for RTR purposes, and few additional refinements are needed for those mills. However, there remain 

a number of pulp and paper mills for which substantial updates to their NEI data sets are requested in order for EPA 

to more accurately conduct RTR for the pulp and paper NESHAP standards. In addition, there may be some mills 

for which no prior pulp and paper MACT category NEI data are available. 

If 2005 NATA NEI data exist for your mill, then the two spreadsheet tabs in P&P NEI update.xls (Facility tab and 

Inventory tab) have been pre-populated with your mill’s NEI data set. You will need to review and revise the NEI 

data in these two tabs as necessary following the instructions provided below in section C1 for “Updating prepopulated NEI data.” 

If NEI data do not already exist for your major source mill, then you will need to provide a full NEI update using the 

P&P NEI blank.xls spreadsheet file (New Facility and New Inventory tabs). See the instructions in section C2 below 

for “Completing the NEI update if not pre-populated by EPA.” 

General instructions that apply to your NEI update regardless of whether you are asked to revise pre-populated NEI 

data (in P&P NEI update.xls), or supply new NEI data (in P&P NEI blank.xls) are provided in the paragraphs below. 

Additional specific instructions are provided in sections C1 and C2 (where needed). “Instruction” rows are provided 

in the NEI update spreadsheets. 

Emission units and MACT codes to include in your NEI update. Part II of this survey asks questions about the 

emission units listed in Attachment 1 to this document. Attachment 1 lists all of the emission units included in both 

Parts I and III of the pulp and paper sector survey that should also be included in your Part II NEI update. Updates 

to the list of emission units, descriptions, and SCC codes in your NEI update would improve the accuracy and 

completeness of the NEI data for use in EPA’s HAP residual risk efforts. Updated information will allow EPA to 

focus residual risk regulatory analyses on the specific types of emission units with questionable risk. 

Regardless of whether you are updating a pre-populated data set or providing new inventory information, you must 

review and supply, at a minimum, HAP emissions inventory data for emission units falling within the three pulp and 

paper MACT source categories (MACT codes 1626-1, 1626-2, and 1626-3). Note that in some cases, certain 

emission units may fall within a MACT source category but not have any applicable MACT requirements. The pulp 

and paper MACT codes applicable to the emission units in Attachment 1 of this document have been identified to 

assist you with determining the appropriate MACT code to use in your NEI update (see Attachment 1). Additional 

 

1

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MACT codes for equipment outside of the pulp and paper MACT source categories are included in the spreadsheet 

entitled Lookups for P&P survey.xls (MACT Codes tab). 

Pollutants to include in your NEI update. The NEI currently includes both HAP and criteria air pollutant (CAP) 

emissions data. Criteria air pollutants include particulate matter (PM), sulfur dioxide (SO2), nitrogen oxides (NOx), 

carbon monoxide (CO), and volatile organic compounds (VOC). Total reduced sulfur (TRS) emissions generally 

have not been included in the NEI to date. 

The NEI data solicited through this pulp and paper survey will be used by EPA for NESHAP RTR purposes. 

Therefore, at a minimum, you must review and supply HAP emissions data in your NEI update. 

Although we are focused on HAP for RTR purposes, EPA would also like to receive any voluntary updates to CAP 

data and any new TRS emissions data that you wish to provide. Updated CAP and TRS data would be used in 

determining the magnitude of emissions for purposes of reviewing the subpart BB NSPS for kraft pulp mills. 

Updates to the CAP data and inclusion of TRS data in your NEI update are optional. However, should you 

substantially revise the configuration of emission units in your pre-populated NEI for purposes of updating HAP 

emissions, you are strongly encouraged to update the corresponding CAP emissions as well. 

Base year for your NEI update. Use the 2009 calendar year as the base year for your NEI update, except as 

described in section C1 for those mills that have already recently provided NEI updates to EPA for RTR purposes. 

Emission Unit ID. Emission units must be identified with an Emission Unit ID in your NEI update. To the extent 

possible, this same Emission Unit ID should also be used throughout all parts of this pulp and paper survey (Part I, 

Part II, and Part III). 

Also, please be sure that no extra spaces or characters are included in the ID cells. For example, 

Emission Unit ID “DIG1” is not read the same as “DIG-1” or “DIG-1_” by data base software. 

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 functional and 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 consistent 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. 

A Note About Identification Numbers (IDs) 

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Emission Release Point ID. There may be one or more emission release points for a given Emission Unit ID. 

Methods for including various configurations of emission units and release points are discussed in the paragraphs 

below. For each Emission Unit ID and Emission Release Point ID, you will specify emission rates for each 

pollutant, emission release parameters (e.g., stack gas parameters or fugitive release parameters), and 

longitude/latitude coordinates. 

Multiple emission units ducted to a single release point. It is very common for multiple emission units (or 

for multiple emission points from a single emission unit) to be ducted to a common conveyance for 

purposes of emissions capture and control. The NEI provides parameters associated with releases to the 

atmosphere (e.g., tpy emitted, stack parameters) so it is acceptable to include each common emission 

release point in the NEI (rather than listing each emission unit ducted to the common release point 

separately). For example, an LVHC collection system may collect emissions from multiple emission points 

associated with digesters 1, 2, and 3 and an evaporator. You could either list digesters 1, 2, and 3 and the 

evaporator separately in the NEI (and provide data for each associated emission point), or you could 

simply list the LVHC collection system emission point in the NEI. 

A similar approach can be taken for reporting emissions from two distinct emission units that are vented 

through a common stack for purposes other than capture and control. In this scenario, you could apportion 

the emissions to each process and insert a separate row or rows for each distinct process. Identify and enter 

the SCC code associated with each emission unit and note the appropriate stack parameters on each row. 

Note the common stack in the "Emission Unit Description2

” column. For example, indicate the following 

where 2 recovery furnaces share a common release point: Row 1 – emission unit ID 001 (EU001) No. 1 

Recovery Furnace vents to emission release point ID 01 (ERP01) and indicate in the “Emission Unit 

Description” column “No. 1 Recovery Furnace shares common stack with No. 2 Recovery Furnace.” On 

Row 2 – emission unit ID 002 (EU002) No. 2 Recovery Furnace vents to emission release point ID 01 

(ERP01) and indicate in the “Emission Unit Description” column “No. 2 Recovery Furnace shares 

common stack with No. 1 Recovery Furnace.” 

Single emission unit with multiple emission release points. Pulp and paper emission units may 

have multiple emission points (e.g., paper machines, digester blow gases and relief gases, boilers 

with two stacks) that for various reasons may not be consolidated into a single emission point 

before release to the atmosphere. In these situations, the emission unit should be repeated in the 

NEI and emissions data and stack parameters provided for every emission point to the extent that 

emission rates and emission release parameters (e.g., exit gas velocity) can reasonably be specified 

for each emission point. You may use the “Emission Unit Description2

” column to distinguish 

among emission points for each emission unit. An accurate representation of vent configurations 

will lead to more representative risk modeling results. For example, depicting all emissions as 

exiting from one vent on an emission unit with multiple vents will provide different (usually 

higher) risk modeling results than would adding additional vent details that show more accurately 

how the emissions are dispersed. 

Paper machine example: Paper machines have many vents, but most emission factors for paper 

machines do not distinguish among vents. There are multiple ways of including paper machine 

emissions in the NEI: 

(1) You may report the paper machine as a single emission point. 

(2) You may group vents together (e.g., wet end vents and dry end vents) and specify an 

emission rate (based on measurements, or engineering judgment and emission factors) and 

release parameters, 

(3) If there are numerous vents along the roof, then you may wish to depict the paper machine 

as a fugitive emission source (where you would specify the height, length, and width of the 

 

2

 For pre-populated NEI inventories, you would use the "REVISED Emission Unit Description” column for updates. 

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roof area over which the vents appear as described below). With this option, the Emission 

Release Point Type Code = 01. 

(4) You may list every single vent (provided that you can specify/estimate an emission rate and 

emission release parameters for each vent). 

Note that if you do not specify emission release parameters (such as stack height, exit temperature, 

exit gas velocity) then default release parameters will be assigned to the emission point. Under 

options 1, 2, and 4 above, you would specify a point source Emission Release Point Type Code 

(i.e., other than “01” which applies to fugitive releases). Industry default point source release 

parameters that will be assigned for paper machine vents (unless you specify site-specific 

parameters) are as follows: 

Stack height: 70 ft 

Exit Gas Temperature: 125 o

F 

Stack Diameter: 4.6 ft 

Exit Gas Velocity: 30 ft/sec 

Under option 3, conservative NEI default fugitive release parameters will be assigned if you do 

not specify the release parameters (see “Default fugitive release parameters” below). We 

recommend that you, at a minimum, specify the height of paper machine releases (for example, the 

paper machine building height), along with the paper machine building dimensions (or potion of 

the building where the releases occur) for the as fugitive length and width. 

Wastewater emissions. Open wastewater treatment systems (aerated stabilization basins, clarifiers, etc.) are 

best classified as fugitive sources (Emission Release Point Type = 01) for which area source parameters 

(fugitive length, width, and angle) are estimated. See below for more information on specifying fugitive 

emission release parameters, defaults, and latitude/longitude coordinates. 

 

Emission units vented into the building. Do not include emissions units that vent into the building in your 

NEI update unless these emission units are permitted units in your Title V permit. For example, if your 

paper machine vents into the building housing the machine and the emission limits contained in your 

permit are applicable to the building vents, then you would include the paper machine building vents in 

your inventory.

Bypass stacks used only during certain times. If your facility operates an emission unit with a bypass stack 

that allows for emissions to bypass the control system, then you can indicate the emissions associated with 

use of the bypass stacks by entering the appropriate data in a new row (see instructions for “adding a row” 

in section C1 below). If you enter data for bypass stacks, please indicate these emissions as “bypass” 

emissions in the “Emission Unit Description2

” column. Please also indicate in the “Emission Unit 

Description2

” column the release point associated with “normal” operations. 

 

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Emission Release Point Type. In the NEI, each emission release point is characterized by an emissions release 

point type code that you will either assign or revise. Emission release point type code 1 applies for fugitive emission 

sources, while other emission release point type codes (2 through 6) apply for point source (e.g., stack) releases. 

The following emission release parameters apply for fugitive and point source emission releases: 

Emission Release Point Type3 Applicable NEI emission release parameter columns 

Fugitive Multiple emission rate columns 

(code = 1) Stack height (ft) 

Fugitive Length (E-W) (ft) 

Fugitive Width (N-S) (ft) 

Fugitive Angle (degrees) 

Latitude and Longitude columns 

Point Multiple emission rate columns 

(code = 2, 3, 4, 5, 6, or 99) Stack height (ft) 

Exit Gas Temperature (f) 

Stack Diameter (ft) 

Exit Gas Velocity (ft/sec) 

Exit Gas Flow rate (cuft/sec) 

Latitude and Longitude columns 

Note that the emission rate columns, stack height, and latitude and longitude columns are the same for fugitive and 

point sources. These parameters are discussed further in the paragraphs below. 

A Note About Emission Release Parameters 

Please pay particular attention when entering emission release point stack parameters and locations 

(latitude/longitude). These data are critical inputs to the modeling files that EPA will use to determine 

the risk profile for the residual risk review process. 

Default fugitive release parameters. Certain NEI defaults are applied for fugitive releases (Emission Release 

Point Type Code = 01). You may specify the release height (between 0.1 and 100 ft). In the NEI, fugitive releases 

over 100 ft are considered invalid and will be set to the default height of 10 ft. Similarly, the default will be 10 ft if 

you do not specify a height for fugitive releases. In addition to height, you may specify the fugitive length, width, 

and angle (or these column will remain zero - indicating essentially no dispersion). The exit gas temperature default 

is set to ambient (72o

F) unless you specify a different temperature. 

Certain NEI defaults for fugitive releases are set and cannot be changed. The defaults for stack diameter (0.003 ft), 

velocity (0.0003 ft/sec), and flow (0 cu ft/sec) are set to indicate essentially no flow. 

You should consider this information pertaining to default fugitive parameters as you select the Emission Release 

Point Type Code = 01 for fugitive emission sources. When selecting Emission Release Point Type Code = 01, you 

are strongly encouraged to provide the actual release height and fugitive dimensions (particularly length and width) 

because these parameters will result in more accurate dispersion estimates when risk modeling if performed. 

Emission rates (TPY and lb/hr). The “Routine Emissions (TPY)” column should reflect ACTUAL routine 

emissions measured or estimated for the reported calendar year. Routine emissions reflect emissions exiting the air 

 

3

 The Emission Release Point Type codes are: 1 – Fugitive; 2 – Vertical; 3 – Horizontal; 4 - Goose Neck; 5 - 

Vertical with Rain Cap; 6 - Downward-facing Vent; 99 - Unknown 

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pollution control system (for emission units with air pollution controls). The “Routine Emissions Max hourly rate 

(lbs per hour)” column should reflect the ACTUAL maximum hourly (lb/hr) emission rate measured or estimated 

for the reported calendar year. In addition to the routine emissions, columns are included for startup and shutdown 

emissions (tpy and max hourly rate in lb/hr), if available. 

Both the TPY and lb/hr data columns are requested because EPA is modeling both short- and long-term risks. 

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

determining an average hourly emission rate for the year (e.g., tpy divided by operating hours) for purposes of risk 

modeling. Short-term risks would be based on the maximum hourly emission rate(s) (e.g., lb/hr data). 

For routine emissions, the average hourly emission rate (e.g., tpy divided by operating hours) can differ from the 

maximum hourly emission rate due to fluctuations in production rates or other changes in other routine operating 

conditions. In the absence of site- or process-specific information, it has been EPA’s practice to conservatively 

assume that maximum hourly emissions are 10 times the routine hourly emissions for purposes of acute risk 

modeling. EPA would prefer to have site-specific emissions measurements or estimates (such as applicable lb/hr 

permit limits where available) than to apply this default factor-of-10 approach. If these data are unavailable and are 

not provided in the “Routine Emissions Max hourly rate (lbs per hour)” column, then EPA will apply a default 

approach (e.g., the factor-of-10 or similar approach derived for 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). We understand that emissions may 

differ (e.g., be higher or lower than routine emissions) during periods of startup/shutdown, and that mills are 

unlikely to have measured emissions during startup/shutdown. Responses to the startup/shutdown emission rate 

questions are OPTIONAL but are requested from mills that may have previously measured (e.g., with CEMS) or 

estimated such emissions. 

Stack height and fugitive release height. Although labeled “Stack height (ft),” this column applies more 

generically as the release height for either stack or fugitive emission sources. Therefore, you should specify “stack” 

heights for emission sources that vent though stacks, or the fugitive release height for fugitive emission sources. 

Generally, the higher the stack or fugitive release height, the greater the dispersion of air emissions, which in turn 

leads to reduced risk to the surrounding population. The EPA will specify conservative default release height 

parameters if you do not supply this information. 

Latitude/longitude coordinates. In your NEI update, you are asked to provide (or revise) the latitude/longitude for 

each emission release point. The latitude/longitude coordinates should correspond with the actual location of each 

emission point (e.g., the location of each stack–not the general street address of the mill). For point sources, 

latitude/longitude is specified at the center of the emission source. For fugitive sources, latitude/longitude is 

specified at the southwest corner of the emission source if the fugitive angle (defined below) is zero or the western 

most corner if the fugitive angle is greater than zero. EPA requires latitude/longitude for each emission point 

provided in North American Datum (NAD) 83 with 6 digits to the right of the decimal point. 4

 

 

4

Latitude is a measure in decimal degrees of the angular distance on a meridian north or south of the equator. 

Latitude is a positive (+) data point for North America (Example: +78.123456). Longitude is a measure in decimal 

degrees of the angular distance on a meridian east or west of the prime meridian. Longitude is a negative (-) data 

point for North America (Example: -123.234561). For point sources this represents the center of the source; for 

fugitive sources, this is the southwest corner if the fugitive angle is zero, or the western most corner if the fugitive 

angle is greater than zero. 

 

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Fugitive emission release parameters. Quantified sources of fugitive emissions are to be included in your NEI 

update (e.g., fugitive emissions from wastewater handling/treatment units that have been modeled for permitting 

purposes). Fugitive emission release parameters are to be provided in the “Emission Release Point Type” column 

and other columns related to the fugitive length, width, and angle of the fugitive emissions. Examples of the fugitive 

length, width, and angle are below: 

The latitude and longitude for fugitive emission units are depicted in the figures above. The fugitive angle is 

relative to the north-south (y-) direction (commonly referred to as width) of the emission unit as depicted in the 

figures above. For example, an angle of zero means the building width is oriented N-S and an angle of 90° means 

the width is oriented E-W. When the fugitive angle is zero, the latitude/ longitude coordinates are specified at the 

southwest corner of the fugitive emission unit. If the fugitive angle is greater than zero, then the coordinates are 

specified at the western most corner of the emission unit. 

Exit gas temperature, velocity, and flow rate. For point sources (e.g., stacks or vents), you are asked to provide 

typical or representative values for the exit gas temperature, exit gas velocity, and exit gas flow rate based on 

information you have in hand. For example, if you have a one-time measurement of these parameters (e.g., from a 

stack test), then you could use that measurement. If you have continuous monitoring data, then you may choose to 

use the annual average for the parameter. If you have periodic monitoring data (e.g., quarterly data), then you could 

average the quarterly data for the year. The exit gas temperature, velocity, and flow rate influence dispersion of air 

emissions and the risk modeling results (e.g., higher temperatures and velocity/flow rates lead to greater dispersion, 

which in turn leads to reduced risk to the surrounding population). If you do not supply this information, then EPA 

will specify conservative default parameters. Please ensure that you specify positive, non-zero temperatures for 

your emission releases. Ambient temperature is considered to be 72o

F in the NEI. 

Emission Unit Description. Every emission unit listed in your NEI inventory should have an informative 

“Emission Unit Description” that adequately describes the equipment or type of emission unit. You may find it 

helpful if the Emission Unit Description column relates your emission unit/process to your permit or process flow 

diagram. Your “Emission Unit Description” will be used as a check for SCC code assignment. 

SCC and other NEI codes (Lookups for P&P survey.xls). For convenience, the spreadsheet entitled Lookups for 

P&P survey.xls consolidates and provides the various codes associated with the NEI data set you are requested to 

update. These codes were extracted from the NEI data base lookup tables at 

http://www.epa.gov/ttn/chief/net/2005inventory.html. 

This Lookups for P&P survey.xls spreadsheet contains source classification codes (SCCs). The SCCs in the NEI 

will be used by EPA to group similar emission units and draw conclusions regarding the emission levels and 

residual risk associated with each type of emission unit. Proper assignment of SCCs will allow EPA to pinpoint 

emission unit types that need to be examined in more detail for residual risk rulemaking. The SCC codes for pulp 

and paper manufacturing were updated in late 2009 to include more descriptive codes and to provide some guidance 

W=4 ft 

Latitude/longitude 

specified at SW corner 

(when fugitive angle = 0) 

L=10 ft 

Angle = 0 W=4 ft 

L=10 ft 

Latitude/longitude 

specified at western most 

corner (when fugitive 

angle > 0) 

Angle = 45 degrees 

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on which codes should be used for certain equipment types. The process of revising the SCC list in 2009 involved 

both the addition and the removal of pulp and paper-related SCCs. 

For example, the SCC list previously included the SCC: 30700118 Sulfate (Kraft) Pulping / Liquor 

Clarifiers. This SCC is now obsolete and has been replaced with the more specific SCCs: 30700132 

Sulfate (Kraft) Pulping / Green Liquor Processing and 30700133 Sulfate (Kraft) Pulping / White Liquor 

Processing. Please use the most appropriate SCC from the provided lookup table. 

A crosswalk of the available SCC codes with the types of equipment listed in Attachment 1 is included in the P&P 

Att1 with SCC tab of Lookups for P&P survey.xls. The full list of SCC codes used for EPA’s Emissions Inventory 

System (EIS)/NEI is included in the All 11575 SCC tab of Lookups for P&P survey.xls (and is also available in data 

base form at http://www.epa.gov/ttn/chief/net/2005inventory.html). 

Revised SCCs are available for common collection systems (e.g., LVHC, HVLC) and for various systems that are 

commonly comprised of multiple emission points (e.g., 30700114 for bleach plants includes emissions from the 

bleaching towers, washer hoods, filtrate tanks, and vacuum pump exhausts). 

Use the SCC that best describes your process and avoid using generic not-elsewhere-classified (NEC) SCCs 

whenever possible. Please make every attempt to use SCCs specific to the pulp and paper sector (e.g., use SCC 

30700106 for pulp and paper lime kilns as opposed to SCC 30501619 for the lime manufacturing sector). If you do 

not find an SCC that matches your emission unit, then be sure to include an accurate “Emission Unit Description”.

Please do not use generic NEC SCCs unless you absolutely cannot find a specific SCC that resembles your emission 

unit. A detailed “Emission Unit Description” is required if you choose a NEC SCC. 

Updates (i.e., both additions and deletions) may have been made to some of the other NEI code lookup tables (other 

than SCCs). Codes that are being phased out are shaded green in some of the lookup tables (along with a note in the 

lookup table explaining how to treat the green-shaded codes in your inventory update). If a code that you have used 

in the past no longer appears in the appropriate lookup table, please select the most appropriate code from those 

listed. You may clarify your entry by adding text in the “Comment – Process” column. 

Dioxin/furan data. Some pulp and paper mills have included dioxin/furan data in their TRI inventories. These TRI 

estimates have been imported into the NEI data set for many mills. However, TRI does not require mills to specify 

an SCC code so the dioxin/furan data are assigned a generic pulp and paper not-elsewhere-classified SCC when 

imported from TRI into the NEI. We expect that the dioxin/furan estimates entered by mills into TRI are associated 

with combustion sources (such as power boilers or pulp mill chemical recovery furnaces), but clarification of the 

source type is needed in order for EPA to apportion the dioxin/furan data to the proper MACT source category for 

risk assessment. Please be sure to review and revise (if needed) the SCC and MACT code assignments for any 

dioxin/furan data in your pre-populated NEI. Please also review the data source associated with the dioxin/furan 

data because data may have been submitted from multiple sources (which could lead to double-counting). 

Control measures. For EPA to better understand current control measures that are in operation, we are requesting 

that you indicate the type of control measure associated with each emission unit. A list of control measure codes and 

control measure descriptions is provided in Lookups for P&P survey.xls. If you do not provide control measure 

information in your update, the emission unit will be considered uncontrolled. 

Alternate controls. Some facilities may have alternate or backup control system configurations that provide 

flexible operating scenarios. For example, LVHC system gases may normally be collected and burned in a lime 

kiln, but if the lime kiln that controls these emissions is shut down, the facility has the flexibility to send these same 

collected LVHC gases to a power boiler. For this type of scenario, a facility would indicate in the “Control 

Measure” fields that the lime kiln is the primary control device, but would also note in the “Control Measure 

Comment” field that the power boiler serves as an alternate control. 

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C1. Updating pre-populated NEI data 

You will need to review and revise the NEI data contained in the “Facility” and “Inventory” tabs of the P&P NEI 

update.xls spreadsheet file as necessary. The instructions for updating the pre-populated NEI data in the Facility

and Inventory tabs are provided below and in “Instruction” rows in the spreadsheet. 

NEI data are generally requested for the 2009 calendar year. However, EPA is sensitive to the time and effort 

required to update your NEI inventory. Thus, if you have previously reviewed and revised your NEI data within the 

past 3 years and/or you believe the 2005 NATA NEI data in the pre-populated data set provided by EPA is a 

reasonably complete and accurate representation of your mill configuration and emissions, then you do not need to 

update your NEI data for the sole purpose of changing the emission estimates to reflect the 2009 calendar year. 

However, if you must substantially revise or add to your pre-populated NEI data set to make it complete and 

reflective of the current mill configuration, then it is requested that you use the 2009 calendar year for your 

inventory update. 

You will update one row of data in the Facility tab, and multiple rows of data in the Inventory tab. The Inventory

tab contains separate rows of data for each emission unit, emission point, and pollutant. An “Instruction” row 

appears that the top of each spreadsheet tab to provide a brief instruction for fields requiring some description. 

More detailed instructions appear in this document where needed. When updating the NEI data in the Facility and 

Inventory tabs, please indicate changes only in the unshaded columns. Do not overwrite data in the gray shaded 

columns. Guidance for revising specific blocks of data in the Inventory tab is as follows: 

Gray shaded columns. The gray shaded columns have been locked to prevent information in these columns 

from being overwritten. If you wish to change information in these gray columns, then you will need to 

follow the instructions for adding and deleting a row. Copy the entire row with the locked cells and paste it 

below the existing, pre-populated NEI inventory to add and update it. Then mark the old row for deletion 

by indicating your intent with an "X" in the “Delete” column. 

Adding a row. If you need to add a new emission unit or pollutant that is not currently in the inventory, 

you should scroll to the last row and enter any missing data. You can copy any useful information from 

other inventory rows and state in the "Comment Process" field "Adding new process." For additions, 

information does NOT need to be in a revised field. Specify “RTR09” in the “Data Source Code” column. 

Deleting a row. If you need to delete a row, indicate your intent with an "X" in the “Delete” column and 

indicate your reason for deletion in the “Delete Comment” column. You may wish to delete rows, for 

example, because an emission unit was decommissioned or is now collected as part of the LVHC system; 

or because you cannot identify the source. 

To revise or replace a whole row. Add your new row and delete the old row using the instructions for 

adding and deleting rows above. 

To replace the whole inventory. You may choose to submit a complete NEI replacement. To completely 

replace your NEI data, mark all existing NEI rows for deletion with an "X" in the “Delete” column and note 

“complete inventory replacement” in the “Delete Comment” column. Add your new inventory below the 

NEI data being replaced. 

To indicate that no revisions needed. If you review the data in the Inventory tab and conclude that no 

revisions are needed, then mark all existing NEI rows in the “Is Reviewed With No Changes” column in 

the Inventory tab accordingly. 

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Why can’t I over-write existing data? 

EPA maintains a record of all changes and "matches" existing NEI entries (i.e., those in the 

attached spreadsheet) to new entries (your revisions). So if a line (record) in the 

spreadsheet/database does not match our existing files, both the old and the new records are 

incorporated into the NEI, which can result in double counting. For these reasons, any changes 

must be recorded in one of the unshaded fields and you cannot (successfully) change data 

by over-writing existing data in a field. 

General steps for updating your pre-populated NEI data are as follows: 

STEP 1. Review and update the single row of NEI data in the Facility tab as needed following the instructions 

above and that appear in each column of the spreadsheet. 

STEP 2. Review the pre-populated data in the Inventory tab, and the specific instructions for updating prepopulated data in this document. You may find the following questions helpful for guiding your review: 

• Are all of required emission units included in the inventory? 

• Are the emission unit configurations depicted correctly (e.g., single unit with multiple vents; common 

collection systems and stacks, etc.) 

• Is the Emission Release Point Type specified correctly for each emission unit? 

• Are all of the known pollutants (particularly HAP) that are emitted from each emission unit included in the 

inventory? 

• Considering the inventory year (Start Date and End Date columns), are the emissions of each pollutant 

included in the inventory representative of the 2009 operating year? 

• Is the Emission Unit Description adequately filled in? 

• Is the SCC assignment correct? 

• Are MACT codes properly assigned for each emission unit? 

• Are the stack or fugitive release parameters correct? 

• Are latitude/longitude specified correctly for the location of each emission point? 

• Are the control measures specified correctly? 

• What data do you have for specifying the Routine Emissions Max Hourly Rate (lbs per hour) and for 

populating the startup/shutdown emissions columns? 

• Are there other revisions that need to be made (e.g., SIC or NAICS code, facility name changes, etc)? 

STEP 3. After you have reviewed the NEI data and assessed what changes need to be made, proceed with making 

the changes following the instructions in this document and the instructions that appear in each column of the 

spreadsheet. 

STEP 4. Submit your revised inventory following the instructions in Section B of this document. 

Additional detailed instructions for updating your pre-populated NEI data are provided in the following paragraphs. 

Emission units unrelated to the pulp and paper NESHAP (or NSPS) source categories. Please note that the 

pre-populated NEI data sets contain all emissions data for a facility identified as having any equipment 

belonging to the pulp and paper MACT categories (e.g., equipment with MACT codes 1626-1, 1626-2, or 

1626-3). Some of the emissions may be from processes NOT associated with the pulp and paper MACT 

category. The column labeled “MACT Code” indicates if the HAP pollutant emissions are associated with 

the pulp and paper MACT category or another MACT category at the facility (e.g., MACT code 0107-2 

associated with Industrial/Commercial/Institutional Boilers & Process Heaters – gas.). A full list of MACT 

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codes is included in the spreadsheet file Lookups for P&P survey.xls. Data from MACT categories other 

than the pulp and paper NESHAP categories are shown in the pre-populated spreadsheets to provide a 

complete dataset for the facility and/or help you spot additional processes which should be assigned to the 

pulp and paper MACT category. 

In this survey, we are seeking updates to the equipment used for pulp and paper manufacturing (i.e., 

pulping processes, pulping byproduct recovery, bleaching, papermaking, etc). A list of the types of 

equipment of interest for pulp and paper production is provided in Attachment 1 to this document. We are 

not seeking updates to collocated operations that are not associated with pulp and paper manufacture (e.g., 

a lumber mill, chemical plant, or wood products mill) at this time, but would accept voluntary updates to 

these data since the data could be considered in determining residual risk for the entire facility. 

Emission Unit IDs. General instructions pertaining to Emission Unit IDs are provided above. Existing 

NEI Emission Unit IDs have been provided for you in a gray shaded column of your pre-populated 

inventory. These Emission Unit IDs may have originated from states or other entities that supplied data for 

the NEI. For existing emission units, please use the existing Emission Unit ID whenever possible to avoid 

confusion. You may create new Emission Unit IDs (text limited to 6 characters) for emission units that you 

add in your NEI update. 

“Emission Unit Description” and “REVISED Emission Unit Description” columns. General instructions 

pertaining to Emission Unit Descriptions are provided above. An “Emission Unit Description” column was 

included in prior drafts of the NEI that mills were asked to voluntarily review and update. If no “Emission 

Unit Description” is in the NEI for a given emission unit, then you will need to add one in the “REVISED 

Emission Unit Description” column. If you find that the “Emission Unit Description” in the NEI is not 

informative, then you may revise it using the “REVISED Emission Unit Description” column. 

“SCC” and “REVISED SCC” columns. General instructions pertaining to SCC assignments are provided 

above. In some cases, you may find that your pre-populated NEI data contains multiple SCCs for the same 

emission unit (e.g., a multifuel-fired boiler with separate SCCs indicated for each fuel type). In their NEI 

updates, some States split emission units by fuel type and specify separate SCCs for each fuel type. 

Although this is an option for reporting inventory data, for simplicity, EPA would prefer that you assign the 

single most relevant SCC to the emission unit (e.g., the SCC relating to the predominant fuel) and report 

the emissions rates for the emission unit only once (as opposed to attempting to apportion the emissions 

across different SCCs for different fuel types). You are not required to make revisions to your inventory 

solely to aggregate emissions already apportioned across multiple SCC codes for the same emission unit if 

you believe the emissions are reasonable. However, we suggest that you do not add any new emission 

units with multiple SCCs for each fuel type. 

“Start Date” and “End Date” columns. The “Start Date” and “End Date” columns indicate the dates for 

which NEI data are provided. For example, Start Date = 20020101 and End Date = 20021231 indicates 

that the pre-populated NEI data cover emissions for the 2002 operating year (e.g., from 1-1-2002 until 12-

31-2002). You are asked to specify a “REVISED Start Date” and a “REVISED End Date.” For the 2009 

operating year, this would be REVISED Start Date = 20090101 and REVISED End Date = 20091231. 

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C2. Completing the NEI update if not pre-populated by EPA 

A 2005 NATA NEI data set does not exist for your mill if you did not receive a version of the P&P NEI update.xls 

spreadsheet with pre-populated data in it. There are various reasons why the NEI data set may be unavailable. For 

example, some States have not supplied NEI data for major sources. Also, NEI data may be unavailable for nonmajor sources, or there may be no emission units in your NEI data set that correspond with the pulp and paper 

MACT codes. (Note: If your mill is an area source of HAP emissions, then follow the instructions for notifying 

EPA of your status in section A of this document.) 

If your mill is a major source of HAP emissions, then you will need to develop and supply the NEI data set 

requested in the P&P NEI blank.xls spreadsheet of the pulp and paper sector survey. Useful starting points for 

providing the NEI data set may include your air operating permit or permit application, an inventory of emission 

sources for your mill developed for permitting purposes, or the emission calculations developed for the Toxics 

Release Inventory (TRI) for your mill. Additional resources useful for estimating emissions are listed in Attachment 

2 to this document. The spreadsheet file entitled Lookups for P&P survey.xls provides various codes associated 

with the NEI data (including SCCs). 

General instructions for providing NEI data appear in section C of this document (above). The steps for providing a 

new NEI inventory are as follows: 

STEP 1. Populate the NEI information in the New Facility tab of the P&P NEI blank.xls spreadsheet following the 

instructions in Section C above and that appear in each column of the spreadsheet. You will add a single row of data 

in the New Facility tab. 

NEI Site ID. Use an NEI Site ID of “NEW_____” where the blank is your mill’s zip code, as this will (in 

all likelihood) provide a unique identifier for your mill. 

STEP 2. Populate the NEI information in the New Inventory tab of the P&P NEI blank.xls spreadsheet following 

the instructions in Section C above and that appear in each column of the spreadsheet. You will add multiple rows of 

data in the New Inventory tab (one row for each pollutant emitted from each emission unit emission release point). 

“Start Date” and “End Date” columns. You are asked to provide emissions data for the 2009 operating 

year. The “Start Date” and “End Date” columns indicate the dates for which NEI data are provided. For 

example, Start Date = 20090101 and End Date = 20091231 indicate that the NEI data cover emissions for 

the 2009 operating year (e.g., from 1-1-2009 until 12-31-2009). 

STEP 3. Submit your revised inventory following the instructions in Section B of this document. 

 

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PART II - ATTACHMENT 1 

Emission Units to Include in the NEI Update 

Include the following types of equipment (emission units) in your NEI Update. You may not operate all of the 

emission units listed below. Only include equipment operated at your mill. 

The Lookups for P&P survey.xls file (P&P Att 1 with SCC tab) contains a crosswalk of the equipment listed in this 

attachment with the available source classification codes (SCCs). The relevant pulp and paper MACT codes are 

indicated in parentheses below. Other MACT codes can be found in the Lookups for P&P survey.xls file (MACT 

Code tab). 

Chemical Recovery Combustion Equipment (1626-2)

Chemical recovery furnace 

Chemical recovery combustion unit 

Black liquor oxidation system 

Smelt or ash dissolving tank 

Salt cake mix tank 

Lime kiln or calciner 

Black liquor gasification system 

Sulfur burner 

Causticizing Equipment (1626-1)

Green liquor clarifier 

Green liquor storage tank 

Green liquor surge tank 

Slaker 

Causticizers 

White liquor clarifier 

White liquor storage tank 

White liquor pressure filter tank 

White liquor/weak wash pressure filter 

Weak wash storage tank 

Dregs washer 

Dregs filter exhaust 

Lime mud washer 

Lime mud filter system 

Digester Area Equipment (1626-1)

Digester 

Chip bin 

Chip steaming vessel 

Flash tank 

Blow tank 

Condenser 

Turpentine decanter 

Pulp Washing, Thickening, and Storage Equipment

(1626-1)

Brown stock washers 

Hoods 

Filtrate tanks 

Vacuum pumps 

Screens 

Knotters 

Decker 

Stock chests (including open stock chests) 

Pulp storage tanks 

Thickeners 

Evaporators (1626-1) 

Black liquor storage tanks 

Evaporator hot wells 

Condensers 

Boilout tanks 

Soap storage tanks 

Soap skimmer tanks 

Other emission points associated with the 

evaporators. 

Oxygen Delignification Equipment (1626-1)

Oxygen delignification reactor 

Oxygen delignification blow tank 

Oxygen delignification washer 

Post-oxygen washer filtrate tank 

Pulp storage tanks 

Other oxygen delignification system emission points. 

Non-condensable Gas (NCG) Collection (1626-1)

LVHC system 

HVLC system 

Stripper System Equipment (1626-1) 

Stripper feed tanks 

Condensers 

Heat exchangers 
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Methanol Rectification Equipment (1626-1)

Rectifiers 

Condensers 

Decanters 

Storage tanks 

Storage Tanks (1626-1)

Weak liquor storage tanks 

Strong liquor storage tanks 

Liquor storage ponds 

Acid condensate storage tanks (at sulfite mills) 

Tall Oil Production Equipment (1626-1)

Tall oil acidulation reactor 

Storage tank 

Dehydrator 

Brine storage tank 

Screen 

Centrifuge tank 

Other tall oil production vents 

Mechanical Pulping Equipment (1626-1)

Stone grinder 

Refiner 

Chip pre-steaming vessel 

Chip cooker 

Screen 

Decker 

Brightening/bleaching tower 

Non-wood Pulping Equipment (1626-1)

Secondary Fiber Pulping Equipment (1626-1)

Bleaching Equipment (1626-1)

Tower vents 

Washer hoods 

Seal tank vents 

Chemical and steam mixers 

Vacuum pumps

Paper Making Equipment (1626-1)

Paper machines 

Pulp dryers 

Machine chest 

Repulpers 

Stock blending and storage tanks 

Broke tanks 

Savealls 

White water storage tanks 

Wastewater Treatment System Units (1626-1)

Clarifiers 

Settling ponds 

Aerated stabilization basins 

Activated sludge systems 

UNOX systems 

Wastewater tanks 

Other wastewater handling and treatment units 

Power Boilers (Including Small Package Boilers)

Thermal Oxidizers/Incinerators (1626-1 or 1626-2)

Woodyard Operations (1626-3)

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PART II - ATTACHMENT 2 

Resources for Estimating Emissions 

Compilation of air pollution emission factors. Volume I: Stationary point and area sources (5th edition). AP-42. Section 

10.2, Chemical Wood Pulping. September 1990. Research Triangle Park, NC. U. S. Environmental Protection Agency, 

Office of Air Quality Planning and Standards. Available at http://www.epa.gov/ttn/chief/ap42/ch10/index.html.

Compilation of air pollutant emission factors. Volume I: Stationary point and area sources (Chapter 1, External 

Combustion Source). AP-42. 2001. Research Triangle Park, NC. U.S. Environmental Protection Agency, Office of Air 

Quality Planning and Standards. Available at http://www.epa.gov/ttn/chief/ap42/ch01/index.html.

National Council for Air and Stream Improvement, Inc. (NCASI). 2010. Compilation of ‘Air Toxic’ and Total 

Hydrocrabon Emissions Data for Pulp and Paper Mill Sources – A Second Update. Tehcnial Bulletin No. 973. Research 

Triangle Park, NC. Available to NCASI members at www.ncasi.org.

National Council for Air and Stream Improvement, Inc. (NCASI). 2002. Compilation of speciated reduced sulfur 

compound and total reduced sulfur emissions data for kraft mill sources. Technical Bulletin No. 849. Research Triangle 

Park, NC. Available to NCASI members at www.ncasi.org.

National Council for Air and Stream Improvement, Inc. (NCASI). 2003. Compilation of ‘air toxic’ and total 

hydrocarbon emissions data for sources at kraft, sulfite and non-chemical pulp mills – An update. Technical 

Bulletin No. 858. Research Triangle Park, N.C. Available to NCASI members at www.ncasi.org.

National Council for Air and Stream Improvement, Inc. (NCASI). 2004. Compilation of criteria air pollutant emissions 

data for sources at pulp and paper mills including boilers. Technical Bulletin No. 884. Research Triangle Park, N.C. 

Available to NCASI members at www.ncasi.org.

National Council for Air and Stream Improvement, Inc. (NCASI). 2010. Compilation of ‘air toxic’ and total 

hydrocarbon emissions data for sources at kraft, sulfite and non-chemical pulp mills – A Second update. Technical 

Bulletin No. 973. Research Triangle Park, N.C. Available to NCASI members at www.ncasi.org.
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Part II - Attachment 3 

Instructions for Accessing the Pulp and Paper NEI Update FTP Site 

In Internet Explorer go to: https://ftp.rti.org/

You should see this login request: 

Enter: 

username: pulppaper

password: part2NEI 
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Once you're logged in, the following screen will be displayed. 

Click on the "Upload" button at the bottom left corner of the screen. 

An "Upload" dialog box will appear. Browse to the file that you wish to upload, then click on the 

"Upload" button to upload the file to the FTP site. 
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The "Upload" dialog box will remain open so that you may upload more than one file. Click on the 

"Close" button when you are finished. 

The files that you have uploaded will be listed in the main window. 

After you have verified that your uploaded files are listed, click on the "Logout" button at the top right 

of the screen. 
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Pulp and Paper Sector Survey 

Instructions for Part III: 

Chemical Recovery Combustion Sources 

2/4/11 

This survey overview document provides instructions for completing Part III the pulp 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. PIII 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 III - 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

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A. Part III Introduction 

The pulp and paper sector information request applies for pulp and/or paper/paperboard mills 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 quantity, 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 completed 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 this information request applies for pulp mills that are a major source or synthetic area source of 

hazardous air pollutant (HAP) emissions that perform chemical wood pulping (for example, with the kraft, sulfite, 

soda, semichemical or other pulping process). 

This survey is to be completed in a Microsoft 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). Table 1 below denotes which survey spreadsheet 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 114 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, they can be downloaded here: 

https://icr2010.rti.org/Industries/PulpPaper.aspx

Use the 2009 calendar year as the base year for all survey responses (e.g., 2009 emissions inventory, 2009 capacity, 

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 

document. 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 stack, etc.) for each survey tab. Attachment 2 of 

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

under Part III. 

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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 selected 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 mills 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) 

PIII 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 submittal 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 data 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 

intent 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. 

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B. Confidential Business Information (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 indicating in the red 

block at the top 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 clearly 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 mills claiming large amounts of information as trade 

secret, especially information that is readily reported by other mills without such claims. 

C. How to Submit Your Part III Survey Response 

If your response to this information collection request includes 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 mailing addresses. 

C1. Submitting Your Non-CBI Response 

Follow these instructions for the non-CBI portions of your survey response (or for responses that are entirely nonCBI.) 

After you have completed and reviewed your survey response, sign and date the certification form in Attachment 4 

of the Survey Overview document. Remove 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 portions of your completed response, emission test reports, and any other electronic nonCBI 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 attachments to your survey (such as the signed certification form or test data). Please 

clearly label and mail 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 deadline 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 Mailroom (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. 

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C2. 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 CBI 

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. Roberto 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 Survey 

Your survey response will consist of emission test reports and completed Microsoft Excel spreadsheets. Separate 

Excel spreadsheet files are provided for completion (P&P survey_PIII.xls; P&P CEMS_PIII.xls; P&P costs 

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_PIII.xls spreadsheet file is to be 

completed if you have continuous emissions 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 white (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. 

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

In this portion of the survey you are asked to add data to 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_PIII.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 write 

in information if your selection is not contained in the pull-down menu. 

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Why does EPA need process data? 

Facility and equipment details are being requested to inform the technological review of the pulp and 

paper NESHAP and NSPS and to provide information on means of reducing residual risk. While the 

NEI 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 and 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). Applicability of the 

NESHAP and NSPS compliance options depends on the specific process equipment. 

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 the 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 PIII 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 functional and 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 consistent 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 the ID cells. For example, 

Emission Unit ID “DIG1” is not read the same as “DIG-1” or “DIG-1_” by data base software. 

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What if I have difficulty pairing emission units with corresponding Emission Unit IDs 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 pulp 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 Part 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 Equip 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 (covering 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 machine’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 unrelated 

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 least one mill. In this situation, 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 data 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 for 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 tabs to clarify any 

matching discrepancies with the Part II NEI. These notes will assist EPA in analyzing the data and 

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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 agency 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 

constraints of the pulping/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 answer 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 respondents 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 responses as “UK or “NA” are likely to receive 

scrutiny and follow-up inquiries from EPA related to their survey response.

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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). 

The types of emission units listed in Attachment 1 that you operate should be included in the PIII Equip detail tab. 

Columns A through AM ask generic questions for all emission units. The columns 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-AM 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 oxidation 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-CE 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 points 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. List each emission 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 separately and provide the same Collection system ID for the different Emission Unit IDs. 

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 Federal 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 emission unit in the PIII Equip detail tab. 

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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 PIII Equip detail tab, and then indicate in 

the “Emission unit description” 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 PIII Equip 

detail tab, and enter “FUGITIVE” in the “Configuration if not emitted through a conveyance” 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 PIII Equip detail tab 

(e.g., as a “Single emission unit with multiple release points” as described in the instructions immediately 

above for the PIII 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 the 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 detail tab. 

Air pollution control devices (APCDs). 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 unit (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 the Controls tab. For 

example, 

If 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-specific details requested in columns AN 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 equipment requiring instructions 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 PIII Equip detail and other survey tabs ask for process parameters such as exhaust 

flow rate (acfm), percent solids, temperature, etc. Unless otherwise specified, typical values are requested, 

and are subject to the respondent’s discretion. For example, if you measure a particular parameter 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 most recent measurement. 

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All emission units listed in Attachment 1. Complete columns A through AM. 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 AN through DU may also apply for selected emission unit types. 

Mills using the PM bubble compliance option. If 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 calculations 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 semichemical combustion 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 semichemical combustion unit configurations. 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 recent 

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 supplemental fuels. 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 firing rates for 

various nationwide impact analyses. Because the types and amounts 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-fired equipment such as lime kilns. Primary fuels are not requested 

for recovery furnaces or semichemical combustion units because black liquor (or red liquor) is assumed to be the 

primary material combusted in these units. Non-condensable gases (NCG) and stripper off gases (SOG) are not 

considered to be either primary or supplemental fuels for purposes of this survey. Supplemental and other fuel 

information is requested for recovery furnaces and semichemical combustion units in addition to other fuel-fired 

equipment such as lime kilns and thermal oxidizers. Information for secondary and additional fuels used routinely 

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

Emission unit startup and shutdown. Complete the startup 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 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. The startup and shutdown 

questions would also identify pulp and paper emission unit types for which startup and shutdown are not already 

addressed with the current emission standards. You are asked to supply 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 startup and shutdown data in the PIII Equip 

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

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b. PIII 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 response 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 below. These 

suggested units were taken from existing Federal limits codified in 40 CFR Part 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 every 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 (O2) for a combustion unit 

SO2 limit specified in the permit in terms of ppmdv, lb/hr, lb/day, and tpy, lb/MMBtu at specified % O2, 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 similar 

emission units nationwide. Please be as specific as possible when entering permit limit units. Include any oxygen 

correction factors (% O2). Be sure to note if ppm values are on a dry (d) or volume (v) or weight (w) basis if 

specified this way in your permit (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 the 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 limits). 

Permits restating NESHAP and NSPS limits. Your permit may simply restate the emission limits contained 

in Federal rules such as NESHAP subparts S and 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 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. 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 limits of most interest to EPA are those for fuel fired equipment such as recovery 

furnaces, semichemical combustion 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 PIII Permit limits tab, we will accept a copy of your 

operating permit (e.g., title V operating permit) instead of the completed PIII 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. 

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Table 2. Suggested Units of Measure for Permit Limits 

Pollutant Suggested units 

PM1 Recovery furnaces/chemical recovery combustion units: gr/dscf @ 8% O2

SDT: lb/ton BLS 

LK: gr/dscf @10% O2

Other processes: lb/ton of throughput, lb/MMBtu, gr/dscf, g/dscm, or specify 

PM101

PM2.51

Opacity % (provide averaging time) 

TRS RF/combustion units: ppmdv @ 8% O2

SDT: lb/ton BLS (as H2S) 

LK: ppmdv @ 10% O2

Other processes: lb/ADT pulp and/or ppmdv 

SO2 lb/MMBtu and/or ppmdv or limits on fuel S content 

NOX lb/MMBtu (as NO2) 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: lb/ton BLS 

HCl ppmdv and/or % reduction 

Methanol and gaseous organic 

HAP 

chemical recovery combustion sources: lb/ton BLS 

process sources: ppmv @ 10% O2, 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 limits distinguish between the filterable and condensable PM 

fractions. 

c. PIII Controls tab 

Complete the PIII Controls tab by following the instructions in the “Instruction” row for add-on APCDs used to 

control the Part III pulp and paper emission units 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. low-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 control efficiency. Actual control efficiencies are requested for PM, TRS, HCl, SO2, 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 reduction in the requested pollutant 

across the control device, then you would enter this test result as the “actual” control efficiency. You may leave 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 questions pertaining to thermal oxidizers for thermal oxidizers or regenerative 

thermal oxidizers used to control Part III chemical recovery combustion units (e.g., semi-chemical recovery units). 

Control device startup 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 

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different combinations of emission units and control devices used in the pulp and 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, you are asked to supply information for routine startup and shutdown 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 understand 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 tab by following the instructions in the “Instruction” row. 

D2. Test data 

Attachment 2 of this Part III survey contains a table of emission units and pollutants for which existing emissions 

data are requested. Emissions data are being requested in the form 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 the “PIII Emissions 

test data tab” for emissions test reports. Follow the instructions for completing the “CEMS data spreadsheet (P&P 

CEMS_PIII.xls)” if you have continuous emissions monitoring system (CEMS) data instead of emission test reports 

for a given 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 and 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 CEMS 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 not 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. Locate 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 required 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 

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need not supply emissions data for the prior configuration. However, you may voluntarily supply emissions data for 

prior configurations, as such information would be useful to EPA in characterizing emissions in general (for nonsite-specific uses), but we request that you identify that such data are no longer representative in the PIII Emissions 

test data tab. 

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

dates (e.g., 2001 or date of MACT compliance) 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 data prior 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 data 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, submit 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 Emissions test data tab to identify the specific emission units and control systems for which 

emission test reports are being submitted, the pollutant tested, and the test method. The PIII Emissions 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 emissions test data received through this survey. 

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

The EPA is requesting existing CEMS data and/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_PIII.xls) is provided for submittal of the requested CEMS 

data. The spreadsheet file contains individual worksheets (tabs) designed specifically for TRS (12-hour block 

average), TRS (hourly), Opacity, and other pollutants (NOx, SO2, 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 worksheets 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_PIII.xls spreadsheet file. 

TRS (12-Hour Average). This worksheet is designed for recovery furnaces, smelt dissolving 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 TRS 

emissions guidelines). Respondents are requested to specify the Emission Unit ID (or Collection system ID), 

the APCD_ID, and report the 12-hour averages of CEMS concentration data for TRS for CY2009 operations. 

In addition, respondents are asked to provide 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 

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malfunction conditions. [Note: The reported concentrations of TRS should be corrected to 8% O2 for 

recovery furnaces and 10% O2 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 averages. 

Opacity. This worksheet is designed for recovery furnaces or lime kilns equipped with COMS but may be 

used for other equipment. Respondents are requested to specify the Emission Unit ID (or Collection system 

ID) and the APCD_ID, and report the 6-minute average opacity for CY2009 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 highest single 6-minute average opacity recorded in CY2009: (a) under 

normal operating conditions, (b) under conditions of startup or shutdown, and (c) under malfunction 

conditions. 

Other pollutants (such as NOx, SO2, 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 Collection system ID) and the 

APCD_ID (or type of combustion controls used), and report the 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 malfunction 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 or 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 analysis 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 that, 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 not 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 operating hours in a day to estimate hourly production). 

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D3. Optional cost data 

The EPA requests information related to the capital and operating costs of selected air pollution controls or 

process/equipment changes. Providing this cost 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 mills 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, or if the entire tab should be treated as CBI. Responses containing CBI 

should be submitted according to the instructions in section C2 of this document. 

Any cost information that you provide would be very useful to EPA for purposes of evaluating the costs 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 is requested (e.g., costs dating back to 1998). The cost 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, the EPA is particularly interested in costs of the following APCDs. Please supply this information 

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 dry PM return system for your ESP 

 - Adding chambers/fields to an existing ESP 

 - Installation of quaternary 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 

 - Replacing 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 an 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 that 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 not be required for other mills). 

 

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 18

PART III - ATTACHMENT 1 

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

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

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

Chemical Recovery Combustion Equipment

Recovery furnace 

Semichemical combustion unit 

Black liquor oxidation system 

Smelt or ash dissolving tank 

Salt cake mix tank 

Lime kiln or calciner 

Black liquor gasification system 

Sulfur burner 
Part III Form Approved 02/17/2011 

OMB Control No. 2060-0656 

Approval Expires 02/28/2014 

PART III - ATTACHMENT 2 

Part III Emissions 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.)

 19
Part III 

Part III - Attachment 2. Pulp and Paper Emission Units and Pollutants for Which Existing Representative Emiss

Note: Emissions test data representative of your current operations are requested as described in the surv

Emission Unit Particulate 

matter 

(PM)1

Speciated 

HAP 

metals2

PM2.5 

(fil.) 

PM2.5 

(cond.) 

Hydrochloric 

acid (HCl) 

Acetaldehyde, 

Formaldehyde, 

Methanol1

Total 

hydrocarbon 

(THC) as 

carbon 

CDD/CDF 

and 

POM/PAH 

Total reduced 

sulfur (TRS)1,3

Test methods4 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. 

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 

vent 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 

Chemical 

recovery 

combustion units 

- sulfite 

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 

 20
Part III 

 21

Emission Unit Particulate 

matter 

(PM)1

Speciated 

HAP 

metals2

PM2.5 

(fil.) 

PM2.5 

(cond.) 

Hydrochloric 

acid (HCl) 

Acetaldehyde, 

Formaldehyde, 

Methanol1

Total 

hydrocarbon 

(THC) as 

carbon 

CDD/CDF 

and 

POM/PAH 

Total reduced 

sulfur (TRS)1,3

Chemical 

recovery 

combustion units 

- stand alone 

semichemical 

Supply data 

from 1990 

or more 

recent 

Supply 

most 

recent 

data 

Supply data 

from 1990 or 

more recent 

Not requested 

Smelt dissolving 

tanks (SDT) or 

ash dissolving 

tanks 

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 

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 data 

1 If your emission unit is equipped with a continuous emissions monitoring system (CEMS) or continuous opacity monitoring system (COMS), supply the CEMS dat

CEMS_PIII.xls). Synthetic area sources should supply the most recent data (if data are available). 

2 The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chromium VI (Cr+6) a

available. 

3 Speciated TRS would include: hydrogen sulfide (H2S), 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 

methods can be found at http://www.epa.gov/ttn/emc/prelim.html 
*

Section 114 requires public availability of all emission data and authorizes disclosure of confidential

 information in certain circumstances. See 40 FR 36902 - 36912 (September 1, 1976)

(Rev. 12/8/95)

EPA’s Information Gathering Authority

Under Section 114 of the Clean Air Act

Under Section 114 of the Act (42 U.S.C. 7414), Congress has given the U.S. Environmental Protection

Agency broad authority to secure information needed “for the purpose of (i) developing or assisting in the

development of any implementation plan under Section 100 or 111(d), any standard of performance under

Section 111, or any emission standard under Section 112, (ii) determining whether any person is in violation of

any such standard of any requirement of such a plan, or (iii) carrying out any provision of this Act.” Among other

things, Section 114 authorizes EPA to make inspections, conduct tests, examine records, and require owners or

operators of emission sources to submit information reasonably required for the purpose of developing such

standards. In addition, the EPA Office of General Counsel has interpreted Section 114 to include authority to

photograph or require submission of photographs of pertinent equipment, emissions, or both.

Under Section 114, EPA is empowered to obtain information described by that section even if you

consider it to be confidential. You may, however, request that EPA treat such information as confidential. 

Information obtained under Section 114 and covered by such a request will ordinarily be released to the public

only if EPA determines that the information is not entitled to confidential treatment.*

 Procedures to be used for

making confidentiality determinations, substantive criteria to be used in such determinations, and special rules

governing information obtained under Section 114 are set forth in 40 CFR Part 2 published in the Federal Register

on September 1, 1976 (40 FR 36902).

Pursuant to §2.204(a) of EPA’s Freedom of Information Act (FOIA) regulation, in the event a request is

received, or it is determined that a request is likely to be received, or EPA desires to determine whether business

information in its possession is entitled to confidential treatment even though no request for release of the

information has been received, please be advised that EPA will seek, at that time, the following information to

support your claim as required by §2.204(e)(4) of EPA’s FOIA regulations:

1. Measures taken by your company to guard against undesired disclosure of the information to others;

2. The extent to which the information has been disclosed to others, and the precautions taken in

connection therewith;

3. Pertinent confidentiality determinations, if any, by EPA or other Federal agencies, and a copy of any

such determinations, or reference to it, if available; and

4. Whether your company asserts that disclosure of the information would be likely to result in

substantial harmful effects on the business’ competitive position, and if so, what those harmful effects would be, 

why they should be viewed as substantial, and an explanation of the causal relationship between disclosure and

such harmful effects.

Enclosure 2
Enclosure 3

Enclosure 4
1

1. Purpose

This memorandum describes Agency policy and procedures set forth for the handling of

information claimed as Confidential Business Information (CBI), whether submitted voluntarily

or obtained under Section 114 of the Clean Air Act (CAA), and governed by U.S. Environmental

Protection Agency (EPA) regulations in 40 Code of Federal Regulations (CFR), Part 2, Subpart

B, and other EPA regulations and policies.

2. Reference Documents:

a. Clean Air Act as amended.

b. 40 CFR, Chapter 1, Part 2, Subpart B - Confidentiality of Business Information.

c. EPA Information Security Manual.

d. Clean Air Act Confidential Business Information Security Manual (January 2002)

3. Exception:

This document was prepared as a summary of data gathering and handling procedures

used by the OAQPS, EPA. Nothing in this document shall be construed as superseding or being

in conflict with any applicable regulations, statutes, or policies to which EPA is subject.

4. Definition:

Confidential Business Information - Information claimed by the provider to be

confidential. This information may be identified with such titles as trade secret, secret,

administrative secret, company secret, secret proprietary, privileged, administrative confidential,

company confidential, confidential proprietary, or proprietary. NOTE: These markings should

not be confused with the classification markings of National Security information identified in

Executive Order 11652.

5. Background

Section 114 (c) of the Clean Air Act as amended reads as follows:

January 2002

Enclosure 5
2

“Any records, reports, or information obtained under subsection (a) shall be available to the

public, except that upon a showing satisfactory to the Administrator by any person that records,

reports, or information, or particular part thereof (other than emission data), to which the

Administrator has access under this section if made public, would divulge methods or processes

entitled to protection as trade secrets of such person, the Administrator shall consider such

records, report, or information or particular portion thereof confidential in accordance with the

purposes of Section 1905 of Title 18 of the United States Code, except that such record, report,

or information may be disclosed to other officers, employees, or authorized representatives of the

United States concerned with carrying out this Act or when relevant in any proceeding under this

Act.”

The treatment of CBI by EPA, including data obtained under Section 114 of the Clean

Air Act, is governed by 40 CFR, Part 2. These regulations require EPA offices to include a

notice with each request for information to inform the business of: (1) its right to assert a claim

of confidentiality covering part or all of the information, (2) the method for asserting a claim,

and (3) the effect of failure to assert a claim at time of submission. In addition, the regulations: 

(1) set forth procedures for the safeguarding of confidential information; (2) contain provisions

for providing confidential information to authorize representatives; (3) contain provisions for the

release of information to the Congress, Comptroller General, other Federal agencies, State and

local governments, and Courts; (4) permit the disclosure of information within EPA to

employees with an official need for the information; and (5) prohibit wrongful use of such

information and cite penalties for wrongful disclosure. Further, the regulations contain the

Agency’s basic rule concerning the treatment of requests for information under the Freedom of

Information Act (5 U.S.C. 552).

6. Procedures:

a. Request for Information

Each request for information made under the provisions of Section 114(a) is signed by

the Division Director. The request includes standard enclosure “EPA’s Information Gathering

Authority under Section 114 of the Clean Air Act,” which was designed to meet the requirement

of 40 CFR Part 2 discussed above.

b. Receipt of CAA Confidential Business Information

Upon receipt of information for which confidential treatment has been requested, the

OAQPS Document Control Officer (DCO) logs in the material and a permanent file is

established. If part of the material is claimed to be confidential, that portion should be marked

“Subject to Confidentiality Claim.” In compliance with Sections 2.204 and 2.208 of 40 CFR

Part 2, the Group Leader responsible for the requested information reviews the information to

determine the validity of the confidentiality claim as prescribed by the sections. If the

information is clearly not confidential, the Group Leader prepares a letter for the signature of the

responsible Division Director to notify the business of this finding. Information claimed as

confidential is hand carried to the OAQPS CBI Office to be logged into the OAQPS CAA CBI

tracking system and filed for safekeeping. The OAQPS CAA CBI tracking system provides a
3

brief description of the material (submitter, subject, number of pages, etc.), identifies it with the

correct project number, or work assignment number, and lists those persons who are authorized

to have access to the information. A record of personnel accessing the information (Attachment

A) is also kept on filed. By regulation, confidential information must be so marked or

designated by the originator. EPA takes additional measures to ensure that the proprietary

designation is uniformly indicated and immediately observable. All unmarked or undesignated

information (except as noted below) may be authorized for public release.

c. Storage of CAA Confidential Business Information

Folders, documents, or material containing CAA CBI (as defined) shall be secured,

within the confines of the instructions listed in the OAQPS Security Manual. In addition, the

CBI storage area that has been identified specifically for that purpose and equipped with a

supplementary locking device. The storage area and files are under the direct control of the

OAQPS DCO.

Access to the storage area is limited to the Document Control Officer DCO, Document

Control Assistant (DCA) and the minimum number of persons required to effectively maintain

normal business operations as directed by the Director, Planning, Resources and Regional

Management Staff (PRRMS).

Files may be issued upon confirmation that the requesting individual is authorized to

receive the information. All confidential files must be returned no later than close of business on

the same day. The intended user must sign the CBI Control Record when checking out files.

Individuals signing out confidential files are responsible for their safekeeping. Files must

never be left unattended. The information must not be disclosed to any non-authorized

personnel.

Storage procedures for CAA CBI by an authorized representative of EPA (see Section d.

below) must be, at a minimum, as secure as those established for EPA offices within OAQPS. 

Whenever CBI is removed from the EPA files to be transmitted to an authorized representative, a

notation is made in the file’s control record and transfer log indicating what information was

transmitted, the date, and the recipient. The authorized representative returns a signed receipt to

the DCO.

d. Access to CAA Confidential Business Information

Only authorized EPA employees may open or distribute CAA CBI.

Only employees who require, have a need to know and are authorized access to CAA

CBI in the performance of their official duties are permitted to review documents and, upon

receiving a confidential document, must sign and date the form shown in Attachment A to certify

their access to the document.

The Group Leader having primary responsibility for the CAA CBI provides a

memorandum to the DCO designating those personnel authorized to access specific CBI. No
4

person is automatically entitled to access based solely on grade, position, or security clearance. 

The names of persons granted access to CAA CBI are placed on the CAA CBI access list. The

CAA CBI access list indicates the “specific” CBI each person is permitted to see. The Access

List is reviewed and updated periodically.

Companies under contract to perform work for the EPA may be designated authorized

representatives of EPA. As authorized representatives, contractors may be granted access to

CAA CBI. The following conditions apply when it has been determined that disclosure is

necessary:

 (1) The contractor designated as a representative and its employees (a) may use such

confidential information only for the purpose of carrying out the work required, (b) must refrain

from disclosing the information to anyone other than EPA without having received from EPA

prior written approval of each affected business or of an EPA legal office, and (c) must return to

EPA all copies of the information (and any abstracts or excerpts there from) upon request or

whenever the information is no longer required for the performance of the work.

 (2) The authorized contractor designated as a representative must obtain a written

confidentiality agreement from each of its employees who will have access to the information. 

A copy of each employee agreement (Attachment B) must be furnished to EPA before access is

permitted.

 (3) The contractor designated as an authorized representative must agree that the

conditions in the contract concerning the use and disclosure of CAA CBI are included for the

benefit of, and shall be enforceable by, both EPA and any affected business having a proprietary

interest in the information.

Information may be released to or accessed by EPA employees other than OAQPS

employees only upon approval of the Director, PRRMS.

Requests for CAA CBI from other Federal agencies, Congress, the Comptroller General,

Courts, etc., are processed in accordance with 40 CFR 2, Subpart B.

Requests under the Freedom of Information Act (FOIA) are handled in accordance with

40 CFR 2, Subpart A. The Freedom of Information Act Coordinator must be consulted prior to

responding to any request for information if a claim of confidentiality has been asserted or if

there is reason to believe that a claim might be made if the business knew release was intended.

e. Use and Disclosure of CAA Confidential Business Information

The CAA CBI as defined may not be used in publications, supporting document,

memoranda, etc., that become a part of the public domain, except as provided for in 40 CFR 2

Subpart B. CAA CBI may not be summarized without the approval of the Group Leader

responsible for the CAA CBI. Any authorized reproductions must be logged into the CAA CBI

document tracking system and treated according to the same procedures applicable to the

original confidential material. Documents, materials, or extracts of information generated by
5

EPA which contain CAA CBI must be stamped “Subject to Confidentiality Claim” and a cover

sheet must be attached to identify the material as CBI.

f. Handling of Other Information

Reports, memoranda, documents, etc., prepared by EPA or its authorized representatives

are not normally circulated outside EPA for comment or review prior to publication except in

such cases as described in section 6 above. However, because industrial-data-gathering visits,

plant inspections, and source testing can involve inadvertent receipt of CAA CBI, it is the policy

of OAQPS to protect all parties involved in the following manner:

(1) Prior to or at the inception of a plant inspection, data-gathering visit, or source test,

EPA or its authorized representative discusses with a responsible industry official the

information sought, how it is to be used, and how it is to be protected. A copy of this summary

is usually provided to the industry official being consulted.

(2) Following an inspection, visit, or test, a trip report is prepared to include, as

practicable, all information received by EPA or its authorized representative during the visit or

test. The report may be prepared by either EPA or its authorized representative. The draft report

is clearly identified, with an attached, yellow cover sheet. A second copy of the draft trip report

is forwarded by EPA to the responsible industry official for review. The responsible industry

official is requested by cover letter to review the report, clearly mark any information considered

to be confidential, and return the marked up-report to the responsible EPA employee within the

time specified. The original draft is kept in the CBI file until the marked-up copy is returned by

the business firm.

(3) When the reviewed copy of the report, as marked by the responsible plant official, is

received by EPA, information designated confidential is placed in the CBI files as described

above. The original draft of the trip report is edited to delete the confidential information and the

trip report is authorized for release. 

Attachments (2)


Survey NEI RTI ID Company Name Mill Name Mill Contact Name Mill Address Mill City Mill State Mill Zip

No NEI 507 3M 3M (Tilton) Peter Masterson 1 Paper Trail Tilton NH 03276-0739

NEI41565 198 AbitibiBowater Inc. AbitibiBowater Inc. (Calhoun Mill) Lori Chalker 5020 Hwy 11 S Calhoun TN 37309

NEI47077 200 AbitibiBowater Inc. AbitibiBowater Inc. (Catawba Mill) Dale Herendeen 5300 Cureton Ferry Rd Catawba SC 29704

NEI18390 199 AbitibiBowater Inc. AbitibiBowater Inc. (Coosa Pines Mill) Daniel Diehl 17589 Plant Rd Coosa Pines AL 35044

NEI11108 231 AbitibiBowater Inc. AbitibiBowater Inc. (Grenada Mill) Environmental Compliance Manager 1000 Papermill Road Grenada MS 38901

NEI11367 512 Ahlstrom Filtration LLC Ahlstrom Filtration, L.L.C. (Madisonville Mill) Shad Clayton 215 Nebo Rd. Madisonville KY 42431

NEIIL0215971 511 Ahlstrom Filtration LLC Ahlstrom Filtration, L.L.C. (Taylorville Mill) Shad Clayton 1200 E. Elm St. Taylorville IL 62568

NEIPA04115-0 510 Ahlstrom Mt. Holly Springs, L.L.C. Ahlstrom Mt. Holly Springs, L.L.C. (Mount Holly Springs Mill) Mark Cassel 122 W. Butler St. Mount Holly Springs PA 17065-0238

NEI18373 208228535 Alabama River Cellulose Alabama River Cellulose Environmental Compliance Manager 2373 County Road 39 Perdue Hill AL 36470

NEI7106 501 American Eagle Paper Mills Inc. American Eagle Paper Mills Inc. (Tyrone Mill) Environmental Compliance Manager 1600 Pennsylvania Ave. Tyrone PA 16686

NEI2NH900001 509 APC Paper Co. APC Paper Co. Paul Mallet 130 Sullivan St. Claremont NH 03743

No NEI 506 APC Paper Co. APC Paper Co. of NY Mike Ward 100 Remington Ave. Norfolk NY 13667

NEI7104 207 Appleton Appleton (Roaring Spring Mill) Dennis Zink 100 Paper Mill Rd Roaring Spring PA 16673

NEI11645 451 Appleton Appleton (West Carrolton Mill) Nancy McDonald 1030 W. Alex-Bell Rd. West Carrollton OH 45449

NEI43207 526 Appleton Coated L.L.C. Appleton Coated LLC (Combined Locks) Kristin Marshall 540 Prospect St Combined Locks WI 54113

No NEI 504 Atlas Paper Mills Atlas Paper Mills LLC (Hialeah Mill) Environmental Compliance Manager 3725 E. 10th Ct. Hialeah FL 33013

NEI8122 232 Augusta Newsprint Co. Augusta Newsprint Co. (Augusta Mill) Roxanne Fincher 2434 Doug Bernard Pkwy Augusta GA 30906

No NEI 503 Augusta Tissue Augusta Select Tissue Mike Sherback 3452 Cookie Rd Augusta GA 30906

NEI208 409 Bear Island Paper Co., LLC Bear Island Paper Co., L.L.C. (Ashland Mill) Environmental Compliance Manager 10026 Old Ridge Rd. Ashland VA 23005

NEIWI105154003080 356 Beloit Box Board Co., Inc. Beloit Box Board Co., Inc. (Beloit Mill) Richard Schneider 801 Second St Beloit WI 53512-0386

NEIMIB2013 330 Berry Plastics Berry Plastics Holding Corporation (Constantine Mill) Environmental Compliance Manager 700 Centreville Rd Constantine MI 49042

NEI13329 495 Blue Heron Paper Co. Blue Heron Paper Co. (Oregon City Mill) Bruce Martin 419 Main St. Oregon City OR 97045

NEI40282 206 Blue Ridge Paper Products Inc. Evergreen Packaging Inc. (Pigeon River Mill) Environmental Compliance Manager 175 Main St Canton NC 28716

NEI7559 201 Boise Inc. Boise Inc. (DeRidder Mill) Environmental Compliance Manager 4200 Hwy 190 West DeRidder LA 70634

NEI12411 202 Boise Inc. Boise Inc. (International Falls Mill) Environmental Compliance Manager 400 Second St International Falls MN 56649

NEI8601 205 Boise Inc. Boise Inc. (Jackson Mill) William Davis 4585 Industrial Rd Jackson AL 36545

NEI40553 204 Boise Inc. Boise Inc. (Saint Helens Mill) Environmental Compliance Manager 1300 Kaster Road St Helens OR 97051

NEI42410 203 Boise Inc. Boise Whitepaper LLC (Wallula Mill) Eric Steffensen 31831 West Hwy 12 Wallula WA 99363

NEIWI20052 497 BPMI BPM, Inc. (Peshtigo Mill) Gary L. Motkowski 200 W. Front St. Peshtigo WI 54157-0149

NEI47091 606 Buckeye Technologies Inc. Buckeye Florida L.P. (Perry Mill) Ray Andreu One Buckeye Dr Perry FL 32348

NEITNT$5064 700 Buckeye Technologies Inc. Buckeye Technologies Inc. Environmental Compliance Manager 1001 Tillman Memphis TN 38112

No NEI 488 Burrows Paper Corp Burrows Paper Corp. (Lyonsdale Mill) Mindy Bird 7801 Lyonsdale Rd. Lyons Falls NY 13368

No NEI 490 Burrows Paper Corp Burrows Paper Corp. (Mill St) Melinda Bird 730 E. Mill St. Little Falls NY 13365

No NEI 492 Burrows Paper Corp Burrows Paper Corp. (Mohawk Valley) Melinda Bird 489 W. Main St. Little Falls NY 13365

No NEI 487 Burrows Paper Corp. Burrows Paper Corp. (Pickens Mill) Joe Roberts 196 Burrows Drive Pickens MS 39146

NEICA0854393 354 California Paperboard California Paperboard Corp. (Santa Clara Mill) Keith Wharton 525 Mathew St Santa Clara CA 95052

NEI2GA700022 359360367 Caraustar Industries Austell Boxboard Mills # 1 and #2 and Sweetwater Paperboard (Austell Mill) Howard Sinyard 3400 Joe Jerkins Boulevard Austell GA 30106

NEIRSC0-0013 352 Carotell Paperboard Carotell Paperboard (Taylors Mill) Vince Fields 873 Alexander Rd Taylors SC 29687

NEI18658 171 Carter Holt Harvey Evergreen Packaging Inc. (Pine Bluff Mill) Kelly Bryant 5201 Fairfield Rd. Pine Bluff AR 71611

NEICT3102 275 Cascades Boxboard Cascades Boxboard Group Connecticut LLC Moira A McCue 130 Inland Road Versailles CT 06383

No NEI 616 Cascades Holdings US Inc. Cascades Tissue Group - Oregon Inc. (Saint Helens Mill) Dennis Cox 1300 Kaster Rd Saint Helens OR 97051

NEI2NC300006 445 Cascades Tissue Group Cascades Tissue Group - NC Inc. (Rockingham Mill) Karen Bellamy 805 Midway Rd. Rockingham NC 28380

No NEI 484 Cascades Tissue Group Cascades Tissue Group - New York Inc. (Mechanicville Mill) Nick Landry 510 S. Main St. Mechanicville NY 12118

NEI2PA690032 482 Cascades Tissue Group Cascades Tissue Group - PA. Inc. (Ransom Mill) Sean Wolfe 1 Main St. Ransom PA 18640

No NEI 485 Cascades Tissue Group Cascades Tissue Group - TennesUse Inc. (Memphis Mill) Environmental Compliance Manager 1535 Thomas St. Memphis TN 38107

NEIWI6180224 444 Cascades Tissue Group Cascades Tissue Group - Wisconsin Inc. (Eau Claire Mill) Kathy Gillespie 1200 Forest St. Eau Claire WI 54703

NEI13216 210 Catalyst Paper Catalyst Paper (Snowflake) Inc. Kenneth Giberson Spur 277 North Snowflake AZ 85937

No NEI 480 Cellu Tissue Cellu Tissue (East Hartford Mill) Chris Fiedler 2 Forbes St. East Hartford CT 06128-0096

NEI42774 443 Cellu Tissue Cellu Tissue-CityForest LLC (Ladysmith Mill) Environmental Compliance Manager 1215 East Worden Ave. Ladysmith WI 54848-2079

No NEI 479 Cellu Tissue Holdings Inc. Cellu Tissue (Natural Dam Mill) Robin Gaumes 4921 Rte 58N Gouverneur NY 13642

No NEI 477 Cellu Tissue Holdings Inc. Coastal paper (Wiggins Mill) Gavin Black 1321 S. Magnolia Dr. Wiggins MS 39577

No NEI 605 Cellynne Corporation Cellynne Corp. (Haines City Mill) Mary Ellen Diamond 1006 Marley Drive Haines City FL 33844

No NEI 239 Cheney Pulp & Paper Co. Cheney Pulp & Paper Co. (Franklin Mill) Environmental Compliance Manager 1000 Anderson Street Franklin OH 45005

NEIOH0611431071006 349 Cincinnatti Paperboard Cincinnati Paperboard (Cincinnati Mill) Aaron Yonka 5500 Wooster Rd Cincinnati OH 45226

No NEI 348 Climax Paperboard Inc. Climax Paperboard Inc. (Carthage Mill) Fred Gutermout 30 Champion St Carthage NY 13619

No NEI 476 Cottrell Paper Co., Inc. Cottrell Paper Co., Inc. (Rock City Falls Mill) Environmental Compliance Manager 1135 Rock City Rd. Rock City Falls NY 12863-0035

NEIMA0030038 486 Crane & Co., Inc. Crane & Co. Inc. (Byron Weston Mill) Jim Nole 800 Main St. Dalton MA 01226

No NEI 475 Crane & Co., Inc. Crane & Co., Inc. (Bay State Mill) Jim Nole 30 Main St. Dalton MA 01226

NEIMA0030039 474 Crane & Co., Inc. Crane & Co., Inc. (Wahconah Mill) Jim Nole 130 Housatonic St. Dalton MA 01226

NEIMA0170368 609 Creative Packaging and Paper Inc Creative Paper Co. (Worcester Mill) Chris Booth 175 James St Worcester MA 01603

NEIMA0270055 472 Crocker Technical Papers Crocker Technical Papers (Fitchburg Mill) Chris Dembrowski 431 Westminster St. Fitchburg MA 01420-4700
Survey NEI RTI ID Company Name Mill Name Mill Contact Name Mill Address Mill City Mill State Mill Zip

NEI18657 197 Delta Natural Kraft Delta Natural Kraft (Pine Bluff Mill) Lisa Bowling 1701 Jefferson Pkwy Pine Bluff AR 71602

NEI40686 100 Domtar Corporation Domtar Corporation (Johnsonburg Mill) Andrew M. Redmond 100 Center St Johnsonburg PA 15845

NEI42695 617 Domtar Corporation Domtar Corporation (Nekoosa Mill) David Ulrich 301 Point Basse Ave. Nekoosa WI 54457

NEI18660 196 Domtar Industries Domtar Industries (Ashdown Mill) Environmental Compliance Manager 285 Hwy 71 South Ashdown AR 71822

NEI33981 468 Domtar Paper Company LLC Domtar Corporation (Port Huron Mill) Christine Loeffler 1700 Washington Ave. Port Huron MI 48060

NEI54400 365 Domtar Paper Company LLC Domtar Corporation (Rothschild Mill) Terry Charles 200 N. Grand Ave. Rothschild WI 54474

NEI9201 103 Domtar Paper Company LLC Domtar Paper Company (Plymouth Mill) Dianne Hardison NC Highway 149 N Plymouth NC 27962

NEI32869A 109 Domtar Paper Company LLC Domtar Paper Company LLC (Hawesville Mill) Joel Howell Hwy 1406, 58 Wescor Road Hawesville KY 42348

NEI41599 106 Domtar Paper Company LLC Domtar Paper Company LLC (Kingsport Mill) D Anthony Robbinson 100 Clinchfield St Kingsport TN 37660

NEI47074 107 Domtar Paper Company LLC Domtar Paper Company LLC (Marlboro Mill) Athena Strickland 585 Willamette Road Bennettsville SC 29512

No NEI 467 Dunn Paper Dunn Paper (Port Huron Mill) Anthony Kessler 218 Riverview St. Port Huron MI 48060

NEINM03187045MCKNLCO 346 Durango McKinley Paper Co. Durango-McKinley Paper Co. (Prewitt Mill) John Shaw County Rd 19 Prewitt NM 87045

NEI42136 345 EHV Weidmann Industries Inc. Weidmann Electrical Technology Inc. (Saint Johnsbury Mill) Larry Corrow 1 Gordon Mills Way St. St. Johnsbury VT 05819

NEIMA0110121 441 Erving Paper Mills Inc. Erving Paper Mills Inc. (Erving Mill) Environmental Compliance Manager 97 E. Main St. Erving MA 01344

NEIMA0110100 466 Esleeck Manufacturing Co., Inc. Southworth Co. (Turners Falls Mill) Jeff Poirier 36 Canal Rd Turners Falls MA 03176

No NEI 344 Fibercorr Inc. Fibercorr Inc. (Massillon Mill - Fibercorr) Scott Shew 670 17th St. NW Massillon OH 44646

NEIVT7 528 FiberMark North America, Inc. FiberMark North America, Inc. (Brattleboro Mill) Bryan Maloy (and/or Steve Pfistner) 161 Wellington Rd Brattleboro VT 05301

No NEI 619 FiberMark North America, Inc. FiberMark North America, Inc. (Brownville Mill) Tim Shear (cc Stephen Pfistner) Bridge St (no number) Brownville NY 13615

NEI39968 193 Finch Paper LLC Finch Paper LLC (Glens Falls Mill) Larry Phillips 1 Glen St Glens Falls NY 12801

No NEI 461 First Quality Tissue First Quality Tissue LLC (Lock Haven Mill) Jim Vaina 904 Woods Ave Lock Haven PA 17745

No NEI 460 Flower City Tissue Mills Co. Flower City Tissue Mills Co. (Rochester Mill) Bill Shafer 700 Driving Park Ave. Rochester NY 14613-0497

No NEI 343 Franklin Boxboard Co. Franklin Boxboard Corp. (Franklin Mill) Environmental Compliance Manager 50 E 6th St Franklin OH 45005-0427

NEI42730 192 Fraser Papers Inc. Flambeau River Papers, LLC (Park Falls Mill) Kristen Palecek 200 1st Avenue North Park Falls WI 54552-1260

NEI2NHT14578 191 Fraser Papers Inc. Fraser Papers Inc. (Gorham Mill) Ryan Carrier 72 Cascade Flatts Gorham NH 03581

NEIMIB4238 455 French Paper Co. French Paper Co. (Niles Mill) Mike Ford 100 French St. Niles MI 49120

NEIWI139471032210 523 George A. Whiting Paper Co. George A. Whiting Paper Co. (Menasha Mill) Tina Pfeffer 100 River St Menasha WI 54952

NEI42211 187 Georgia-Pacific Corp. Georgia-Pacific Corp. (Big Island Mill) Environmental Compliance Manager 9363 Lee Jackson Hwy Big Island VA 24526

NEI18338 130 Georgia-Pacific Corp. Georgia-Pacific Corp. (Brewton Mill) Environmental Compliance Manager 32224 U.S. Highway 31 Brewton AL 36427

NEI42482 436 Georgia-Pacific Corp. Georgia-Pacific Corp. (Broadway Street/West Mill) Todd Cullen 1919 S. Broadway. Green Bay WI 54304

NEI46599 185 Georgia-Pacific Corp. Georgia-Pacific Corp. (Camas Mill) Environmental Compliance Manager 401 NE Adams St Camas WA 98607

NEI26491 190 Georgia-Pacific Corp. Georgia-Pacific Corp. (Cedar Springs Mill) Jeff Lawrence 12551 Highway 273 W Cedar Springs GA 39832

NEI54342 189 Georgia-Pacific Corp. Georgia-Pacific Corp. (Crossett Mill) Environmental Compliance Manager 101 Plywood Rd Crossett AR 71635

NEIWI4050324 520 Georgia-Pacific Corp. Georgia-Pacific Corp. (Day Street/East Mill) Todd Cullen 1919 S. Broadway. Green Bay WI 54302

NEI11172 613 Georgia-Pacific Corp. Georgia-Pacific Corp. (Monticello Mill) Kim Grantham 604 NA Sandifer Rd Monticello MS 39654

NEI12980 428 Georgia-Pacific Corp. Georgia-Pacific Corp. (Muskogee Mill) Steve Landers 4901 E Chandler Rd. Muskogee OK 74403

NEI18334 186 Georgia-Pacific Corp. Georgia-Pacific Corp. (Naheola Mill) Laura Connor 7530 Hwy 114 Pennington AL 36916

NEI8265 525 Georgia-Pacific Corp. Georgia-Pacific Corp. (Palatka Mill) Jeremy Alexander 215 County Road 216 Palatka FL 32178

NEI46817 184 Georgia-Pacific Corp. Georgia-Pacific Corp. (Port Hudson Mill) Ronnie Albritton 1000 W Mt Pleasant Zachary Rd Zachary LA 70791

NEI8178 430 Georgia-Pacific Corp. Georgia-Pacific Corp. (Savannah River Mill) Environmental Compliance Manager 393 Fort Howard Rd. Rincon GA 31326

NEI40600 188 Georgia-Pacific Corp. Georgia-Pacific Corp. (Toledo Mill) Environmental Compliance Manager 1400 S.E. Butler Bridge Rd Toledo OR 97391

NEI40554 615 Georgia-Pacific Corp. Georgia-Pacific Corp. (Wauna Mill) Jeff Sorensen 92326 Taylorville Road Clatskanie OR 97016

NEI8196 243 Georgia-Pacific Corp. GP Cellulose, LLC (Brunswick Mill) Environmental Compliance Manager 1400 9th Street Brunswick GA 31520-3240

NEI34066 242 Georgia-Pacific Corp. GP Cellulose, LLC (Leaf River Mill) Environmental Compliance Manager 157 Buck Creek Rd. New Augusta MS 39462

NEI40488 149 Glatfelter Glatfelter (Chillicothe Mill) Environmental Compliance Manager 401 S Paint St Chillicothe OH 45601

NEI7181 182 Glatfelter Glatfelter (Spring Grove Mill) Phillis Chant 228 S Main St Spring Grove PA 17362

NEIMIB1534 329 Graphic Packaging Corp. Graphic Packaging International Inc. (Battle Creek Mill) Environmental Compliance Manager 79 E Fountain St Battle Creek MI 49017-4198

NEIMIB1678 342 Graphic Packaging Corp. Graphic Packaging International Inc. (Kalamazoo Mill) Environmental Compliance Manager 1500 N Pitcher St Kalamazoo MI 49007-2539

NEI26471 180 Graphic Packaging Corp. Graphic Packaging International Inc. (Macon Mill) Environmental Compliance Manager 100 Riverwood International Way Macon GA 31206-2098

NEI11602 288 Graphic Packaging Corp. Graphic Packaging International Inc. (Middletown Mill) Leslie O'Hara 407 Charles St Middletown OH 45042

NEIIL179814A 317 Graphic Packaging Corp. Graphic Packaging International Inc. (Pekin Mill) Jeff Lyman 1525 S 2nd St Pekin IL 61554

NEICA0854651 293 Graphic Packaging Corp. Graphic Packaging International Inc. (Santa Clara Mill) Rick Horne 2600 De La Cruz Blvd Santa Clara CA 95050

NEI6057 181 Graphic Packaging Corp. Graphic Packaging International Inc. (West Monroe Mill) Cindy Brown 1000 Jonesboro Rd West Monroe LA 71294

NEIWA0270002 518 Grays Harbor Paper, L.P. Grays Harbor Paper, L.P. (Hoquiam Mill) Bob Martin 801 23rd St Hoquiam WA 98550

NEI33879 517 Great Lakes Tissue Co. Great Lakes Tissue Co. (Cheboygan Mill) Tom Palowski 437 S Main St Cheboygan MI 49721

NEI42486 341 Green Bay Packaging Inc. Green Bay Packaging Inc. (Green Bay Mill) Jennifer Peplinski 1601 N Quincy St. Green Bay WI 54302

NEI46852 340 Green Bay Packaging Inc. Green Bay Packaging Inc. (Morrilton Mill) Environmental Compliance Manager 338 Hwy 113 S. Morrilton AR 72110

No NEI 422 Greif Inc. Greif Inc. (Massillon Mill) Jamie Cutcher 787 Warmington Rd SW Massillon OH 44648

NEIVA00022 304 Greif Inc. Greif Inc. (Riverville Mill) Environmental Compliance Manager 861 Fibre Plant Rd. Amherst VA 24521

No NEI 618 Gusmer Enterprises, Inc. Gusmer Enterprises, Inc. Heather Jensen 1401 Ware Street Waupaca WI 54981-1365

NEI23 339 Halltown Paperboard Co. Ox Paperboard LLC (Halltown Mill) Martin Weller Halltown Rd, Old Rte 340 Halltown WV 25423-0010

NEI11795 338 Hartford City Paper, L.L.C. Hartford City Paper, L.L.C. (Hartford City Mill) Neil Butchard 501 S. Spring St. Hartford City IN 47348
Survey NEI RTI ID Company Name Mill Name Mill Contact Name Mill Address Mill City Mill State Mill Zip

NEIMA131179 515 Hollingsworth & Vose Co. Hollingsworth & Vose Co. (East Walpole Mill) Environmental Compliance Manager 112 Washington St East Walpole MA 02032

NEINY5532600 508513 Hollingsworth & Vose Co. Hollingsworth & Vose Co. (Easton Mill) Virginia Keefer 3235 County Route 113 Greenwich NY 12834

NEINY5533400 496 Hollingsworth & Vose Co. Hollingsworth & Vose Co. (Greenwich Mill) Virginia Keefer 3235 County Route 113 Greenwich NY 12834

NEIGAT$3909 516 Hollingsworth & Vose Co. Hollingsworth & Vose Co. (Hawkinsville Mill) Rachel Revis 106 Industrial Blvd Hawkinsville GA 31036

NEI6175 514 Hollingsworth & Vose Co. Hollingsworth & Vose Co. (West Groton Mill) Environmental Compliance Manager 219 Townsend Rd West Groton MA 01472

NEIWA0630092 421 Inland Empire Paper Co. Inland Empire Paper Co. (Millwood Mill) Douglas Krapas 3320 N. Argonne Rd. Spokane WA 99212

NEINY7355800 701 Interface Solutions Inc. Interface Solutions Inc. Debra L. Morris 2285 ST RTE 481 Fulton NY 13069

No NEI 235 Interface Solutions, Inc. Omniafiltra, LLC (Beaver Falls Mill) Patty Flint 9547 Main St. Beaver Falls NY 13305

NEI26514 175 International Paper Co. International Paper Co. (Augusta Mill) Rob Wood, EHS Manager 4278 Mike Padgett Hwy Augusta GA 30906

No NEI 351 International Paper Co. International Paper Co. (Cedar Rapids Mill) John Myers, OE Team Leader 4600 C Street SW Cedar Rapids IA 52404

NEI18357 600 International Paper Co. International Paper Co. (Courtland Mill) Steve Rickman, EHS Env. Engineer 16504 County Rd 150 Courtland AL 35618

NEI46760 162 International Paper Co. International Paper Co. (Eastover Mill) Greg Arling, EHS Manager 4001 McCords Ferry Rd Eastover SC 29044

NEI41314 166 International Paper Co. International Paper Co. (Georgetown Mill) Ken Ray, EHS Manager 700 S Kaminski St Georgetown SC 29440

NEIKY1010117 259 International Paper Co. International Paper Co. (Henderson Mill) Larry Griffin, Technical Manager 1500 Commonwealth Dr. Henderson KY 42420

NEI26124 260 International Paper Co. International Paper Co. (Hueneme Mill) Victor Kumpera, Dept Mgr Technical 5936 Perkins Rd Oxnard CA 93033

NEI33013 169 International Paper Co. International Paper Co. (Mansfield Mill) James Strange, EHS Manager 1202 HWY 509 Mansfield LA 71052

NEI26309 178 International Paper Co. International Paper Co. (Pensacola Mill) Rusty Plenkers, EHS Manager 375 Muscogee Rd Cantonment FL 32533

NEI8619 116 International Paper Co. International Paper Co. (Pine Hill Mill) Kyle Morre, EHS Manager 7600 Hwy 10 West Pine Hill AL 36769

NEI8560 163 International Paper Co. International Paper Co. (Prattville Mill) Martha Sims, EHS Manager 100 Jensen Rd Prattville AL 36067

No NEI 108 International Paper Co. International Paper Co. (Red River Mill) Larry Morgan, EHS Manager 4537 Highway 480 Campti LA 71411

NEI40247 174 International Paper Co. International Paper Co. (Riegelwood Mill) Ed Kreul, EHS Manager 865 John L Riegel Rd Riegelwood NC 28456

NEI18335 172 International Paper Co. International Paper Co. (Riverdale Mill) Ken Trosper, EHS Manager 601 County Road 78 Selma AL 36703-8305

NEI8186 531 International Paper Co. International Paper Co. (Savannah Mill) Annette Ford, EHS Manager 1201 West Lathrop Avenue Savannah GA 31415-1099

NEI45182 105 International Paper Co. International Paper Co. (Springfield Mill) Scott Freeburn, EHS Manager 801 42nd Street Springfield OR 97478

NEI41628 165 International Paper Co. International Paper Co. (Texarkana Mill) Moe Marquis, EHS Manager 9978 Farm Market Road 3129 Queen City TX 75572

NEI35908 173 International Paper Co. International Paper Co. (Ticonderoga Mill) Dean Messner, EHS Manager 568 Shore Airport Road Ticonderoga NY 12883

NEI11251 104 International Paper Co. International Paper Co. (Valliant Mill) Kathryn Crenwelge, EHS Manager 890 IP Lane Valliant OK 74764

NEI34070 167 International Paper Co. International Paper Co. (Vicksburg Mill) John Adams, EHS Manager 3737 Hwy 3 North Redwood MS 39156

NEI8177 159 Interstate Paper L.L.C. Interstate Paper L.L.C. (Riceboro Mill) Environmental Compliance Manager 2366 Interstate Paper Rd Riceboro GA 31323

NEINY1150015 498 Irving Tissue Inc. Irving Tissue Inc. (Fort Edward Mill) Tom Nash 1 Eddy St Fort Edward NY 12828

NEIVT88 491 Isovalta Inc./US Samica Isovolta Inc./US Samica (Rutland Mill) Paul Darby 477 Windcrest Road Rutland VT 05701

NEIIL46 489 IVEX Packaging Corp. IVEX Packaging Corp. (Joliet Mill) Environmental Compliance Manager 292 Logan Av Joliet IL 60433

NEI30271 481 IVEX Specialty Paper IVEX Packaging Corp. (Peoria Mill) Larry Rohman 1 Sloan St Peoria IL 61643

NEI43703 336 Jackson Paper Manufacturing Co. Jackson Paper Manufacturing Co. (Sylva Mill) Environmental Compliance Manager 152 W Main St Sylva NC 28779

NEITN4715700190 453 K.T.G. (USA) L.P. K.T.G. (USA) L.P. (Memphis Mill) Teresa Greene 400 Mahannah Ave Memphis TN 38107-1021

NEI47104 176 KapStone KapStone Kraft Paper Corp. (Roanoke Rapids Mill) Mary Lee Ransmeier 100 Gaston Road Roanoke Rapids NC 27870

NEI41252 151 KapStone KapStone Paper and Packaging Corp. (N. Charleston Mill) Amy Artmeier 5600 Virginia Avenue North Charleston SC 29406-3612

NEI6285 420 Katahdin Paper Co. Katahdin Paper Co. (East Millinocket Mill) Bruce Albert 50 Main St. East Millinocket ME 04430

NEIWI1398260 702 Kimberly-Clark Kimberly-Clark Corp., West Office Environmental Compliance Manager 2100 COUNTY ROAD II Neenah WI 54956

NEISCT$3616 446 Kimberly-Clark Corp. Kimberly-Clark Corp. (Beech Island Mill) Environmental Compliance Manager 1420 Sanddarfary Rd Beech Island SC 29841

NEI7319 442 Kimberly-Clark Corp. Kimberly-Clark Corp. (Chester Mill) Environmental Compliance Manager Front Street and One Avenue of the States Chester PA 19013

NEI42385 158 Kimberly-Clark Corp. Kimberly-Clark Corp. (Everett Mill) Robert Waddel 2600 Federal Ave Everett WA 98201

NEICA0592137 450 Kimberly-Clark Corp. Kimberly-Clark Corp. (Fullerton Mill) Environmental Compliance Manager 2001 E Orangethorge Av Fullerton CA 92831

NEIOK1431855 437 Kimberly-Clark Corp. Kimberly-Clark Corp. (Jenks Mill) Environmental Compliance Manager 13252 S Yale Pl Jenks OK 74037-3000

NEITN1050093 435 Kimberly-Clark Corp. Kimberly-Clark Corp. (Loudon Mill) Environmental Compliance Manager 5600 Kimberly Way Loudon TN 37774

NEIWI4380391 440 Kimberly-Clark Corp. Kimberly-Clark Corp. (Marinette Mill) Environmental Compliance Manager 3120 Riverside Ave Marinette WI 54143

NEI18371 434 Kimberly-Clark Corp. Kimberly-Clark Corp. (Mobile Mill) Leanne Strickland 200 Bay Bridge Rd Mobile AL 36610

NEICT0050606 335 Kimberly-Clark Corp. Kimberly-Clark Corp. (New Milford Mill) Environmental Compliance Manager 58 Pickett District Rd New Milford CT 06776

NEIKY807 438 Kimberly-Clark Corp. Kimberly-Clark Corp. (Owensboro Mill) Environmental Compliance Manager 601 innovative Way Owensboro KY 42301

NEI36019 433 Knowlton Technologies, LLC Knowlton Specialty Papers (Watertown Mill) Environmental Compliance Manager 213 Factory St. Watertown NY 13601

NEI2MN141036 333 Liberty Paper Inc. Liberty Paper Inc. (Becker Mill) Jim Swanson 13500 Liberty Ln Becker MN 55308

NEISC2337 332 Lin Pac Inc. US Corrugated, Inc. (Cowpens Mill) Michael McLean 139 Price Farm Rd Cowpens SC 29330

NEI33104 157 Lincoln Paper and Tissue Lincoln Paper and Tissue (Lincoln Mill) Dennis C. McComb 50 Katahdin Ave Lincoln ME 04457

NEI42338 156 Longview Fibre Co. Longview Fibre Paper Co. (Longview Mill) Environmental Compliance Manager 300 Fibre Way Longview WA 98632

No NEI 431 Lydall, Inc. Lydall, Inc. (Green Island Mill) Environmental Compliance Manager 68 George St Green Island NY 12183

NEINH01703867LYDLLCH 432 Lydall, Inc. Lydall, Inc. (Rochester Mill) Xiangping Shen 134 Chestnut Hill Road Rochester NH 03867-5182

NEIIL12731 416 Madison Paper Co. Myllykoski North America (Madison Paper, Alsip Mill) Environmental Compliance Manager 13101 S. Pulaski Rd. Alsip IL 60803

NEIME0250002 363 Madison Paper Co. Myllykoski North America (Madison Paper, Madison Mill) Dan Mallett 1 Main Street Madison ME 04950

NEI33986 429 Manistique Papers Inc. Manistique Papers Inc. (Manistique Mill) Mark Ozoga 453 S Mackinac Ave Manistique MI 49854

NEINJ0030015 427 Marcal Paper Mills, Inc. Marcal Paper Mills, LLC (Elmwood Park Mill) Ed Knapick 1 Market St Elmwood Park NJ 07407

NEI2NYT14938 426 MeadWestvaco MeadWestvaco (Cedar Mill) Joel Behm 547A Sissonville Rd Potsdam NY 13676
Survey NEI RTI ID Company Name Mill Name Mill Contact Name Mill Address Mill City Mill State Mill Zip

NEI759 146 MeadWestvaco MeadWestvaco (Covington Mill) T.G. Botkins 104 E Riverside St Covington VA 24426

NEI6450 147 MeadWestvaco MeadWestvaco (Evadale Mill) Brett Tremblay 1913 FM 105 Evadale TX 77615

NEI46931 148 MeadWestvaco MeadWestvaco (Mahrt Mill) Pam Bohneny Hwy 165 S Cottonton AL 36851

NEI11940 144 Menasha Corporation Otsego Paper Inc. (Otsego Mill) Environmental Compliance Manager 320 N Farmer St Otsego MI 49078

NEI33950 423 Menominee Paper Co. / Cellu Tissue Menominee Paper Co. / Cellu Tissue (Menominee Mill) Kevin French 144 First St Menominee MI 49858

NEIPA04141-1 532 MH Technologies LLC MH Technologies LLC (Mount Holly Springs Mill) Environmental Compliance Manager Box C, 1 Mountain St Mount Holly Springs PA 17065-0240

No NEI 415 Mississippi River Corp. Mississippi River Corp. (Natchez Mill) Tanya Richardson 30 Majorca Rd. Natchez MS 39121-0727

No NEI 328 Mobile Paperboard Corp. Mobile Paperboard Corp. (Mobile Mill) Leone Everett 701 Mobile St Mobile AL 36617

NEIOHT$6401 502 Mohawk Paper Mills, Inc. Mohawk Fine Papers Inc. (Beckett Mill) Environmental Compliance Manager 400 Dayton St Hamilton OH 45011

No NEI 407 Mohawk Paper Mills, Inc. Mohawk Fine Papers Inc. (Cohoes Mill) George Milner 465 Saratoga St Cohoes NY 12047

No NEI 406 Mohawk Paper Mills, Inc. Mohawk Fine Papers Inc. (Waterford Mill) George Milner 1 O'Connor Drive Waterford NY 12188

NEINH15855 405 Monadnock Paper Mills, Inc. Monadnock Paper Mills, Inc. (Bennington Mill) Environmental Compliance Manager 117 Antrim Rd Bennington NH 03442-4205

NEI18330 533 National Gypsum Co. National Gypsum Co. (Anniston Mill) Environmental Compliance Manager 4811 US Hwy 78 W Oxford AL 36203

NEI2NJ51607 321 National Gypsum Co. National Gypsum Co. (Delair Mill) Environmental Compliance Manager 175 Derousse Ave Delair NJ 08110

NEIPA11904-1 325 National Gypsum Co. National Gypsum Co. (Milton Plant) Environmental Compliance Manager 2586 Old Route 15 New Columbia PA 17856

NEI2OKT17614 326 National Gypsum Co. National Gypsum Co. (Pryor Mill) Environmental Compliance Manager 4189 Hunt St Pryor OK 74361

NEIWI0879100 459 Neenah Paper, Inc. Neenah Paper, Inc. (Appleton Mill) Dave Linden 600 South Vulcan St Appleton WI 54915

NEI33866 403 Neenah Paper, Inc. Neenah Paper, Inc. (Munising Mill) Howard Piotrowski 501 E Munising Ave Munising MI 49862

NEIWI4710310 404 Neenah Paper, Inc. Neenah Paper, Inc. (Neenah Mill) Steven E. Hagglund 135 N Commercial St Neenah WI 54956

NEICA0991982 456 Neenah Paper, Inc. Neenah Paper, Inc. (Ripon Mill) Environmental Compliance Manager 942 S. Stockton Ave. Rippon CA 95354

NEIWI0978930 402 Neenah Paper, Inc. Neenah Paper, Inc. (Whiting Mill) John Kohler 3243 Whiting Rd Stevens Point WI 54481-6300

NEI20683 323 Newark Pacific Paperboard Corp. Newark Pacific Paperboard Corp. (Los Angeles Mill) Environmental Compliance Manager 6001 S Eastern Ave Los Angeles CA 90040

NEIPA1013489 322 Newman & Co., Inc. Newman & Co., Inc. (Philadelphia Mill) Henry Ligier 6101 Tacony St Philadelphia PA 19135

NEIMN14904 368611 NewPage Corporation NewPage Corp. (Duluth Paper and Recycled Pulp Mills) Diane Gobin, Environmental Manager 100 N. Central Ave. Duluth MN 55807

NEIWI7500086 & 

NEIWIT$8597 224 NewPage Corporation NewPage Corp. Stevens Point Mill & Water Renewal Center Karen Rozumalski 707 Arlington Place Stevens Point WI 54481

NEI42961 223 NewPage Corporation NewPage Corporation (Biron Mill) Shane Adam 621 N Biron Dr Wisconsin Rapids WI 54494

NEI33883 155 NewPage Corporation NewPage Corporation (Escanaba Mill) Todd Schmidt 7100 County Rd 426, M.5 Rd Escanaba MI 49829

NEI33135 & NEI706 145 NewPage Corporation NewPage Corporation (Luke Mill) Ron Paugh 300 Pratt St Luke MD 21540

NEI6273 150 NewPage Corporation NewPage Corporation (Rumford Mill) Scott Reed 35 Hartford St Rumford ME 04276

NEI11338 152 NewPage Corporation NewPage Corporation (Wickliffe Mill) Scott Kirkpatrick 1724 Fort Jefferson Hill Road Wickliffe KY 42087

NEI42963, NEI46739, and 

NEIWI7720116 154 NewPage Corporation NewPage WI Rapids Pulp & Paper Mill, Recycle Paper Mill, and Water Quality Center Jason Lindquist 950 4th Avenue North Wisconsin Rapids WI 54495

No NEI 614 Newton Falls Fine Papers Company, LLC Newton Falls Fine Papers Company (St. Lawrence Mill) Scott Travers 875 Route 60 Newton Falls NY 13666

NEI42329 414 Nippon Paper Industries USA Co., Ltd. Nippon Paper Industries USA Co., Ltd. (Port Angeles Mill) Environmental Compliance Manager 1902 Marine Dr. Port Angeles WA 98362

No NEI 320 Norampac Industries Inc. Norampac Industries Inc. (Niagara Falls Mill) Environmental Compliance Manager 4001 Packard Road Niagara Falls NY 14303-2297

NEI42341B 371 North Pacific Paper Corp. (Norpac) North Pacific Paper Corp. (Norpac) (Longview Mill) Environmental Compliance Manager 3001 Industrial Way Longview WA 98632

NEIDE0030018 401 NVF Co. NVF Co. (Yorklyn Mill) Environmental Compliance Manager 1166 Yorklyn Road (Marshall Bros Mill) Yorklyn DE 19736

NEIWI4430444 534 Oconto Falls Tissue, Inc. ST Paper, LLC (Oconto Falls Mill) Environmental Compliance Manager 106 E Central Avenue Oconto Falls WI 54154

NEI40424 319 Ohio Paperboard Corp. Ohio Paperboard Corp. (Baltimore Board Mill) Kevin McMunn 310 Water St Baltimore OH 43105-1272

NEIMA10626 425 Onyx Specialty Paper MeadWestvaco (Willow Mill) Environmental Compliance Manager 40 Willow St South Lee MA 01260

NEI2TX25731 347 Orance County Container Group, LLC Orange County Container Group, LLC (Forney Mill) Dave Nelson 855 E Hwy 80 Forney TX 75126

No NEI 400 Orchids Paper Products Co. Orchids Paper Products Co. (Pryor Mill) Environmental Compliance Manager 4826 Hunt Street Pryor OK 74361

NEI21111 318 PABCO Paper PABCO Paper (Vernon Mill) Mark Wasson 4460 Pacific Blvd Vernon CA 90058-2206

NEI41552 142 Packaging Corp. of America Packaging Corp. of America (Counce Mill) Environmental Compliance Manager 6715 Hwy 57 Counce TN 38326

NEI33945 247 Packaging Corp. of America Packaging Corp. of America (Filer City Mill) Environmental Compliance Manager 2246 UDELL ST. FILER CITY MI 49634

NEI46750 141 Packaging Corp. of America Packaging Corp. of America (Tomahawk Mill) Environmental Compliance Manager N9090 County Road E Tomahawk WI 54487

NEI26504 143 Packaging Corp. of America Packaging Corp. of America (Valdosta Mill) Environmental Compliance Manager 5495 Lake Park Road Clyattville GA 31601

NEI40720 290 PaperWorks Industries, Inc. PaperWorks Industries, Inc. (Philadelphia Mill) Joe Atkinson 5000 Flat Rock Rd Philadelphia PA 19127

No NEI 291 PaperWorks Industries, Inc. PaperWorks Industries, Inc. (Wabash Mill) Sam Atwood 455 W Factory St Wabash IN 46992

NEI2WAT18798 370 Ponderay Newsprint Co. Ponderay Newsprint Co. (Usk Mill) Environmental Compliance Manager 422767 State Hwy 20 Usk WA 99180-9771

NEI13340 140 Pope & Talbot Inc. Pope & Talbot Inc. Lisa Scott 30480 American Dr Halsey OR 97348

NEI42357 139 Port Townsend Paper Corp. Port Townsend Paper Corp. (Port Townsend Mill) Environmental Compliance Manager 100 Mill Rd Port Townsend WA 98368

NEI18652 138 Potlatch Corp. Potlatch Corp. (Cypress Bend Mill) Environmental Compliance Manager 5082 Highway 4 North Arkansas City AR 71630

NEI26581 137 Potlatch Corp. Potlatch Corp. (Idaho Pulp & Paperboard) Environmental Compliance Manager 803 Mill Rd Lewiston ID 83501

No NEI 394 Potlatch Corp. Potlatch Corp. (Las Vegas Plant) Environmental Compliance Manager 3901 N Donna St North Las Vegas NV 89030

NEI2IDT18063 395 Potlatch Corp. Potlatch Corp. (Lewiston Plant) Environmental Compliance Manager 801 Mill Rd Lewiston ID 83501-0057

NEI2GA247037 261 Pratt Industries Pratt Industries (USA) (Conyers Mill) Randy Clark 1800 A Sarasota Business Parkway Conyers GA 30013

NEI2NY300107 316 Pratt Industries Pratt Industries (USA) (Staten Island Mill) Timothy Tarantino 4435 Victory Blvd Staten Island NY 10314

NEIMO0310053 393 Proctor & Gamble Paper Products Co. P&G Paper Products Co. (Cape Girardeau Mill) Environmental Compliance Manager 14484 State Highway 177 Jackson MO 63755-8323

NEI26487 391 Proctor & Gamble Paper Products Co. P&G Paper Products Co. (Albany Mill) Jesse Edgar 512 Liberty Expy SE Albany GA 31705-5958
Survey NEI RTI ID Company Name Mill Name Mill Contact Name Mill Address Mill City Mill State Mill Zip

NEI42499 390 Proctor & Gamble Paper Products Co. P&G Paper Products Co. (Fox River Plant) Environmental Compliance Manager 501 Eastman Ave Green Bay WI 54302

NEI40738 389 Proctor & Gamble Paper Products Co. P&G Paper Products Co. (Mehoopany Mill) Alex Fried Rte 87 Mehoopany PA 18629

NEI26054 392 Proctor & Gamble Paper Products Co. P&G Paper Products Co. (Oxnard Mill) Environmental Compliance Manager 800 N Rice Ave Oxnard CA 93030

NEIVT02511 412 Putney Paper Co. Inc. Putney Paper Co. Inc. (Putney Mill) Environmental Compliance Manager 67 Kathan Meadow Road Putney VT 05346

NEI2CT1503 314 Rand Whitney Containerboard Rand Whitney Containerboard (Montville Mill) Paul Schaffmen 370 Route 163 Montville CT 06353

NEI26382 241 Rayonier Inc. Rayonier Inc. (Fernandina Mill) Environmental Compliance Manager 10 Gum Street Fernandina Beach FL 32034-4280

NEI26526 240 Rayonier Inc. Rayonier Inc. (Jesup Mill) Deborah Oder 4470 Savannah Highway Jesup GA 31545-5275

NEI33103 183 Red Shield Environmental Red Shield Environmental Environmental Compliance Manager 24 Portland St Old Town ME 04468

No NEI 311 Republic Paperboard Co. Republic Paperboard Co. LLC (Lawton Mill) Lisa McGregor 8801 S.W. Lee Blvd. Lawton OK 73505

NEIIL0898531 607 Rock-Tenn Co. Rock-Tenn Co. (Aurora Mill) Minerva Chiari 1601 East Mountain St Aurora IL 60505

NEIMIB4072 299 Rock-Tenn Co. Rock-Tenn Co. (Battle Creek Mill) Environmental Compliance Manager 177 Angell St Battle Creek MI 49015-1958

NEITN0653455 306 Rock-Tenn Co. Rock-Tenn Co. (Chattanooga Mill) Jim Grantham 701 Manufactures Road Chattanooga TN 37405

NEI11610 301 Rock-Tenn Co. Rock-Tenn Co. (Cincinnati Mill) Environmental Compliance Manager 3347 Madison Rd Cincinnati OH 45209

NEITXT$11223 298 Rock-Tenn Co. Rock-Tenn Co. (Dallas Mill) Environmental Compliance Manager 1120 E Clarendon Dr Dallas TX 75203

NEI45474 179 Rock-Tenn Co. Rock-Tenn Co. (Demopolis Mill) Environmental Compliance Manager 28270 US Hwy 80 W Demopolis AL 36732-5121

NEIIN380 308 Rock-Tenn Co. Rock-Tenn Co. (Eaton Mill) Environmental Compliance Manager 800A S Romy St Eaton IN 47338

NEI42153 303 Rock-Tenn Co. Rock-Tenn Co. (Missisquoi Mill) Environmental Compliance Manager 369 Mill Street Sheldon Springs VT 05485

NEI12322 300 Rock-Tenn Co. Rock-Tenn Co. (Saint Paul Mill) Environmental Compliance Manager 2250 Wabash Ave Saint Paul MN 55114

NEI2PA890018 307 Rock-Tenn Co. Rock-Tenn Co. (Stroudsbourg Mill) Environmental Compliance Manager Paper Mill Rd Delaware Water Gap PA 18327

No NEI 286 Rock-Tenn Co. Rock-Tenn Co. (Syracuse Mill) Steve VanDoren 53 Industrial Drive Syracuse NY 13204-1035

NEI12368 136 Sappi Fine Paper North America Sappi Fine Paper North America (Cloquet Mill) Rob Schilling 2201 Avenue B Cloquet MN 55720

NEI33118 135 Sappi Fine Paper North America Sappi Fine Paper North America (Somerset Mill) Tom Griffin 1329 Waterville Road Skowhegan ME 04976

NEI33072 387 Sappi Fine Paper North America Sappi Fine Paper North America (Westbrook Mill) Tom Howard 89 Cumberland Street Westbrook ME 04092-3592

NEIAL0330055 381 SCA Tissue North America, L.L.C. SCA Tissue North America, L.L.C. (Barton Mill) Robin Wood 1834 Haley Drive Cherokee AL 35616

No NEI 380 SCA Tissue North America, L.L.C. SCA Tissue North America, L.L.C. (Encore Paper) Environmental Compliance Manager 1 River St South Glens Falls NY 12803

NEI2AZ052204 383 SCA Tissue North America, L.L.C. SCA Tissue North America, L.L.C. (Flagstaff Mill) Don Uhles 1600 E Butler Ave Flagstaff AZ 86001

NEIWI4710355 382 SCA Tissue North America, L.L.C. SCA Tissue North America, L.L.C. (Menasha Mill) Environmental Compliance Manager 190 3rd Street Menasha WI 54952-3072

NEINY021R021 379 Schweitzer-Mauduit International Inc. Schweitzer-Mauduit International Inc. (Ancram Mill) Environmental Compliance Manager 2424 Rte 82 Ancram NY 12502-0010

NEI45187 237 Schweitzer-Mauduit International Inc. Schweitzer-Mauduit International Inc. (Spotswood Mill) Hal Bernstein 85 Main St. Spotswood NJ 08884

NEI44800 378 Sealed Air Corp. Sealed Air Corp. (Lenoir Mill) Environmental Compliance Manager 2075 NW Valway Rd Lenoir NC 28645

NEIPA02922-1 377 Sealed Air Corp. Sealed Air Corp. (Modena Mill) George Alexcovich 22 Meredith CT Modena PA 19358

NEIPA01167-2 386 Sealed Air Corp. Sealed Air Corp. (Reading Mill) Environmental Compliance Manager 450 Riverfront Dr Reading PA 19602

NEIMA0270035 376 Seaman Paper Co. of MA, Inc. Seaman Paper Co. of Massachusetts, Inc. (Otter River Mill) George Jones III 51 Main St Baldwinville MA 01436

NEI161 297 Seven Hills Paperboard, LLC Seven Hills Paperboard, LLC (Lynchburg Mill) Environmental Compliance Manager 1801 Concord Turnpike-Lower Basin Lynchburgh VA 24504-0980

NEIWV0490043 454 SFK SFK Pulp Recycling USA Inc. (Fairmont Mill) Michael Runner 702 AFR Dr. Fairmont WV 26554

NEIMIN3929 424 SFK SFK Pulp Recycling USA Inc. (Menominee Mill) Environmental Compliance Manager 701 Fourth Ave. Menominee MI 49858-0277

NEI42800 375 Shawano Specialty Papers Shawano Specialty Papers Mark Bosin W7575 Poplar Road Shawano WI 54166

NEI13363 133 Simpson Tacoma Kraft Co Simpson Tacoma Kraft Co. (Tacoma Mill) Environmental Compliance Manager 801 Portland Ave Tacoma WA 98421

NEI11600 373 Smart Papers L.L.C. Smart Papers L.L.C. (Hamilton Mill) Environmental Compliance Manager 601 North B St Hamilton OH 45013

NEIMA177072 372 Smurfit Munksjo Paper Inc. Munksjö Paper Decor Inc. (Fitchburg Mill) Environmental Compliance Manager 642 River St Fitchburg MA 01420

NEI11461 128 Smurfit-Stone Container Corp. Smurfit-Stone Container Corp. (Coshocton Mill) Environmental Compliance Manager 500 N 4th St Coshocton OH 43812

NEI8261 132 Smurfit-Stone Container Corp. Smurfit-Stone Container Corp. (Fernandina Beach Mill) Environmental Compliance Manager N. 8th Street Fernandina Beach FL 32034

NEI7933 127 Smurfit-Stone Container Corp. Smurfit-Stone Container Corp. (Florence Mill) Environmental Compliance Manager 2202 Paper Mill Road Florence SC 29506

NEI33023 226 Smurfit-Stone Container Corp. Smurfit-Stone Container Corp. (Hodge Mill) Environmental Compliance Manager Mill Street Hodge LA 71247

NEI42317 126 Smurfit-Stone Container Corp. Smurfit-Stone Container Corp. (Hopewell Mill) Environmental Compliance Manager 910 Industrial St Hopewell VA 23860

NEI8278 124 Smurfit-Stone Container Corp. Smurfit-Stone Container Corp. (Panama City Mill) Environmental Compliance Manager One Everitt Avenue Panama City FL 70791

NEI26304 289 Smurfit-Stone Container Corp. Smurfit-Stone Container Corp. (Seminole Mill) Michele Rundlett 9469 Eastport Rd Jacksonville FL 32218

NEI18347 245 Smurfit-Stone Container Corp. Smurfit-Stone Container Corp. (Stevenson Mill) Environmental Compliance Manager 1611 County Rd. 85 Stevenson AL 35772-0908

NEI42254 131 Smurfit-Stone Container Corp. Smurfit-Stone Container Corp. (West Point Mill) Environmental Compliance Manager 19th and Main Street West Point VA 23181

NEI21319 284 Sonoco Products Co. Sonoco Products Co. (City of Industry Mill) Environmental Compliance Manager 166 N Baldwin Park Blvd City of Industry CA 91746

NEI43472 244 Sonoco Products Co. Sonoco Products Co. (Hartsville Mill) Peggi Davis 1 North 2nd Street Hartsville SC 29550-3305

No NEI 282 Sonoco Products Co. Sonoco Products Co. (Holyoke Mill) Environmental Compliance Manager 200 S Water St Holyoke MA 01040

NEIKS1550063 285 Sonoco Products Co. Sonoco Products Co. (Hutchinson Mill) Environmental Compliance Manager 100 N Halstead Hutchinson KS 67504

NEI40425 281 Sonoco Products Co. Sonoco Products Co. (Lancaster Mill) Environmental Compliance Manager 831 S Memorial Dr Lancaster OH 43130-4370

NEIWI4710312 276 Sonoco Products Co. Sonoco Products Co. (Menasha Mill) Environmental Compliance Manager 69 Washington St Menasha WI 54952

NEITN0290020 361 Sonoco Products Co. Sonoco Products Co. (Newport Mill) Environmental Compliance Manager 766 Industrial Rd Newport TN 37821

NEI42322 279 Sonoco Products Co. Sonoco Products Co. (Richmond Mill) Andy Cibels 1850 Commerce Rd Richmond VA 23224

No NEI 278 Sonoco Products Co. Sonoco Products Co. (Sumner Mill) Environmental Compliance Manager 1802 Steele Avenue Sumner WA 98390-1606

NEI45735 236 Southern Cellulose Products Inc. Southern Cellulose Products Inc. (Chattanooga Mill) Randall Burris 103 W. 45th St. Chattanooga TN 37409

NEIGAT$3911 369 SP Newsprint Co. SP Newsprint Co. (Dublin Mill) Environmental Compliance Manager 677 Papermill Road East Dublin GA 31027

NEI40648 410 SP Newsprint Co. SP Newsprint Co. (Newberg Mill) Environmental Compliance Manager 1301 Wynooski St. Newberg OR 97132
Survey NEI RTI ID Company Name Mill Name Mill Contact Name Mill Address Mill City Mill State Mill Zip

NEICA0370338 604 Specialty Paper Mills Inc. Specialty Paper Mills Inc. (Santa Fe Springs Mill) Lorenzo Apostol 8834 S. Millergrove Dr Santa Fe Springs CA 90670-0188

NEIWI1414250 536 Stora Enso North America Corp. Corenso North America (Wisconsin Rapids Mill) Jason Lemke 800 Fremont Street Wisconsin Rapids WI 54495-8050

NEI2WAT18765 274 Tacoma Paperboard Tacoma Paperboard (Tacoma Mill) Kyle Ricks 808 E 26th St Tacoma WA 98421

NEI2IA17186 273 Tama Paperboard Tama Paperboard (Tama Mill) Environmental Compliance Manager 117 Siegel St Tama IA 52339

NEI2INT16350 315 Temple-Inland Temple Inland-Newport Mill Chris Kull 2585 E 200 North Cayuga IN 47928

NEIMA0130152 222 Texon USA Texon USA Mark Reardon 1190 Huntington Rd Russell MA 01071

NEI42710 164 Thilmany Papers, LLC Thilmany Papers, LLC (Kaukauna Mill) Tom Jayne 600 Thilmany Rd Kaukauna WI 54130

NEI42495 500 Thilmany Papers, LLC Thilmany Papers, LLC (Nicolet Mill) Kent Hubbard 200 Main Ave De Pere WI 54115

NEI46814 119 TIN Inc., dba Temple-Inland Temple-Inland (Bogalusa Mill) Alban Bush, Environmental Manager 401 Avenue U Bogalusa LA 70427

NEIKY1030 271 TIN Inc., dba Temple-Inland Temple-Inland (Maysville Mill) Melissa Wiegand, Technical & Environmental Manager 1241 W Second St Maysville KY 41056

NEI46866 122 TIN Inc., dba Temple-Inland Temple-Inland (New Johnsonville Mill) Mike Goodman, Environmental Manager 2877 Scepter Road Waverly TN 37185

NEICA0712460 272 TIN Inc., dba Temple-Inland Temple-Inland (Ontario Mill) Steve Delaney, Technical & Environmental Manager 5100 E Jarupa St Ontario CA 91761

NEI12492 121 TIN Inc., dba Temple-Inland Temple-Inland (Orange Mill) John Melancon, Environmental Manager 1750 Inland Rd Orange TX 77632

NEI26495 120 TIN Inc., dba Temple-Inland Temple-Inland (Rome Linerboard Mill) Russ Foulke, Environmental Manager 238 Mays Bridge Road Southwest Rome GA 30165-8116

NEIME0030002 529 Twin Rivers Paper Twin Rivers Paper (Madawaska Mill) Eric Carrier 82 Bridge Ave. Madawaska ME 04756

No NEI 220 Unicell Paper Mills Inc. Roses Southeastern Paper Inc. (Sanford Mill) Alvaro Virgen 3401 St. Johns Parkway Sanford FL 32771

NEI2NJ41642 265 United States Gypsum Co. United States Gypsum Co. (Clark Mill) Environmental Compliance Manager 1255 Raritan Rd Clark NJ 07066

NEITX201762F 268 United States Gypsum Co. United States Gypsum Co. (Galena Park Mill) Environmental Compliance Manager 1201 Mayo Shell Rd Galena Park TX 77547

NEIMO0470007 266 United States Gypsum Co. United States Gypsum Co. (North Kansas City Mill) Chris Hansen 1115 Armour Rd North Kansas City MO 64116-3783

NEINY8183800 264 United States Gypsum Co. United States Gypsum Co. (Oakfield Mill) Ray Tamblin 2750 Maple Avenue Oakfield NY 14125

NEI34030 118 UPM, Blandin Paper Co. UPM, Blandin (Grand Rapids Mill) Nathan Waech 115 First Street, SW Grand Rapids MN 55744-3699

NEIWI0092110 277 US Paper Mills Corp US Paper Mills Corp Mark Velicer 824 Fort Howard Ave De Pere WI 54115-5850

No NEI 262 Valley Converting Co. Valley Converting Co. (Toronto Mill) Mike Biasi 405 Daniels St Toronto OH 43964

NEI6261 610 Verso Paper Corp. Verso Paper Corp. (Androscoggin Mill) Environmental Compliance Manager 300 Riley Road Jay ME 04239

NEI6284 230 Verso Paper Corp. Verso Paper Corp. (Bucksport Mill) Environmental Compliance Manager 2 River Rd. Bucksport ME 04416

NEI33887 177 Verso Paper Corp. Verso Paper Corp. (Quinnesec Mill) Jeff Maule W6791 Us Highway 2 Quinnesec MI 49876

NEI12407 229 Verso Paper Corp. Verso Paper Corp. (Sartell Mill) Environmental Compliance Manager 100 E. Sartell St. Sartell MN 56377

No NEI 417 Von Drehle Corp. Von Drehle Corp. (Cordova Mill) Todd Robinson 126 1st St. Cordova NC 28330

NEI34020 213 Wausau Paper Wausau Paper (Brainerd Mill) Pierre Comeau 1801 Mill Ave NE Brainerd MN 56401

NEI42690 215 Wausau Paper Wausau Paper (Brokaw Mill) Steve J. Lewens 202 2nd Street Brokaw WI 54417

NEI42689 117 Wausau Paper Wausau Paper (Mosinee Mill) Environmental Compliance Manager 100 Main St. Mosinee WI 54455

NEI43202 216 Wausau Paper Wausau Paper (Rhinelander Mill) Tom Emond 515 W Davenport St Rhinelander WI 54501

NEIOH0170043 449 Wausau Paper Wausau Paper Towel & Tissue, LLC (Middletown Mill) Denise Curry 700 Columbia Ave. Middletown OH 45042

NEI46992 212 West Linn Paper Co. West Linn Paper Co. (West Linn Mill) Penny Machinski 4800 Mill St West Linn OR 97068

NEI34064 112 Weyerhaeuser Co. Weyerhaeuser Co. (Columbus Mill) Chris Ford 4335 Carson Rd, Hwy 792 Columbus MS 39701

NEI26506 114 Weyerhaeuser Co. Weyerhaeuser Co. (Flint River Mill) Jay Son 2449 Stagecoach Rd Oglethorpe GA 31068

NEI42341A 102 Weyerhaeuser Co. Weyerhaeuser Co. (Longview Mill) Environmental Compliance Manager 3401 Industrial Way Longview WA 98632

NEI45206 111 Weyerhaeuser Co. Weyerhaeuser Co. (New Bern Mill) Roy Brinson 1785 Weyerhaeuser Road Vanceboro NC 28586

NEI26476 115 Weyerhaeuser Co. Weyerhaeuser Co. (Port Wentworth Mill) Chris Blocker 1 Bonnybridge Rd. Port Wentworth GA 31407

NEIMIB2024 258 White Pigeon Paper Co. White Pigeon Paper Co. (White Pigeon Mill) Environmental Compliance Manager 15781 River St White Pigeon MI 49099

NEICT8601 211 Windsor-Stevens Inc. Windsor-Stevens Inc. (Poquonock Mill) Environmental Compliance Manager 99 Stevens Mill Rd. Windsor CT 06064

NEIWI0793640 254 Wisconsin Paperboard Corp. Wisconsin Paperboard Corp. (Milwaukee Mill) Environmental Compliance Manager 1514 E Thomas Ave. Milwaukee WI 53211-4397

NEI46835 195 Woodland Pulp LLC Woodland Pulp LLC (Woodland Mill) C. Scott Beal 144 Main St Baileyville ME 04694

NEIPA13322-2 246 Yorktowne Paperboard Corp. Yorktowne Paperboard Corp. (Newark Yorktowne Mill) Bill Deats 1001 Loucks Mill Rd York PA 17402