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### 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 com plete 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 s ubpart BB new source performance standards ( NSPS ) and will be due by March 17, 2011.

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

June 6, 2011. Part III requests information on chemi cal recovery combustion sources add ressed

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

, emission s data ( in the form of emissions test re ports 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 p reparation 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 (“tab s” within the spreadsheet file). In addition to the survey forms, Enclosure 1 also

contains specific i nstructions for each part of the survey to assist you in comp l eting your

r esponse 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/pap erboard mills that are a major

source 1 

### or synthetic area source 2 

### of 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 sourc e” 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. (C ontact 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 pursua nt to CAA s ections 111(b)(1)(B), 112(d)(6)

, and 112(f)(2) with respect to the pulp and paper production source category. O n February 23, 1978 , t he 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 o n May 20, 1986 , and a nother review of the kraft pulp mill N SPS is required under the

CAA. The EPA issued NE SHAP for the pulp and paper indus try (40 CFR part 63, subpart S) o n April 15, 1998, and for chemical recovery combustion sources at kraft, soda, sulfite, and stand

al one semichemical pulp mills (40 CFR part 63, subpart MM) on January 12, 2001 , under the

au thority of section 112 of the CAA. As required under CAA s ection 112(d)(6)

, EPA must
review

, and , if appropriate, revise existing NESHAP, taking into account developments in practices, processes, and control technol ogies. 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 r equired 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 obligation s u nder CAA section s 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 station ary 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

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

### 3

technology review of the subpart S and subpart MM NESHAP. Emi ssions 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 E PA has entered into a proposed consent d ecree

— 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

t he 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 NESH AP 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

surve y is contained in s ection 114 of the CAA, as amended (42 U.S.C. §7414). Enclo sure 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 o n 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 tr ade secret under EPA’s CBI regula tions at

40 CFR part 2, subpart B, will be protected pursuant to those regulations and, for tra de 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 pursua nt to EPA regulations at 40 CFR 2.203.

Because CAA sectio n 114(c) exempts emission s data from claims of confidentiality, the

emission s data you provide will be made available to the pub lic notwithstanding any claims of

### 4

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

Enclosure 3.

What is RTI’ s Role ?

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

, to
condu ct 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 ha s the same rights

d iscussed 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 c ontractors 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 inst ruction 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 confide ntial

and non

- confidential survey responses. Pre

- printed r eturn 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

- confiden tial 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?

E ach part of the pulp and paper sector survey has a different due date, as specifie d 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, 2011 1,2



### II NEI Update June 6 , 2011 1



### III Chemical Recovery Combustion Sources August 24, 2011 1

1. Postmark ed 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) mil ls.

### 5

Who Do I Contact With Questions?

If you have questions regarding this information request you may:

 Contact Mr. Bill Sc hrock (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.o rg

 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 aft er 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 ap preciated.

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 info rmation 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 fo r 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 liste d 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 w ith your completed Part I or Part III response. Pre-printed return mailing labels for Parts I a nd III are also provided for your convenience.Survey Overview Document Form Approved 02/17/2011

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## Pulp and Paper Sector Survey

Overview

Survey coverage. The pulp and paper sector survey is a thr ee-part information request that applies for pulp and/or paper/paperboard mills that are a majo r 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., thermome chanical 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 em its 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 h azardous 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 s ource, but was not operational in 2009 (and remains closed) or does not produce pulp, perform bleaching, or manufacture paper or pa perboard products, then you should complete the form in Attachment 1 a nd email (or fax) it to Bill Schrock of EPA at schrock.bill@epa.gov explaining the status of your mill. You ar e 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-operati onal 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 a pplies for major and synthetic area source mills operating chemical recovery combustion sources. Part s I and III request process data for the emissions

units listed in Attachment 1 of the instructions fo r 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).



### 1Survey Overview Document Form Approved 02/17/2011

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### 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 Deadline 1 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 days 2 -P&P survey_PI.xls -P&P CEMS _PI.xls 3
-P&P costs OPTIONAL_PI.xls -Flow diagrams -Test reports 3
-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, PM 2.5 , TRS, NOx, SO 2 , and CO.



### Please complete the survey for the facility listed in th e Section 114 letter you received in the mail. If you received more than one Section 114 letter for multip le 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 equipmen t configurations, etc.), unless another year is specified in the instructions (e.g ., for emissions test data).

Definitions . For reference, Attachment 2 to this overv iew contains the regulatory definitions from the kraft pulp mill new source performance standards (N SPS) (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 N SPS and NESHAP General

Provisions.

Acronyms/abbreviations . Attachment 3 to this overview cont ains acronyms and abbreviations used throughout the survey instruction do cuments 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, Pa rt 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 instruc tions, 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.aspxSurvey Overview Document Form Approved 02/17/2011

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### 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 list ed above is not a major source or synthetic area source of hazardous air pollutant emissions (HAP) emission s. 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 faci lity listed above was not operational in 2009 (the base year for the pulp and paper sector survey), and that the facility rema ins non-operational (closed). A brief explanation is prov ided 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 pr ovided 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 pr ocess is also considered pa rt 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 compo unds 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 di gester used for the cook ing of wood in white liquor, and associated flash ta nk(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, w ith 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 chemi cals 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 sm elt 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 solid s are fed to the recovery furnace or the

semichemical combustion unit.

Chemical recovery combustion source means any source in the chemical recove ry 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 chem ical 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 cont act between the hot recovery furnace exhaust gases and the strong black liquor.

Direct contact evaporator (DCE) recovery furnace system means a direct contact evap orator recovery furnace and any black liquor oxidation system, if present, at the pulp mill.

Dry electrostatic precipitator (ESP) system means an electrostatic precipitato r 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 tr ansport 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 contai ning 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 fr om 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 bu rn black liquor produced by the kraft pulping process, as well as any recovery furnace that burns bl ack liquor produced from both the kraft and semichemical pulping processes, and includes the dir ect 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 valu e 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 (excl uding 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 evaporato r (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, sm elt dissolving tank, or lime kiln in a chemical recovery system at a kraft or soda mill.

Recovery furnace means an enclosed combustion device where conc entrated 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 h eat 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 pu rpose of chemical recovery. Incl udes 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 no t 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 su ccessful completion of the gasification technology supplier’s performance warranty demonstration, which proves the technology and equipment are performing to warranted le vels 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 (4 0 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 bleac hing stages arranged in series such th at bleaching of the pulp progresses as the pulp moves from one stage to the next.

Bleaching stage means all process equipment associat ed with a discrete step of chem ical application and removal in the bleaching process including chemi cal 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 chemi cals following the pulping system, up to and including the final bleaching

stage.

Boiler means any enclosed combustion device that extracts usef ul 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 fr om 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 oxidati on 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 digest er used for the chemical treatment of wood or non-wood fibers. The digester system equipment includes associated flash ta nk(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 h azardous air pollutants regulat ed under this subpart, including emissions from individual pr ocess 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-ev aporators, multi-effect ev aporators, concentrators, and vacuum systems, as well as associated condense rs, 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 subpar t 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 sy stem 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 sy stem 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 sy stem 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 mechani cal and thermo-mechanical processes to reduce

wood to a fibrous mass. The mechan ical pulping processes include, but are not limited to, stone groundwood, pressurized groundwood, refiner mech anical, thermal refiner mechani cal, 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 determina tions for both the pulping and bleachin g 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 bleachin g system. The oxygen delignification sy stem 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 co mbustion de without the addition of other fuels.

Process wastewater treatment system means a collection of equipment, a proces s, or specific technique that removes or destroys the HAPs in a process wa stewater 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 wash ers, 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 e quipment 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 reco very 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 pr ior to the bleaching system, includi ng 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 conc entrated 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 pu lp 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 additio n 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 co mbines both chemical and m echanical pulpin g 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 condensa tes using steam. The steam stri pper system also contains all equipment associated with a methanol rectification pr ocess 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 mi xture of sulfurous acid and bisulfite ion as the cooking liquor.

Temperature monitoring device means a piece of equipment used to monito r 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 filtr ate 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 th e 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 installa tion 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 compon ents 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 comple te, 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 affect ed source will be construed as reconstr uction if it satisfies the criteria for

reconstruction as defined in this section. The costs of re placing 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 consid ering controls, in the aggreg ate, 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 standa rd, 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 th at would be required to construct a comparable new source; and (2) It is technologically and economically feas ible 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

BOD 5 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

Cl 2 chlorine

ClO 2 chlorine dioxide

Co cobalt

CO carbon monoxide

CO 2 carbon dioxide COMS continuous opacity monitoring system(s)

Cr chromium

CTMP chemi-thermo mechanical 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)

ft 2 square foot (feet) FTP file transfer protocol g gram(s) gal gallon(s) gpm gallon(s) per minute gr grain(s) GW groundwood

H 2 O water

H 2 O 2 hydrogen peroxide

H 2 S 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)

KMNO 4 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 ApplicableSurvey Overview Document Form Approved 02/17/2011

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Na 2 S 2 O 4 sodium hydrosulfite NaClO sodium hypochlorite

NAD North American Dictum

NAICS North American I ndustry 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

NH 3 ammonia

Ni nickel

No. number

NO 2 nitrogen dioxide

NO X nitrogen oxides NSPS new source perfor mance standard(s)

NSSC neutral sulfite semichemical

NV not vented

O 2 oxygen O 3 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

PM 10 PM with an aerodynami c diameter of up to 10 μm

PM 2.5 PM with an aerodynami c 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

SO 2 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 afte r 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 afte r 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 afte r 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/info rmation 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 Intr oduction ........................................................................................................... ................................ 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 de tail ta b ........................................................................................................... ...... 11

c. PI Perm it limits tab ..................................................................................................... ........... 15

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

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

f. Byproduct s ta b ................................................................................................................ ....... 19

g. Kraft conden sates tab ......................................................................................................... ... 19

h. CCA ta b ....................................................................................................................... .......... 20

i. Bleaching tab ................................................................................................................. ........ 21 j. Paper prod tab ................................................................................................................ ........ 22

k. HAP additiv es tab ............................................................................................................. ..... 22

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

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

a. PI Emissions te st data tab .................................................................................................... .. 24

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

D4. Optional co st da ta............................................................................................................. ............... 26

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

PART I - ATTACHMENT 2 Smal l Business Si ze 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 (T MP), 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 st ationary 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 fr om 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 pu lp 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 spread sheet file that is divided into several worksheets (“tabs” within the spreadsheet). You must complete certain tabs of the survey spreadsheet (depen ding 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 fo r the facility listed in the Section 114 lette r 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 th e 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 e ach survey tab. Attachment 2 contains a listing of small

business size standards for North Ameri can Industry Classifica tion System (NAICS) code Subsector 322, Paper Manufacturing. Finally, Attachment 3 of this survey co ntains 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, s ubpart 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 th roughout the survey and asso ciated 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 condensates 2 Mills that perform kraft pulping

CCA 2 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 operati ng emission units for which test data are requested in Attachment 3 to

this document. P&P CEMS_PI.xls

CEMS data 1 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/info rmation 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) accomp anying the pulp and paper information collection request (ICR). If you believe that providing any specific informati on 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 spre adsheet 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 likel y 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 Pa rt 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 you r 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 replaci ng 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, hardcopy 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 mate rials in one envelope to EPA at the address specified below by the specified response deadlin e 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 someon e 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., hi ghlighted or circled). Clearly mark the disk with the words “Confidential Business Information.” Send only thes e 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 th e 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 su pply your Boiler MACT survey ID codes when completing P&P survey_PI.xls.

You will enter data into the white (unshaded) cells of the sp readsheets. 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 no t 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/com bustion 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 ch ests, and pulp storage tanks following the last stage of pulp washing and/or those located prior to the pape r 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 necessa ry 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 digest er “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 prov ide 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) pr ovides EPA with data related to emissions release points (e.g., mass emission rate an d 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 concentr ations). 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: Fac ilityID 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 ex ists (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 mi ll. 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 th e 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 spre adsheet 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 fr om 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 an d 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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### 8 What if I have difficulty pairing emission units wi th 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 thos e instances where we need to link the NEI and Part I/III data). However, we realize that information may be presented in th e 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 ma y 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 Em ission 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 NE I data are unable to match one or more NEI Emission Unit IDs with emissions unit(s) at their mill (using the S CCs 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 (optio nal)” column in the Part I/III Equip detail tabs to clarify any matching discrepancies with the Part II NEI. Thes e notes will assist EPA in analyzing the data and prevent confusion.

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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 comp are 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 thro ughput 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 pi ece 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 provid e 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 a pplicable" is accurate. Further, survey respondents providing an excessive number of responses as “UK or “NA” are likely

to receive scrutin y and follow-u p in q uiries from EPA related to their surve y res p onse.

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 calcu lated 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 operab le 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 machin es 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 machin es instead of utilizati on 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 inform ation for each indi vidual emission unit. The purpose of this tab is to provide EPA with equi pment-specific details needed fo r 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 oxid ation 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 diff erent 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 po ints 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 yo u should list each emission unit separately in the PI Equip detail tab even if the exhaust from the emission uni t is ducted to a common conveyance. For multiple emission units ducted thro ugh a common conveyance to the same release point, list each Emission Unit ID separately and provide the same Collecti on 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 Un it 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 diff erent release points (vents or stacks) have different

controls or different NSPS/NESHAP applicability then you w ill need to list each vent (or group of vents with the same controls) on separate rows. Repeat th e Emission Unit ID on separate rows and distinguish the release points using the “Emission unit description” co lumn 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 re lease (exhaust flow, APCD information and NSPS/NESHAP compliance options) in each row. En ter 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 conveya nce)” 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 (exhau st 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 (v ents or stacks) that are controlled and some that are uncontrolled (or if NSPS/NESHAP app licability 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 separa te 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 (exh aust flow, APCD inform ation and NSPS/NESHAP compliance options) in each row. Enter equipment details (year inst alled, 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 “Configura tion if not emitted thro ugh 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 alte rnate (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 us ed 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) shou ld be used in Part III wh en equipment-specific details are provided for these equipment. (Note that proces s 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) contro ls 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 reques ted 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 give n 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 subpar t 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. Fo r 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 aver age for the parameter. However, if the parameter is only measured periodically, then you may want to pr ovide the most recen t 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 ope rations 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 ther mal 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) curren tly 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 pa per 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 (Facility ID 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 ther mal 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 a nd 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 di rect-fired dryers (e .g., pulp dryers or paper machine dryers). NCG and SOG are not considered to be either pr imary or supplemental fuels for purpos es 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 pr ovide EPA with an understanding of th e 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 ar e asked to supply information for routine startup and shutdown events associated with planned process or m ill 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 purpos es and will not be used for enforcement purposes.

c. PI Permit limits tab

Permit limits for each emission unit/point listed in Attachme nt 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 show n 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 th e 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/for mat for pollutants with multiple limits in different units of measure or formats (e.g., only provide ppmdv and lb/MMBtu at specified % oxygen (O 2 ) for a combustion unit sulfur dioxide (SO 2 ) limit specified in the permit in terms of ppmdv, lb/hr, lb/day, and tpy, lb/MMBtu at specified

% O 2 , etc.). The survey spreadsheet allows for up to five different permit limit format s for the same pollutant.

Permit limits of most interest to EPA are concentration limit s (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 (% O 2 ). Be sure to note if ppm values are on a dry (d) or volume (v) or weight (w) basis if specified this way in 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 ar e those for fuel-fired equi pment 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 pref er 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

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

PM 2.5 1
Opacity % (provide averaging time)

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

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

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

CO lb/MMBtu or ppmdv

Pb or other HAP metals Specify units

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

THC Report as carbon.

RF/combustion units: lb/ton BLS

HCl ppmdv and/or % reduction Methanol and gaseous organic

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

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

1 Specify filterable and/or condensable if your permit 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 distingu ish 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 categ ory. 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 ar e requested for PM, TRS, HCl, SO 2 , and other HAP. This information will be used in determining the capability of different control devices for reducing emissions. If you have data from inlet/outlet emissions testing used to determine a percentage reduction in the requested pollutant across the control device, then you would enter this test re sult as the “actual” control ef ficiency. You may leave the control efficiency columns blank (rathe r 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 c ontrolling 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 st artup, shutdown, and malfunction exem ption 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 m onitoring 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. Th e 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 pulpin g process/line should occupy only one row (e.g., a mill that co-produces kraf t and mechanical pulps should use two rows). Some data fields apply for specific types of pulp (e.g., m echanical 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 understa nd the general mill flow and in estimation of impacts and economic analyses. In the Pulp prod tab, the 2009 pulp capacity (ADT P/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/br ightening line (if applicable)

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

• is used onsite to manufactur e 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 ma y 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 asso ciated 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 st reams (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 coll ected/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/contro lled 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 M ills 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 headin gs III, IV, V, and/or VI) and the question in table heading VII. For example, if your mill normally treats conde nsates with a steam stripper but relie s 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 sy stems. Debit generating sources can include equipment from the kraft mill HVLC system, including: pulp washing systems, knotter systems, screen systems, decker systems, O 2 delignification systems, and weak liquor storag e 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), pleas e 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 us ed to show compliance with the CCA at this time. However, EPA reserv es 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, second ary fiber, or non- wood pulp s 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 se parate 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 fo r the bleaching/brightening emission unit and answer the questions to the left of the orange vertical line (entering “NA” for questio ns that are not applicable.

If your bleaching system includes any stag es that use chlorine or chlorinated compounds, then you must complete the portion of this tab to the right of the orange vertical line. Extractio n 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 th e various bleaching stages, enter not a pplicable “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 particul ar bleaching stage are not r outed 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 m ills according to bleaching processes used, estimate nationwide emissions, and identify subpart S complia nce 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 mach ine (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 pa per 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). S hould EPA consider paper machines for residual risk rulemaking, information such as pulp type, whether the pulp is bleach ed 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 eac h paper machine furnish - sp ecifically the approximate percentage of each pulp type. We recognize that the per centage can vary throughout the operating year and within paper grades (due to specific product variations), and theref ore, 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, napt halene, methylene chloride, acrylamide, or benzene. Only include in this tab additiv es with measurable quantities of HAP as reported on the material safety data sheet (MSDS) for the additive. For pu rposes of this survey, “measurable” is defined consistent with OSHA requirements that chemical suppliers provid e 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 m achine 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 id entify 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 treatme nt 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 ot her 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 inform ation will be used by EPA fo r 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 H 2 S) 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 treatm ent 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, th en 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 pe rcentage of WWTP capacity from various mill areas will inform EPA of the overall nature of the wastewaters gene rated 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 owne d 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 d eadline 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, PM 2.5 , 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 em issions 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 unle ss 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 forprior 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 emissi on 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., datin g 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 repres entative 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 outle t 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 spreads heet (P&P CEMS_PI.xls)

The EPA is requesting existing CEMS data and/or continuo us 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 curren t 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 NS PS 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 (hourl y), Opacity, and other pollutants (NOx, SO 2 , 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 in structions are included on each worksheet. An “EXAMPLE” comp leted 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 recove ry furnaces, smelt dissolving tanks, lime kilns, digester systems, brown stoc k washer systems, multiple effect evaporator systems, and condensate stripper systems subject to the TRS m onitoring 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 aske d 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% O 2 for recovery furnaces and 10% O 2 for lime kilns and other equipment.]

TRS (1-Hour Average) . Same as above, except that this worksh eet 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 fo r 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 aver age 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 prov ide the highest single 6-minut e 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, SO 2 , 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 OPTI ONAL. 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 eas ily 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 rate s, 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 informatio n on a voluntary basis to pe rform 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 sh ould be treated as CBI. Res ponses containing CBI should be submitted according to the instructio ns 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 fro m wastewater handling and treatment systems - Bleach plant CO control devices

The EPA is particularly interested in costs of the followi ng 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 alternat ive 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 estim ate 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 co st included installation of extra buildings, land purchases, etc. that may not be required for other mills).



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### 28 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 “b leaching stage 1” represents all of the emission points associated with that syst em). [Note: Chemical r ecovery 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 associat ed 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)

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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 NA ICS 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 Classifica tion System Codes, Effective August 22, 2008. Accessed June 16, 2009 at: http://www.sba.gov/idc/groups/public/documen ts/sba_homepage/serv_sstd_tablepdf.pdf



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

(Note: Test Reports submitted should be full and complete copies of the emission test re ports, to include field and lab data sheets and example calculations.)Part IForm Approved 02/17/2011OMB Control No. 2060-0656Approval Expires 02/28/2014Part I - Attachment 3. Pulp and Paper Emission Units and Pollutants for Which Existing Representative Emission Test Data Are RequestedNote: Emissions test data representative ofyour current operations are requested asdescribed in the survey instructions. Mills required to complete Part III may postpone until the deadlinefor 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.Emission UnitParticulatematter (PM)1Speciated HAPmetals2PM2.5(fil.)PM2.5(cond.)ChlorinatedHAP (Cl)1Acetaldehyde,Formaldehyde,and Methanol1Totalhydrocarbon(THC) ascarbonTotal reducedsulfur (TRS)1,3Nitrogenoxides(NOx)1Sulfurdioxide(SO2)1Carbonmonoxide(CO)1Test methods4M5, M29,M17PM CEMS,COMSM29EPAOTM 27EPAOTM 28Chlorine (Cl2) viaM26A withmodificationsdescribed insubpart SCl2CEMSMethanol: Method308 (part 63) orMethanol CEMSOther methods(e.g., foracetaldehyde &formaldehyde)M25 or M25AM16(or variantssuch as 16A,16B, 16C) orTRS CEMSProvide totalTRS data. Alsoprovidespeciated TRSdata, ifavailable.M7(or variantssuch as 7E)CEMSM6(or variantssuch as 6C)CEMSM10CEMSThermal oxidizerscontrolling Part Iemission sourcesSupply mostrecent dataNot requestedSupplymost recentdataDigesters, Pulpwashers,Evaporators,Turpentine recovery,Strippers, O2delignification,Knotters andscreens, Deckers(high densitystorage), and Weakand strong liquorstorage tanks (ortheir associatedLVHC and/or HVLCcollection systems)Not requestedSupply most recentdata followingMACT complianceSupply mostrecent datafollowingMACTcomplianceNotrequestedSulfite pulpingsourcesNot requestedSupply most recentdata followingMACT complianceSupply mostrecent dataNot requested32Part IForm Approved 02/17/2011OMB Control No. 2060-0656Approval Expires 02/28/201433Emission Unit Particulatematter (PM)1Speciated HAPmetals2PM2.5(fil.)PM2.5(cond.)ChlorinatedHAP (Cl)1Acetaldehyde,Formaldehyde,and Methanol1Totalhydrocarbon(THC) ascarbonTotal reducedsulfur (TRS)1,3Nitrogenoxides(NOx)1Sulfurdioxide(SO2)1Carbonmonoxide(CO)1Wastewatertreatment systemsNot requestedSupply most recentmodeling ormeasurement data(as requested inWWtab)Supply mostrecent modelingor measurementdata (asrequested inWWtab)NotrequestedBleaching systemssubject to subpart SNot requestedSupply mostrecent datafollowing MACTcomplianceSupply mostrecent datafollowingMACTcompliancePaper machineemission pointsNot requestedSupply most recentdataCausticizing areasourcesNot requestedSupply mostrecent dataStand alonesemichemical,mechanical,nonwood, andsecondary fiberpulpingNot requestedSupply mostrecent data1If your emission unit is equipped with a continuous emissions monitoringsystem (CEMS) or continuous opacity monitoring system(COMS), supply the CEMS and COMS data using the CEMS dataspreadsheet (P&P CEMS_PI.xls). Synthetic area sources should supply the most recent data (if data are available).2The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chromium VI (Cr+6) and speciated mercury (Hg) test data ifavailable.3Speciated TRS would include: hydrogen sulfide (H2S), methyl mercaptan, dimethyl sulfide, and dimethyl disulfide.4M = method (e.g., M5 is EPA Method 5). EPAMethods 5, 6, 7, 10, 16, 17, 23, 25/25A, 26/26A appear in 40 CFR Part 60, Appendix A. EPA Method 308 appears in Part 63, Appendix A. The “OTM” testmethods can be found at http://www.epa.gov/ttn/emc/prelim.html

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# 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 In troductio n .......................................................................................................... ................................ 2

B. How to Submit Your NEI Update ................................................................................................. .................. 3

C. How to Complete the NEI Update ................................................................................................ ................... 4

C1. Updating pre-popula ted NEI data ............................................................................................... .... 12

C2. Completing the NEI update if not pre-populate d 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 po llutant (HAP) emissions that: (a) Perform chemical wood pulping (kraft, sulfite, soda, or semi-chemical), or (b) Perform mechanical, groundwood (e .g., thermomechanical pulping (T MP), 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 comp lete 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 st ationary 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 fr om 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 fo r the facility listed in the Section 114 lette r 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 th e 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. Attachme nt 2 to this document identifies resources that might be useful for estimating emissions for your NEI update. Fo r convenience, a spreadsheet file entitled Lookups for P&P survey.xls accompanies Part II of the survey. This spre adsheet 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, s ubpart 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 th roughout the survey and asso ciated 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/info rmation 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 th ese 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 nu mber (so your file will be submitted to EPA with a unique filename that identifies your f acility). Then, transmit your certifica tion 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 fo r 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 pe rform a technology review of the pulp and pa per 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 Bl eaching Systems at Kraf t, 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 upda tes to their NEI data sets are requested in order for EPA to more accurately conduct RTR for the pulp and paper NESH AP 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 c odes 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 anal yses 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 For more information about the 2005 NEI, please go to : http://www.epa.gov/ttn/chief/net/2005inventory.html.



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MACT codes for equipment outside of the pulp and paper MACT source categories are in cluded 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 (SO 2 ), 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 surv ey will be used by EPA fo r 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 u pdate the corresponding CAP emissions as well

.

Base year for your NEI update . Use the 2009 calendar year as the ba se year for your NE I 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 fr om 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 an d 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 Rel ease Point ID, you will speci fy 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 emissi on 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 pr ocess. Identify and enter

the SCC code associated with each emission unit and note the appropriat e stack parameters on each row. Note the common stack in the "Emission Unit Description 2 ” 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 Description 2 ” 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. Ther e 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, th en 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 th at you can specify/estimat e an emission rate and emission release paramete rs 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 (aerat ed 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. S ee 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 Description 2 ” column

. Please also indicate in the “Emission Unit Description 2 ” 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 thro ugh 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 Type 3 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

P lease pay particular attention when entering emi ssion 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 fo r 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 (72 o 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 defau lt 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 disper sion estimates when risk m odeling 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 pollu tion 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 routin e 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 pro duction 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 emissi ons measurements or estimates (such as applicable lb/hr permit limits where available) than to apply this default f actor-of-10 approach. If thes e 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 bu t 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 fugitiv e 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 fugitiv e release height, the greater the disper sion 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 latit ude/longitude coordinates should corres pond with the actual location of each emission point (e.g., the location of each stack–not the ge neral 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 (E xample: +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 co rner 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 ze ro, the latitude/ longitude coordinates are specified at the southwest corner of the fugitive emission unit. If the fug itive angle is greater than zero, then the coordinates are specified at the western most co rner 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 temperat ure, velocity, and flow rate influence dispersion of air emissions and the risk modeling results (e.g., higher temper atures and velocity/flow rates lead to greater dispersion,

which in turn leads to reduce d risk to the surrounding population). If you do not supply this information, then EPA will specify conservative default parameters. Please ensu re that you specify positive, non-zero temperatures for your emission releases. Ambient te mperature is considered to be 72 o 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 associ ated 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 classificati on 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 ty pe 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

L atitude/longitude specified at SW corner (when fugitive angle = 0) L=10 ft W=4 ft Angle = 0

L=10 ft

L atitude/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., 307001 14 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 SC Cs 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 ma ny mills. However, TRI does not require mills to specify an SCC code so the dioxin/furan data are assigned a ge neric 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 mi ll 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 S CC and MACT code assignments for any dioxin/furan data in your pre-populated NEI. Please also review the data source associ ated 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 un it. 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 se rves 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 instru ctions 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 y ear. 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 em ission 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 inform ation 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 “D ata 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 Comme nt” 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 de letion with an "X" in the “Delete” column and note “complete inventory replacement” in the “Delete Co mment” 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 re visions). 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 (succes sfully) change data by over-writing existing data in a field.

General steps for updating your pre-po pulated 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 corr ectly (e.g., single unit with multiple vents; common collection systems and stacks, etc.)

• Is the Emission Release Point Type speci fied correctly for each emission unit?

• Are all of the known polluta nts (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 representa tive 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 da ta 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 emissi ons 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 show n 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, bleach ing, 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 oper ations that are not asso ciated 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 as ked to voluntarily review and update. If no “Emission Unit Description” is in the NEI for a given emission un it, 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 ty pe 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 fo r 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 vari ous reasons why the NEI data se t may be unavailable. Forexample, 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 resource s 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 spread sheet. You will add a single row of data

in the New Facility tab.

NEI Site ID . Use an NEI Site ID of “NEW_____” where th e 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 eac h 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 indi cate the dates for which NEI data are provided. For example, Start Date = 20090101 and End Date = 20091 231 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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### 16 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 Equipm ent (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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### 18 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 m ills – A Second update. Technical Bulletin No. 973. Research Triangle Park , N.C. Available to NCASI members at www.ncasi.org.Form Approved 02/17/2011

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### 19 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:

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### 20 Once you're logged in, the followi ng 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.Form Approved 02/17/2011

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### 21 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 ar e 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 Pa per Survey Response ............. 18

PART III - ATTACHMENT 2 Part II I 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 (T MP), 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 st ationary 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 fr om 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 mi lls that are a major source or synthetic area source of hazardous air pollutant (HAP) emissions that perform chemical wood pulpi ng (for example, with the kraft, sulfite, soda, semichemical or other pulping process).

This survey is to be completed in a Microsoft Excel spread sheet file that is divided into several worksheets (“tabs” within the spreadsheet file). You must complete certain ta bs 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 c ontinuous emissions monitoring system (CEMS) data or

control measure cost information.

Please complete the survey fo r the facility listed in the Section 114 lette r 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 th e 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, s ubpart 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 th roughout the survey and asso ciated 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 m ills subject to Part III

PIII Permit limits All mills subject to Part III (u nless permit limit informa tion for Part III emission units was provided in Part I)

PIII Controls Mills with add-on air pollution c ontrols on chemical recovery combustion sources.

PIII Emissions test data Mills opera ting 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 recove ry 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/info rmation 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 spreadsh eet 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 separa te 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 valida tion 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 replaci ng 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) an d 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 someon e 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 spread sheet 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 sp readsheets. 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. Howe ver, more detailed instructions for selected tabs are provided below to account for common situations and to prov ide 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) pr ovides EPA with data related to emissions release points (e.g., mass emission rate an d 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 specifi c 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 depend s 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 ex ists (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 mi ll. 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 fr om 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 an d 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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### 7 What if I have difficulty pairing emission units wi th 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 thos e instances where we need to link the NEI and Part I/III data). However, we realize that information may be presented in th e 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 ma y 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 Em ission 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 NE I data are unable to match one or more NEI Emission Unit IDs with emissions unit(s) at their mill (using the S CCs 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 (optio nal)” column in the Part I/III Equip detail tabs to clarify any matching discrepancies with the Part II NEI. Thes e notes will assist EPA in analyzing the data and prevent confusion.

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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 comp are 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 estim ating emissions (for example, values used in your permit application). We are not interested in maximum capac ity 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 provid e 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 ex cessive number of responses as “U K or “NA” are likely to receive

scrutin y and follow-up inquiries from EPA related to their surve y 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, contro ls, 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 po ints 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 uni t is ducted to a common conveyance. For multiple emission units ducted thro ugh a common conveyance to the same release point, list each Emission Unit ID separately and provide the same Collecti on 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 throug h AM. If the different release points (vents or stacks) have different

controls or different NSPS/NESHAP applicability then you w ill need to list each vent (or group of vents with the same controls) on separate rows. Repeat th e Emission Unit ID on separate rows and distinguish the release points using the “Emission unit description” co lumn 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 re lease (exhaust flow, APCD information and NSPS/NESHAP compliance options) in each row. En ter 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 “Configura tion if not emitted thro ugh 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 pr imary 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 reques ted 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 give n 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, temperat ure, etc. Unless otherwise specified, typical values are requested, and are subject to the respondent’s discretion. For ex ample, 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 th e 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 pro cess equipment and controls included in the bubble and submit separately your most recent bubble calculations used for compliance demonstrat ion. Please include the following in your calculation submittal: CaO production rate (ton/day), average volumetr ic 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, so da, 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 an alyses. 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 characteri ze the different types of se michemical 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 a nd 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 kiln s. 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-conden sable gases (NCG) and stripper off gases (SOG) are not considered to be either prim ary or supplemental fuels for purposes of this survey. Suppleme ntal and other fuel information is requested for recovery furnaces and semi chemical 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 pr ovide EPA with an understanding of th e 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 ar e asked to supply information for routine startup and shutdown events associated with planned process or m ill 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 purpos es 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 we re submitted under Part I).

If available in the permit, provide limits in terms consistent with the suggested units show n 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 th e 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/for mat for pollutants with multiple limits in different units of measure or formats (e.g., only provide ppmdv and lb/MMbtu at specified % oxygen (O 2 ) for a combustion unit

SO 2 limit specified in the permit in terms of ppmdv, lb/hr, lb/day, and tpy, lb/MMBtu at specified % O 2 , etc.). The survey spreadsheet allows for up to fi ve 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 comp ared 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 possi ble when entering permit limit units. Include any oxygen correction factors (% O 2 ). Be sure to note if ppm values are on a dry (d) or volume (v) or weight (w) basis if specified this way in 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 equi pment 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 pref er 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

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

PM 2.5 1

Opacity % (provide averaging time)

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

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

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

CO lb/MMBtu or ppmdv

Pb or other HAP metals Specify units

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

THC Report as carbon.

RF/combustion units: lb/ton BLS

HCl ppmdv and/or % reduction Methanol and gaseous organic

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

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

1 Specify filterable and/or condensable if your permit 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 ar e requested for PM, TRS, HCl, SO 2 , and other HAP. This information will be used in determining the capability of different control devices for reducing emissions. If you have data from inlet/outlet emissions testing used to determine a percentage reduction in the requested pollutant across the control device, then you would enter this test re sult as the “actual” control ef ficiency. You may leave the control efficiency columns blank (rathe r 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 ther mal 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 st artup, shutdown, and malfunction exem ption 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 m onitoring 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. Th e 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 informati on 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 surv ey. 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 em issions 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 forprior 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 combin ations. 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., datin g 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 repres entative 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 outle t 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 spreadsh eet (P&P CEMS_PIII.xls)

The EPA is requesting existing CEMS data and/or continuo us 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 curren t 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 (hourl y), Opacity, and other pollutants (NOx, SO 2 , CO, Methanol, HCl, and PM). Each worksheet is designed to accommodate data from one CEMS (including oxygen data). If you have multiple CEMS (e.g., two TRS CEMS on different emission units), then you must copy the relevant worksheet in order to enter data for the

additional CEMS.

A brief introduction to each of the CEMS worksheets follows. Additional, field-specific in structions are included on each worksheet. An “EXAMPLE” comp leted 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 recove ry 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 high est 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 concentr ations of TRS should be corrected to 8% O 2 for recovery furnaces and 10% O 2 for lime kilns and other equipment.]

TRS (1-Hour Average) . Same as above, except that this worksh eet 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 fo r 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, SO 2 , CO, total HAP, methanol, HCl, or PM) . This worksheet is designed for any emissions unit equipped with a CEMS. Specify the continuously monitored pollutant at the top of the worksheet. Respondents are requested to specify the Emission Unit ID (or 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 as ked 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 OPTI ONAL. 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 informatio n on a voluntary basis to pe rform 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 OPTI ONAL_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 OPTIONA L_PIII.xls” spreadsheet contains a re d 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 instru ctions 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 par ticularly interested in costs of the followi ng APCDs. Please supply this information using the APCD costs tab: - Recovery furnace scrubbers, dry sorbent injection/ fabric filter (DI/FF), selectiv e 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 followi ng 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 impr ove combustion efficiency - Process changes to improve lime mud washing or to control makeup water quality in the causticizing area - Replacing a recovery furnace w ith a black liquor ga sification 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 alternat ive format (e.g., as an attachment to your response) if needed. Because the cost data will be used by EPA to estim ate 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 co st included installation of extra buildings, land purchases, etc. that may not be required for other mills).



### 17

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

OMB Control No. 2060-0656 Approval Expires 02/28/2014



### 18 PART III - ATTACHMENT 1 Emission Units to 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 burnerPart 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 re ports, to include field and lab data sheets and example calculations.)



### 19Part IIIForm Approved 02/17/2011OMB Control No. 2060-0656Approval Expires 02/28/2014Part III - Attachment 2. Pulp and Paper Emission Units and Pollutants for Which Existing Representative Emission Test Data AreRequestedNote: Emissions test data representativeof your current operations are requested as described inthe survey instructions.Emission UnitParticulatematter(PM)1SpeciatedHAPmetals2PM2.5(fil.)PM2.5(cond.)Hydrochloricacid (HCl)Acetaldehyde,Formaldehyde,Methanol1Totalhydrocarbon(THC) ascarbonCDD/CDFandPOM/PAHTotal reducedsulfur (TRS)1,3Nitrogenoxides(NOx)1Sulfurdioxide(SO2)1Carbonmonoxide(CO)1Test methods4M5, M29,M17PM CEMS,COMSM29EPAOTM 27EPAOTM 28M26 or 26AMethanol:Method 308(part 63);MethanolCEMS; orOtherapplicablemethodsM25 orM25AM23M16(or variants such as16A, 16B, 16C) orTRS CEMSProvide total TRSdata. Also providespeciated TRS data,if available.M7(or variantssuch as 7E)CEMSM6(or variantssuch as 6C)CEMSM10CEMSRecoveryfurnaces (NDCEand DCE)Supply datafrom 2001and morerecentfollowingsubpart MMMACTcomplianceSupply datafrom 1990 ormore recentSupplymostrecentdataSupply datafrom 1990 ormore recentSupplyanyCDD orPOM dataand note ifequipmentconfig. haschangedSupply most recentdataBlack liquoroxidizer (BLO)Note: The BLOvent is includedin definition ofDCE, but listedseparately in casedata are availablefor only theBLO)NotrequestedSupply datafrom 1990 ormore recentNotrequestedSupply most recentdataNotrequestedChemicalrecoverycombustion units- sulfiteSupply datafrom 2001and morerecentfollowingsubpart MMMACTcomplianceSupply datafrom 1990 ormore recentSupplymostrecentdataSupply datafrom 1990 ormore recentNot requestedSupply mostrecent data20Part IIIForm Approved 02/17/2011OMB Control No. 2060-0656Approval Expires 02/28/201421Emission Unit Particulatematter(PM)1SpeciatedHAPmetals2PM2.5(fil.)PM2.5(cond.)Hydrochloricacid (HCl)Acetaldehyde,Formaldehyde,Methanol1Totalhydrocarbon(THC) ascarbonCDD/CDFandPOM/PAHTotal reducedsulfur (TRS)1,3Nitrogenoxides(NOx)1Sulfurdioxide(SO2)1Carbonmonoxide(CO)1Chemicalrecoverycombustion units- stand alonesemichemicalSupply datafrom 1990or morerecentSupplymostrecentdataSupply datafrom 1990 ormore recentNot requestedSupply mostrecent dataSmelt dissolvingtanks (SDT) orash dissolvingtanksSupply datafrom 2001and morerecentfollowingsubpart MMMACTcomplianceSupply datafrom 1990 ormore recentSupplymostrecentdataSupply datafrom 1990 ormore recentSupply most recentdataNotrequestedLimekilns/fluidizedbed calcinersSupply datafrom 2001and morerecentfollowingsubpart MMMACTcomplianceSupply datafrom 1990 ormore recentSupplymostrecentdataSupply datafrom 1990 ormore recentSupply most recentdataBlack liquorgasificationsystemsSupplymost recentdataSupply mostrecent data1If your emission unit is equipped with a continuous emissions monitoringsystem (CEMS) or continuous opacity monitoring system(COMS), supply the CEMS data using the CEMS data spreadsheet (P&PCEMS_PIII.xls). Synthetic area sources should supplythe most recent data (if data are available).2The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chromium VI (Cr+6) and speciated mercury (Hg) test data ifavailable.3Speciated TRS would include: hydrogen sulfide (H2S), methyl mercaptan, dimethyl sulfide, and dimethyl disulfide.4M = method (e.g., M5 is EPA Method 5). EPA Methods 5, 6, 7, 10,16, 17, 23, 25/25A, 26/26A appearin 40 CFR Part 60, AppendixA. EPA Method 308 appears in Part63, Appendix A. The “OTM” testmethods 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), Congr ess 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 Sec tion 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 Coun sel 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, re quest that EPA treat such information as confidential.

Information obtained under Section 114 a nd 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, s ubstantive criteria to be used in su ch 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 Informati on 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 confidentia l 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 agains t 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 positi on, and if so, what those harmful effects would be, why they should be viewed as substantial, and an expl anation of the causal relationship between disclosure and

such harmful effects.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 20022 

### “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 da ta 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 sta ndard 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 co mpliance 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 a3 

### 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 immediat ely 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 containi ng 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 th e 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 author ized 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. No4 

### 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 othe r 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 empl oyees 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 by5 

### EPA which contain CAA CBI must be stamped “S ubject 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 c over 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 ed ited 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 01420-4700Survey 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 47348Survey 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 13676Survey 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 31705-5958Survey 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 97132Survey 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