Date: July 23, 2012 

Subject: Review of Pulp and Paper Information Collection Request (ICR) Responses 

Pertaining to Startup and Shutdown of Subpart S Equipment 

EPA Contract No. EP-D-11-084; Work Assignment No. 0-03 

From: Katie Hanks 

To: John Bradfield 

Bill Schrock 

U.S. Environmental Protection Agency (EPA) 

Research Triangle Park, NC 27711 

I. Introduction 

The national emission standards for hazardous air pollutants (NESHAP) for the pulp and 

paper industry (40 CFR part 63, subpart S) were promulgated in 1998 and are due for review 

under Clean Air Act (CAA) sections 112(f)(2) and 112(d)(6). To address a lawsuit filed by Sierra 

Club, the subpart S risk and technology review (RTR) package was proposed in December 2011 

(76 FR 81328) and is scheduled to be promulgated by July 31, 2012. 

The U.S. Court of Appeals for the District of Columbia Circuit vacated portions of two 

provisions in the EPA’s CAA section 112 regulations governing the emissions of HAP during 

periods of startup, shutdown, and malfunction (SSM). Sierra Club v. EPA, 551 F.3d 1019 (D.C. 

Cir. 2008), cert. denied, 130 S. Ct. 1735 (U.S. 2010). Specifically, the Court vacated the SSM 

exemption contained in §§63.6(f)(1) and (h)(1) of the NESHAP General Provisions. In the 

December 2011 subpart S RTR proposal, EPA explained that, when incorporated into section 

112(d) regulations for specific source categories, these two provisions exempt sources from the 

requirement to comply with otherwise applicable NESHAP standards during periods of SSM. 

Because the Pulp and Paper NESHAP relied on the General Provisions for SSM, EPA proposed 

to set standards that applied during startup and shutdown periods. Specifically, EPA proposed to 

require the same standards that apply during normal operations for periods of startup and 

shutdown. The EPA separately proposed an affirmative defense approach that would apply for 

malfunctions in §63.456 of subpart S. In addition, EPA requested comment on whether to 

remove, or modify, the excess emissions provisions for low-volume high concentration (LVHC), 

high-volume low concentration (HVLC) and steam stripper systems in §§63.443(e), 63.446(g), 

and 63.459(b)(11)(ii) of subpart S. (76 Fed. Reg. at 81345-81347). 
2

The EPA received numerous comments on the December 2011 subpart S proposal. 

Industry commenters suggested that EPA consider whether separate standards could be adopted 

for startup and shutdown periods (i.e., other than the standards that apply during normal 

operation). The commenters suggested that work practice standards developed pursuant to CAA 

Section 112(h) may be appropriate. Overall the commenter’s rejected EPA’s conclusion from 76 

FR 81346 that, “Nothing in the record suggests that the operations (and attendant emissions) are 

significantly different during startup or shutdown than during normal operation.”

The purpose of this memorandum is to present Information Collection Request (ICR) 

data relating to startup and shutdown of subpart S equipment. This memorandum does not 

address malfunctions covered under the proposed affirmative defense provisions; nor does it 

address the excess emissions allowances. The pulp and paper industry has submitted additional 

information pertaining to the excess emissions allowances which EPA intends to consider as part 

of a future analysis along with additional data that is collected.1

 

II. Information Collection Request Startup and Shutdown Questions 

The EPA sent out a three-part ICR (survey) in February 2011 that requested information 

needed to perform various regulatory reviews, including the subpart S RTR. Part I of the ICR 

contained questions pertaining to startup and shutdown for subpart S emission units and control 

devices. These questions appeared in the PI Equip detail and PI Controls tabs of the spreadsheetbased survey. The startup and shutdown questions were designed to provide EPA with an 

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

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

Appendix A presents the specific Part I survey spreadsheet questions. The corresponding Part I 

survey instructions are as follows: 

Emission unit startup and shutdown. Complete the startup and shutdown questions for all emission units 

currently subject to Federal or State emission limits or monitoring requirements. Questions pertaining to 

emission unit startup and shutdown are asked in order to provide EPA with an understanding of the 

duration, emissions potential, work practices, and control mechanisms of startup and shutdown events for 

the wide variety of equipment used at pulp and paper mills. The EPA is considering standards that could 

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

should apply) in light of the December 2008 vacatur of the NESHAP startup, shutdown, and malfunction 

exemption in 40 CFR Part 63, subpart A. The startup and shutdown questions would also identify pulp and 

paper emission unit types for which startup and shutdown are not already addressed with the current 

emission standards. You are asked to supply information for routine startup and shutdown events associated 

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

events associated with equipment malfunctions.) The startup and shutdown data in the PI Equip detail tab 

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

Control device startup and shutdown. The EPA is considering standards that could apply during startup and 

shutdown events (or whether the current standards developed for normal operation should apply) in light of 

the December 2008 vacatur of the NESHAP startup, shutdown, and malfunction exemption in 40 CFR Part 

63 subpart A. Questions pertaining to control device startup and shutdown are asked in order to provide 

EPA with an understanding of the duration and definition of startup and shutdown events for the types of 

control devices used at pulp and paper mills. The EPA is seeking information on the integral nature of 

                                                           

1

Letter and attachments from P. Noe, American Forest & Paper Association (AF&PA), to G. McCarthy, 

U.S. EPA. June 27, 2012. Information related to excess emissions allowances. 
3

startup and shutdown events for the different combinations of emission units and control devices used in 

the pulp and paper industry. In addition, because Federal NSPS and NESHAP require continuous 

monitoring of emissions or control device operating parameters, information is requested to inform EPA of 

particular pulp and paper NSPS or NESHAP control device parameter limits that cannot feasibly be met 

during startup and shutdown events. Certain parameters may be "instant on" while others are more transient 

in nature (i.e., changing as startup or shutdown progresses). Examples could include control device 

temperature that must heat up to a set point, or pressure drop that cannot be achieved due to low exhaust 

gas flow from the emission unit. The EPA will use this information to evaluate which existing control 

device parameter limits may remain in effect during startup and shutdown events, and which parameter 

limits may need to be replaced with another requirement during startup and shutdown. In all of the control 

device startup and shutdown questions, you are asked to supply information for routine startup and 

shutdown events associated with planned equipment or mill downtime. (Do not provide information for 

unplanned startup/shutdown events associated with equipment malfunctions.) The startup and shutdown 

data in the PI Controls tab are being sought for regulatory development purposes, and will not be used for 

enforcement purposes. 

As shown in Appendix A, the ICR contained optional questions where respondents were 

asked to suggest a separate standard that could apply during emission unit and control device 

startup or shutdown. No useful suggestions for separate standards were received. 

In addition, responses to survey questions asking what marks the beginning and end of 

normal operations for emission units and control devices tended to be very site-specific in nature. 

This stands to reason because mills formerly defined startup and shutdown—in consideration of 

their specific equipment and operational practices—in their SSM plans. Thus, defining the 

beginning and end of startup and shutdown periods in a way that makes sense for each piece of 

process equipment regulated under Subpart S would be unnecessarily complex. However, it is 

not necessary to define startup and shutdown periods if the final RTR rule requires facilities to 

implement startup and shutdown procedures in compliance with the standard. The following 

review focuses on information provided in the 2011 ICR that supports the conclusion that 

procedures are in practice in the industry which will allow facilities to implement practices that 

will assure continuous compliance during periods of startup and shutdown. 

III. Background Information and ICR Data Relevant for the Different Subpart S 

Standards 

Subpart S contains standards for: 

 Kraft, soda, and semichemical pulping vent gases (§63.443); 

 Sulfite pulping vent gases (§63.444); 

 Bleaching vent gases (§63.445); 

 Closed-vent systems used to transport pulping or bleaching vent gases (§63.450); and 

 Kraft pulping condensates (including closed collection systems for kraft condensates) 

(§63.446). 

Rather than comply with the above standards as written in subpart S, some mills have 

elected to comply with site-specific standards through use of the subpart S clean condensate 

alternative (CCA) or through equivalency-by-permit (EBP) approaches. The technologies used 

for site-specific compliance options are often the same as those used to comply with the 

standards noted above. For example, CCA compliance may be achieved by controlling more 

kraft condensates or equipment than are required to be controlled under subpart S (using the 
4

same technologies mills typically use for condensate control), thereby offsetting the need for 

HVLC controls. Since the same technologies are often used for compliance with site-specific 

approaches, then a review of the startup and shutdown ICR responses for the most common 

technologies represents the best available information to determine if the survey data 

demonstrate a need for separate emissions standards that would apply during startup and 

shutdown. While review of the ICR data should cover the majority of situations, it is noted that 

there may be site specific differences between mills in the manner in which they achieve 

continuous compliance during startup and shutdown. For example, one mill may have built more 

redundancy into their operational practices than another mill (e.g., practices could involve 

starting controls and ensuring they meet the required parameter limits before beginning operation 

of the emissions unit, and running the controls until the emissions unit ceases operation). 

Each of the subpart S standards covers a collection of equipment which are usually routed 

through a vent gas (or condensate liquid) collection system to a control device for HAP 

emissions reduction. Subpart S contains a variety of compliance options for each of the standards 

listed above. Appendix B presents a matrix of the subpart S standards, control systems, initial 

compliance demonstration methods (e.g., emissions testing methods) and continuous compliance 

demonstration methods (e.g., monitoring requirements). Collectively these requirements dictate 

how compliance is demonstrated with subpart S. The matrix in Appendix B was initially 

developed as a starting point for a two-step assessment: 

1. Assessing whether ICR information indicates mills may be in violation of a 

continuous compliance requirement should the standards that apply during normal 

operation also apply during periods of startup and shutdown. If not, then, 

2. Identifying appropriate alternative standards that could be applied during startup and 

shutdown. Development of separate emissions standards (separate numeric limits or 

work practices) for startup and shutdown of pulp and paper processing equipment 

would require consideration of emission unit, collection system, and control device 

operation; compliance option used; and methods for demonstrating initial and 

continuous compliance. 

To complete step 1, each set of standards and compliance options were reviewed. Data were 

pulled from the ICR for each control requirement in the standard in order to determine if mills 

actually indicated problems with meeting the monitoring requirements associated with the 

normal operational standards during periods of startup and shutdown. In the end, based on the 

findings from step 1, it was determined that there was little reason to complete step 2 because so 

few mills reported potential issues with meeting the continuous compliance requirements in 

subpart S. Instead of problems, the ICR results revealed that the majority of mills have 

implemented operational practices that allow them to meet the subpart S continuous compliance 

requirements at all times (including startup and shutdown periods). The information considered 

in arriving at this conclusion is presented in the sections below. 

A. Kraft, Soda, and Semichemical Pulping Vent Gases 

As shown in Appendix B, kraft, soda, and semichemical mills typically use a thermal 

oxidizer, boiler, lime kiln or recovery furnace to combust non-condensable gases (NCG) 

including LVHC, HVLC, and stripper off-gases (SOG) which are, by definition, LVHC. Mills 
5

must comply with the both pulping vent gas standards in §63.443 and the standards for closedvent systems in §63.450. 

As noted above, control device startup and shutdown can be sequenced so that the 

controls are available during NCG generating process equipment operational periods. 

Alternatively, continuous control availability is frequently addressed at pulp and paper mills 

through the use of backup NCG controls. The startup (or shutdown) sequence of equipment is a 

consideration since some of the incineration devices used by pulp mills are also process 

equipment (i.e., lime kilns, recovery furnaces, and power boilers). It is reasonable to expect that 

boilers would start up before most other emissions units because boilers provide steam and 

power needed to operate emissions units. Similarly, recovery furnaces often provide steam and 

power for emission units. Although some incineration devices may need to follow a startup 

sequence (e.g., a recovery furnace that does not begin normal operation until spent liquor is 

available from digesters; or a lime kiln that does not begin normal operation prior to smelt being 

generated from the recovery furnace and moving through the causticizing process), these devices 

can begin to start up on auxiliary fuels prior to processing of spent liquor (for a recovery furnace) 

or calcium carbonate (for a lime kiln). As for shutdown, power boilers and recovery furnaces 

would be expected to continue producing steam and/or power until the process units dependent 

on them are shutdown. Many mills also have stand-alone thermal oxidizers that are used as 

backup controls when process units such as lime kilns or recovery furnaces are used as the 

primary control device. 

Mills responded to ICR questions pertaining to which compliance options they elected to 

use for subpart S compliance. These responses were standardized (for counting purposes and for 

consistency) through QA of the Part I data base. As shown in Appendix C1, a query of the Part I 

ICR data base (PI Equip detail tab) reveals that a majority of mills use compliance options for 

NCG control that are based on the following combustion unit design scenarios: 

 A boiler, lime kiln, or recovery furnace in which the HAP gas stream is introduced with 

the primary fuel into the flame zone; or 

 A boiler or recovery furnace with a heat input capacity ≥150 MMBtu/hr (44 MW) in 

which the HAP gas stream is introduced with the combustion air. 

These two compliance options do not involve any emissions or parameter monitoring that would 

show mills to be out of compliance during emission unit startup or shutdown. Compliance is 

demonstrated as long as NCGs are routed to the combustion unit for control, as demonstrated 

through the standards for closed-vent systems in §63.450 (discussed further in Section III.D 

below). The remaining pulping vent gas compliance options involve firebox temperature 

monitoring or optional use of methanol continuous emissions monitoring systems (CEMS). The 

survey data reveal than no mills are using methanol CEMS. 

The ICR data in the startup and shutdown columns of the PI Equip detail and PI Controls

tabs were reviewed to determine measures used to reduce emissions during startup and 

shutdown, or if mills reported issues with not being able to maintain parameter limits during 

startup or shutdown. Appendices C2, C3, and C4 present the data reviewed from the ICR. 

Appendix C2 contains startup and shutdown details from PI Equip detail for kraft, soda, and 

semichemical pulping processes that generate NCGs, organized by emission unit type with the 

control system type noted. (Some of these equipment produce both NCGs and condensates so 
6

there are some references to condensate collection system startup and shutdown in Appendix C2 

in addition to NCG system startup and shutdown information). Appendix C3 contains startup and 

shutdown details from PI Equip detail for recovery furnaces, boilers, lime kilns, and stand-alone 

incinerators (i.e., the types of equipment that incinerate NCGs). Appendix C4 contains details 

from PI Controls for NCG control devices. 

The data in Appendices C2, C3, and C4 requires further explanation. The startup and 

shutdown responses of interest (e.g., that potentially suggested NCG venting during startup and 

shutdown, or inability to combust NCGs) were highlighted in a red or green font color. In each 

case, when an ICR response was highlighted as a potential NCG control problem, it could be 

paired with a practice described in the ICR which eliminates the concern and indicates 

continuous compliance. In example 1, the SU_MarkEnd column was flagged because it could 

potentially indicate that there is a delay between startup of the emission unit (digester) and the 

availability of the NCG collection system. However, the information in the SU_EmissRednMeas 

column clearly stated that the emission unit and control system are in compliance during startup. 

In example 2, the SU_MarkEnd column was highlighted because it noted permissives had to be 

met, a potential concern. However, the SU_EmissRednMeas column clearly stated that boilers 

are operational prior to startup of the emission unit thus eliminating the concern. There are many 

examples like this among the potential startup and shutdown concerns highlighted in Appendices 

C2, C3, and C4 where a potential startup and shutdown concern in one column is negated by 

paired information in another column. Additionally, there are many more rows of data in 

Appendices C2, C3, and C4 where no issues with startup and shutdown are indicated, or the 

response affirmatively states that equipment operates during startup and shutdown in compliance 

with required parameter limits. 

Table 1. Examples of Startup and Shutdown Responses Where Information in One Column 

is Contradicted or Negated by Information in Another Column 

Ex. 

Measures employed to 

reduce air emissions 

during emission unit 

startup (if any) 

What marks the end 

of emission unit 

startup and beginning 

of normal operating 

conditions? 

Measures employed 

to reduce air 

emissions during 

shutdown (if any) 

What marks the 

end of normal 

operating 

conditions and 

beginning of 

emission unit 

shutdown? 

SU_EmissRednMeas SU_MarkEnd SD_EmissRednMeas SD_MarkBegin 

1 

emission unit and 

control device operates 

in compliance with 

NSPS and NESHAP 

parameter limits during 

emission unit startup 

NCG Collection 

System is ready to 

accept vent gases from 

the Blow Heat 

Accumulator System. 

NA - applicable 

emission and 

parameter limits not 

expected to be 

exceeded during 

shutdown 

steam flow to blow 

tanks is off 

2 

Ensure that power 

boilers are operational 

prior to startup. 

When incineration 

device permissives are 

met 

Shutdown sources of 

NCGs prior to 

shutdown. 

When incineration 

device permissives 

are not met 
7

The following are observations from the ICR data presented in Appendices C2, C3, and 

C4 for NCG collection and control systems: 

 Incineration control devices must obtain a combustion temperature set point before NCGs 

can be destroyed. 

 There is a difference between warm and cold startups. Cold startups take longer than 

warm startups (e.g., because process equipment must warm to processing temperatures or 

combustion temperatures must be achieved in incineration devices). Similarly, it takes 

longer for a shutdown to reach “cold” status than if equipment remains warm. 

 The majority of responses indicated that mills ensure NCG collection and control systems 

are operating prior to emission unit startup, and until emission unit shutdown is complete. 

Many responses affirmatively stated that parameter limits are met during startup and 

shutdown. 

 A few mills noted that parameter limits are not necessarily met during startup or 

shutdown; or indicated that the excess emissions allowances are used during startup or 

shutdown. 

 Based on their responses, it appears that a few mills may define the end of startup and 

beginning of shutdown based on the status of their NCG collection system relative to the 

NESHAP parameter limits (e.g., possibly beginning emission unit operation and coding 

of operations as startup or shutdown until NESHAP parameters are met). Such mills 

could be more reliant on the NESHAP SSM exemption and excess emissions allowances 

than mills that wait until the NCG collection and control systems are ready before starting 

emission units (and operate the NCG collection and control system until NCG-producing 

emission units have ceased operation). 

 A few mills reported use of fresh steam (as opposed to flash steam) in the digester chip 

bin to minimize emissions during startup or shutdown (shown in blue text in Appendix 

C2). 

 Startup and shutdown times vary considerably depending on the process and control 

system. In Appendix C2, 63% of startup times reported were 4 hours or lower; 35% were 

between 4 and 24 hours; and 2% were greater than 24 hours. These times are based on the 

maximum of any ranges reported by mills (e.g., the longer cold startup time if a mill 

provided both hot and cold startup). 

 Shutdown often takes the same or less time than startup. 

Overall, considering the lack of issues revealed in the survey responses, the availability 

of multiple compliance options (most frequently equipment design), and widespread use of 

backup NCG incineration controls, it appears that compliance with the normal operational 

pulping vent gas standards during startup and shutdown is possible and achieved in practice at 

most mills. Therefore, development of separate standards for startup and shutdown for kraft, 

soda, and semichemcal pulping vent gases were not explored further in this memorandum. 

B. Sulfite Pulping Vent Gases 

As shown in Appendix B, sulfite mills are required to meet a pound per oven-dried ton of 

pulp (lb/ODTP) or percent reduction standard for sulfite pulping vent gases. Sulfite mills route 

emissions through a closed vent collection system to a scrubber (or other control device). Based 

upon the ICR results, six sulfite mills remain in operation in the U.S., including: 
8

 Three ammonia-based sulfite mills (all meeting the 2.2 lb/ODTP option); 

 Two calcium-based sulfite mills (both meeting the 0.89 lb/ODTP option); and 

 One sodium-based sulfite process co-located at a kraft mill. 

The co-located kraft and sodium-based sulfite mill uses the kraft mill lime kiln to 

incinerate sulfite vent gases along with LVHC. This control system should comply with the 92% 

reduction option for sulfite vent gases (i.e., since 98% reduction is presumed with lime kiln 

incineration). No testing or monitoring is required for lime kiln LVHC incineration. The sulfite 

pulping vent gas standards would be deemed in compliance as long as the lime kiln is operating 

as designed and accepting the sulfite vent gases. 

Subpart S requires the following parameters to be monitored for sulfite scrubbers: 

 Effluent pH (or oxidation/reduction potential), 

 Inlet vent gas flow rate, and 

 Scubber liquid influent flow rate. 

The ICR PI Equip detail and PI Controls tabs were examined to determine if there were 

process-control interdependencies or other reported issues with meeting the scrubber parameter 

limits during startup and shutdown. The ICR data are presented in Appendices D1 and D2, 

respectively. The ICR indicates that scrubbers used at sulfite mills employ a type of fresh water 

(e.g., river water, well water) with caustic addition. Recirculation of scrubbing water within the 

scrubbing system was reported for two of the scrubbers (but not for the other two sulfite 

scrubbers). Flow of fresh or scrubber recirculation water to the scrubber (scrubber liquid influent 

rate) is not dependent on other pulping emission units within the mill (nor is caustic addition 

since the caustic is not coming from any pulping by-product). The scrubbing pH reported ranged 

from 5.6 to 6.3. Scrubber startup and shutdown times were less than 1 hour. 

The ICR data indicated that scrubbers are started up and meeting required operating 

parameter limits before the emission unit is started up; and that the scrubbers remain in operation 

until the emission unit is shut down. Although one mill reported that they consider shutdown to 

begin upon, “Failure to meet operational parameters due to shutdown,” the same mill also stated 

that the, “Control device continues to operate and meets required operating limits while emission 

unit is shut down.” Thus, no issues with meeting subpart S operating parameters were identified 

in the ICR responses and development of separate standards for startup and shutdown for sulfite 

pulping vent gases were not explored further in this memorandum. 

C. Bleaching Vent Gases 

Mills complying with the bleaching vent gas standards typically route chlorinated 

bleaching vent gases through a closed vent collection system to a caustic scrubber or similar 

device. Only the bleaching stages where chlorinated compounds are used are required to be 

controlled. Several compliance options for chlorinated HAP (other than chloroform) are 

available under subpart S, including concentration, percent reduction, and a mass-based emission 

limit. An initial performance test is required for bleach plant scrubbers to demonstrate 

compliance with the emission limits for chlorinated HAP. A 5-year repeat performance test 

would be required with the proposed amendments to subpart S. In addition to performance 
9

testing, continuous compliance for bleaching scrubbers is demonstrated by continuous parameter 

monitoring of effluent pH (or oxidation/reduction potential [ORP]), inlet gas flow rate, and 

scrubber liquid influent flow rate. Continuous monitoring of chlorine (Cl2) concentration is 

allowed as an alternative to continuous parameter monitoring; however, no mills reported use of 

Cl2 CEMS in the survey responses. 

A work practice standard (to either meet effluent guidelines or use no hypochlorite or 

chlorine for bleaching) is required for chloroform. No startup and shutdown issues are 

anticipated with this design-based work practice. 

The startup and shutdown columns of the PI Equip detail and PI Controls tabs were 

reviewed for information relating to bleach plant process and scrubber startup and shutdown. 

These data are included in Appendices E1 and E2. Almost no issues with meeting the bleaching 

scrubber parameter limits were noted in PI Equip detail. Mills generally reported operation of 

the bleach plant scrubber before and after operation of the bleach plant processes, and that 

parameter limits are met during startup and shutdown. Only one mill noted that the “emission 

unit and control device operates during emission unit startup (but not necessarily in compliance 

with all NSPS/NESHAP parameter limits)” but this same mill also indicated that, “All Control 

Equipment remain on-line until source is shut down.” The median startup and shutdown time 

indicated in PI Equip detail was 1 hour. 

According to the PI Controls tab controls query, process waters such as white liquor, 

weak wash, or caustic are most commonly used in bleach plant scrubbers. Scrubber pH ranged 

from 7 to 14 (median 10.7). Many of the scrubbers contained some sort of packing, and recycled 

the scrubber water within the scrubber. Scrubber blowdown - the fraction of scrubber liquid that 

is purged from the system and replaced by new liquid - is either recycled in the process (e.g., 

within the bleaching or chlorine dioxide generation process, but it varies) or sent to the 

wastewater treatment plant. The ability of bleach plant scrubbers to recycle scrubbing liquid 

within the scrubber system serves as a buffer to reduce dependency of the scrubber system on 

other mill processes during brief periods of scrubber startup or shutdown. Median scrubber 

startup time was 0.5 hr; average was 0.8 hr. Median scrubber shutdown time was 0.25 hrs; 

average was 0.7 hr. 

A number of mills reported use of ORP instead of pH. Fan motor amps, revolutions per 

minute (rpm), or fan on/off status are often monitored as indicators of inlet gas flow rate. Several 

mills noted in the PI Controls tab that various scrubber parameters are transient in nature and 

may not be met as the scrubber is started up; but these same mills also indicated that the control 

device is started up and meets required operating parameter limits before the emission unit is 

started up. In addition, one mill indicated in PI Controls that, “White liquor needs to be available 

from causticizing as the scrubbing media.” This same mill noted that if startup [or shutdown] 

“occurs late in the 3-hr block average period, and operation of emission units starts [or stops] 

shortly thereafter within the same 3-hr period, then the scrubber may show noncompliance due to 

the averaging of limited data.” One mill indicated they were unable to meet a pressure drop 

parameter during startup or shutdown, but pressure drop is not a parameter required to be 

monitored under subpart S. Since few issues with meeting subpart S operating parameter limits 
10

were identified in the ICR responses, development of separate standards for startup and 

shutdown were not explored further for bleaching vent gases. 

D. Closed-vent Systems Used to Transport Pulping or Bleaching Vent Gases 

The subpart S standards for closed-vent gas collection systems contain requirements for: 

 Enclosures, openings, and hoods; 

 Components operated at positive pressure; and 

 Bypass lines that could divert vent streams containing HAPs to the atmosphere. 

Mills must maintain negative pressure at enclosures, openings, and hoods. If the 

enclosure, opening, or hood is closed during the initial performance test, it must remain closed 

during operation, except for sampling, inspection, maintenance, or repairs. Compliance with 

these requirements is demonstrated by following a site-specific inspection plan required in 

§63.454(b), where visual inspections of enclosure openings are required every 30 days per 

§63.453(k)(1). The 30-day inspection frequency reduces the chance that mills would be out of 

compliance with this requirement during startup and shutdown. 

Mills are required to operate with no detectable leaks (less than 500 parts per million by 

volume [ppmv] of volatile organic compounds [VOC] above background) for collection system 

components operated at positive pressure. Compliance is measured with initial and annual part 

60, Method 21 leak detection tests. Even if leak detection tests were conducted during startup 

and shutdown, it is not expected that startup and shutdown would change the potential for leaks 

beyond the potential that exists during normal operation, because gas flow volumes are likely to 

be lower during startup and shutdown. There are no apparent reasons mentioned in the ICR why 

enclosures, openings, and hoods could not remain closed or maintain negative pressure during 

startup or shutdown. 

Bypass lines that could divert vent streams containing HAPs to the atmosphere are 

required to either: 

 Operate a computer-controlled flow indicator to monitor for presence of gas stream flow 

in the bypass line at least once every 15 minutes; or 

 Maintain bypass line valves that are not computer controlled in the closed position, sealed 

so that the valve or closure mechanism cannot be opened without breaking the seal. 

Compliance with these requirements is demonstrated by following the site-specific inspection 

plan required in §63.454(b), where visual inspections of enclosure openings are required every 

30 days per §63.453(k)(1). It seems that bypass line valves that are sealed during normal 

operation should stay sealed during startup and shutdown (unless a seal is broken due to a 

malfunction event which could be addressed under affirmative defense). Also, the 30-day 

inspection frequency reduces the chance that mills would be out of compliance with requirement 

to keep bypass lines closed and sealed during startup and shutdown. 

Multiple emission units feed into closed-vent systems. Commenters on the December 

2011 subpart S proposal indicated that gas flow rate into collection systems (and internal system 

pressures) can vary, as emission units are started up or shut down. Computer-monitored bypass 

lines could show some safety-related venting during startup and shutdown until flows within the 
11

collection system are within lower explosive limit (LEL) or upper explosive limit (UEL) 

permissives, and flows are balanced. This safety-related venting is currently covered under the 1 

and 4 percent excess emissions allowances for LVHC and HVLC systems, respectively. 

The PI Equip detail and PI Controls ICR responses were reviewed for indications of 

problems demonstrating compliance with the closed-vent collection system requirements during 

startup and shutdown. The following search terms were used in the startup and shutdown 

columns to screen for issues specific to vent gas collection systems: negative, pressure, open, 

hood, bypass, valve, enclosure, door, positive, vent. Appendices F1 and F2 consolidate the 

responses that were flagged for brevity. Appendices C through E of this memorandum contain all 

the relevant responses (including those that were not flagged for potential collection system 

concerns). Although the majority of responses did not indicate any issues; the following 

responses are noteworthy: 

 One respondent in PI Controls indicated that, “Negative pressure at all hood openings 

cannot be maintained” in reference to a thermal oxidizer. However, the same respondent 

also indicated that, “The unit is not allowed to begin operation until the NCG collection 

system and combustion device are in service.” 

 In PI Equip detail, one mill indicated that startup is complete when, “A negative draft has 

been established for the foul condensate filter and F-secondary knotter Lean (HVLC) Gas 

Vent lines.” But notably, the same respondent also indicated that the emission unit and 

control device operates in compliance with NSPS and NESHAP parameter limits during 

emission unit startup. 

 One respondent in PI Controls stated that the, “Collection system must vent to purge O2 

to avoid explosive gas mixture” in reference to a flare. This safety-related venting is 

currently covered under the excess emissions allowances for NCG systems, respectively.

 Two responses in PI Controls indicated that NCG are vented during change over from 

primary to secondary treatment device. One of the respondents noted that this takes less 

than 5 minutes. This safety-related venting is currently covered under the excess 

emissions allowances for NCG systems, respectively. 

 A few of the responses in PI Equip detail seemed to suggest that venting of NCG 

collection systems could occur during startup or shutdown at some mills (e.g., responses 

that define the end of shutdown or beginning of startup based on when vents close and 

gas flow is diverted to incineration). Most of these respondents also noted that they use 

backup controls, or are in compliance with parameter limits during emission unit startup 

or shutdown. 

Separate standards for startup and shutdown of closed-vent gas collection systems were 

not explored further since overall few mills indicated problems with meeting the vent gas 

collection requirements during start and shutdown in their ICR responses. As noted above, EPA 

was provided additional information from industry that could be relevant to computer-controlled 

bypass lines on closed vent gas collection systems and the standards for excess emissions 

allowances. That information can be evaluated further when EPA considers how to address the 

excess emissions allowances. 

 
12

E. Kraft Pulping Condensates and Condensate Collection Systems 

Kraft pulping condensates are HAP-containing liquids that are condensed from pulping 

system vent streams, including condensates from digesters, turpentine recovery, evaporators, 

LVHC systems, and HVLC systems. The LVHC and HVLC collection system condensates are 

generated by condensation of moisture in the closed-vent collection systems that convey the 

LVHC and HVLC system vent gases to a control device. 

Condensate Collection Standards. The subpart S kraft pulping condensate standards 

include standards for condensate collection and standards for condensate treatment. The kraft 

condensate collection standards include three options: 

1. Collect all named condensate streams. 

2. Collect all LVHC and HVLC streams plus streams that contain 65 percent of the total 

HAP mass from the digester system, turpentine recovery system, and evaporator system 

feed stages. 

3. Collect any subset of the named streams that contain in total 7.2 lb of HAP per ODTP at 

mills that do not perform bleaching, or 11.1 lb HAP per ODTP at mills that perform 

bleaching. 

Kraft condensates are to be conveyed in a closed collection system that meets the 

requirements in §63.446(d) of subpart S for individual drain systems and condensate tanks. A 

mill can meet the closed collection system requirements in two ways: 

 Hardpiping; or 

 Use existing drains, but cover all openings and route all open vents through a closed-vent 

collection system to a control device meeting the subpart S NESHAP requirements for 

pulping system vents. 

Closed collection systems used to transport pulping process condensates containing 

HAPs must meet all of the individual drain system requirements specified in §§63.960, 63.961, 

and 63.962 of 40 CFR part 63, subpart RR (National Emission Standards for Individual Drain 

Systems), except that any air vents in the collection system must comply with the kraft pulping 

vent gas collection and HAP reduction standards in §63.443(c) and (d) of subpart S. Subpart RR 

establishes design, operating, inspection, and monitoring requirement standards for controlling 

air emissions from individual drain systems. The standards control emissions from individual 

drain systems using covers or seals, or hard-piping. Subpart RR also requires inspections of 

water seals and closure devices for defects or damage initially and establishes repair 

requirements for individual drain systems. The closed collection system must be visually 

inspected every 30 days according to §63.964 of subpart RR. 

For condensate tanks, §63.446(d)(2) specifies: 

 The fixed roof and all openings (e.g., access hatches, sampling ports, gauge wells) shall 

be designed and operated with no detectable leaks as indicated by an instrument reading 

of less than 500 ppm above background, and vented into a closed-vent system that meets 

the requirements in §63.450 and routed to a control device that meets the requirements in 

§63.443(d); and 
13

 Each opening shall be maintained in a closed, sealed position (e.g., covered by a lid that 

is gasketed and latched) at all times that the tank contains pulping process condensates or 

any HAP removed from a pulping process condensate stream, except when it is necessary 

to use the opening for sampling, removal, or for equipment inspection, maintenance, or 

repair. 

Compliance with the standards for the different components of closed condensate 

collection systems is based on system design (e.g., covers, seals, or hard-piping), and continuous 

compliance is based on periodic leak checks and inspections. Openings in the condensate liquid 

collection system that are sealed during normal operation should also be sealed during system 

startup and shutdown (except, perhaps, for a malfunction or operator error). In their responses to 

the ICR startup and shutdown questions, some mills noted that they verify condensate collection 

system components are closed. Thus, periods of startup and shutdown are not likely to result in 

violation of the periodic leak check and inspection requirements if this practice is followed. 

Development of separate standards for closed condensate collection systems during startup and 

shutdown periods were not explored further. 

Condensate Treatment Standards. Once collected, kraft pulping condensates must be 

treated according to one of the following subpart S treatment standards:

1. Recycling: Route condensates through a closed vent collection systems to pulping 

equipment controlled by the subpart S kraft pulping vent gas standards; or 

2. Route the condensates to biological treatment, steam stripper or other control device that 

meets one of the following equivalent requirements: 

 Reduce total HAP by at least 92 weight-percent; or 

 For mills without bleaching, either remove at least 6.6 lb total HAP/ODTP, or 

meet 210 ppmw total HAP at the control device outlet; or 

 For mills with bleaching, either remove at least 10.2 lb total HAP/ODTP, or meet 

330 ppmw total HAP at the control device outlet. 

Condensate Recycling. For the condensate recycling treatment option, the compliance 

demonstration consists only of verifying that no leaks are present in the condensate closed 

collection system, and confirming the closed vent gas system and control device requirements 

are met. Separate startup and shutdown standards were not investigated further for control of 

condensates through recycling to pulping equipment subject to the pulping vent gas standards 

based on the discussions above of the kraft pulping vent gas and closed condensate collection 

system standards. 

Steam Strippers and Other Equipment Serving the Same Function. Mills controlling kraft 

condensates with steam strippers or other equipment serving the same function (e.g., an inprocess anaerobic biotreatment unit, wastewater thermal oxidizer, etc.) must perform an initial 

performance test for total HAP (measured as methanol) using 40 CFR part 63 Method 305 or 

NCASI method DI/MEOH-94.03. Inlet and outlet testing is required for mills complying with 

the percent reduction or lb/ODTP collection and removal standards. Only outlet testing is 

required for mills complying with the ppmw condensate standards. Alternatively, measure the 

steam stripper methanol outlet concentration (ppmw). The ICR results reveal that only one mill 

is using the ppmw option (a mill with a thermal oxidizer), and this mill is not using a methanol 
14

CEMS to demonstrate compliance. Mills operating equipment other than steam strippers must 

petition the Administrator for approval of site-specific monitoring requirements. 

For mills using steam strippers, subpart S requires that ongoing compliance be 

demonstrated by continuous parametric monitoring of the process wastewater feed rate, steam 

feed rate and process wastewater column feed temperature. Although not specified explicitly in 

subpart S, the steam feed rate and condensate feed temperature parameter limits are minimum 

limits that relate to how much heat must be applied in the steam stripper system in order to strip 

organics into the vapor phase. The steam-to-feed ratio (SFR) is the stripper operating parameter 

with the greatest effect on stripper performance. This ratio is monitored through subpart S by 

dividing the monitored steam feed rate by the process wastewater feed rate. A larger SFR would 

result in more organics being stripped from the wastewater. Steam feed rate is likely 

automatically controlled in conjunction with wastewater feed rate to ensure a minimum SFR is 

maintained. 

The ICR responses were reviewed to determine if mills reported issues with maintaining 

compliance with the parametric monitoring requirements during startup and shutdown. These 

responses to the PI Equip detail startup and shutdown questions are provided in Appendix G. 

Strippers are usually considered as pulping process equipment, and therefore, were not included 

in the PI Controls tab as an air pollution control device. Mills generally indicated that stripper 

operation would begin after the pulping vent gas collection and control system is ready to accept 

SOG, and after pulping processes have operated long enough for condensates to be generated for 

input into the steam stripper. Some mills noted that condensates may be sent to biotreatment for 

backup until the stripper is fully operational, that stripper operation does not begin until a 

sufficient level of condensates has been collected in the condensate tank, or that condensates 

must reach a specified temperature before they are sent to the stripper. Adequate condensate tank 

capacity serves as a buffer between the pulping process and steam stripper (e.g., allowing 

collection of condensates for a short time while the stripper is offline or in startup and shutdown 

mode). For example, one mill indicated that, “Condensates not sent to stripper until they have 

reached temperature,” which implies that the condensates are held until they reach the specified 

temperature parameter. This same mill also noted hard-piping as a backup condensate control 

option available during shutdown. Using the maximum of any ranges provided by respondents 

(e.g., for cold startup), the median startup and shutdown time for condensate strippers provided 

in the ICR responses (PI Equip detail tab) was 1 hour (for both startup and shutdown), with an 

average of 3 hours (for startup) and 2.4 hours (for shutdown). Presumably because of the 

practices noted above, no specific issues indicating the inability of mills to meet the stripper 

operating parameter limits during startup or shutdown were observed in the ICR responses. 

Therefore, development of separate standards during startup and shutdown periods for kraft 

condensates controlled by steam strippers were not explored further. 

An excess emissions allowance of 10 percent is currently available for condensate steam 

strippers and other in-process equipment serving the same function. This 10 percent allowance 

originally included startup and shutdown times (though this clarification is being removed from 

the rule). Although none of the ICR responses in Appendix G mentioned the 10 percent 

allowance in conjunction with startup and shutdown, EPA will have an opportunity to reconsider 

(based on additional the information submitted by the industry) whether startup and shutdown 
15

requires special consideration in the context of the excess emissions allowance when EPA 

considers how to address the allowance. 

Biological Wastewater Treatment. Mills using biological wastewater treatment to control 

kraft condensates must perform an initial test followed by quarterly sampling to determine the 

fraction of methanol biodegraded. The testing requirements differ somewhat for biotreatment 

systems that are thoroughly mixed versus non-thoroughly mixed, but the continuous parameter 

monitoring requirements are the same. Subpart S requires that mills monitor daily the outlet 

soluble 5-day biochemical oxygen demand (BOD5) concentration, mixed liquor volatile 

suspended solids (MLVSS), horsepower of aerator units, inlet liquid flow, and liquid 

temperature. In addition, mills must obtain daily inlet and outlet liquid grab samples from each 

biological treatment unit to have HAP data available to perform quarterly performance tests and 

to store until after the BOD5 results are obtained. Alternatively, mills can conduct daily 

monitoring of the site-specific parameters approved by the Administrator. Biological wastewater 

treatment systems (e.g., aerated stabilization basins or activated sludge treatment units) differ 

from in-process condensate treatment technologies (e.g., steam strippers or in-process 

biotreatment units dedicated to condensate control), because these wastewater treatment systems 

typically accept wastewaters from all over the mill and must be up and running at all times to 

comply with National Pollutant Discharge Elimination System (NPDES) requirements under the 

CWA. Mill-wide biological wastewater treatment systems were distinguished from in-process 

condensate controls in a clarification that the 10 percent excess emissions allowance does not 

apply for mill-wide wastewater treatment systems. (63 FR 49457, September 16, 1998) 

Standards that would apply only during startup and shutdown are not relevant for mill-wide 

wastewater treatment systems that must be up and running at all times. Consequently, the 

development of separate standards during startup and shutdown periods for kraft condensates 

controlled by biotreatment were not explored further. 

IV. Summary 

 Responses to startup and shutdown questions in Part I of the pulp and paper ICR were 

reviewed to determine the nature and extent of issues mills would have upon removal of the 

startup and shutdown exemption from subpart S, to assess whether there is a need for separate 

standards (other than the normal operational standards) to apply during startup and shutdown 

periods, and to determine what separate standards could apply. Rather than revealing a 

prevalence of issues with meeting the normal operational standards during startup and shutdown, 

the ICR data indicated that the majority of mills are meeting the subpart S continuous 

compliance requirements during startup and shutdown. 

A possible exception recommended for further consideration is equipment with excess 

emissions allowances which are retained in subpart S pending further analysis (e.g., NCG 

collection systems with computer-monitored bypass lines). Additional information pertaining to 

the excess emissions allowances will aid in evaluating whether it is necessary to vent NCGs 

during startup and shutdown or if there are startup and shutdown implications for steam 

strippers. If future analyses of the excess emissions allowances show that it is necessary to 

distinguish between startup and shutdown periods and normal operations (e.g., in the absence of 
16

excess emissions allowances), the EPA will be able to revisit applicability of separate standards 

for startup and shutdown in conjunction with action on the excess emissions allowances. 
Appendix A

Part I Survey Startup and Shutdown Questions
Appendix A

Emission Unit Startup and Shutdown Questions from Part I of the ICRData base field Survey Question Survey Spreadsheet Notes

Spreadsheet menu choices

(in additon to write in option)

SU_Duration_hrs Approximate duration of emission unit startup (hours)

Supply startup/shutdown information for equipment (including collection systems or APCDs) that

appear in the Emission Unit ID column (except thermal oxidizers). Enter startup/shutdown information for thermal oxidizers in the PI Controls tab.Enter approximately how long it takes for the emission unit to startup. Use decimals if less than one hour (e.g., 18 minutes = 0.3 hr).Supply information for routine startup and shutdown events such as events associated with planned mill downtime. (Do not provide information for startup/shutdown events associated with control device or emission unit malfunctions)."Startup" means the setting in operation of an affected source or portion of an affected source for any purpose.

SU_EmissRednMeas Measures employed to reduce air emissions during emission unit startup (if any) Select from menu or write in

>emission unit and control device operates in com

parameter limits during emission unit startup

>emission unit and control device operates during 

necessarily in compliance with all NSPS/NESHAP p

>backup/alternate control

>NA ‐ applicable emission and parameter limits no

during startup

SU_MarkEnd

What marks the end of emission unit startup and beginning of normal operating conditions?

Write in response specifying when startup ends and normal operation begins (e.g., Startup ends when the auxiliary burners switch off and material throughput begins to flow.)

SD_Duration_hrs Approximate duration of emission unit shutdown (hours)

Enter approximately how long it takes for the emission unit to shutdown. Use decimals if less 

than one hour (e.g., 18 minutes = 0.3 hr)."Shutdown" means the cessation of operation of an affected source or portion of an affected source for any purpose.

SD_EmissRednMeas Measures employed to reduce air emissions during shutdown (if any) Select from menu or write in

>continue routing emissions to collection system 

system>stop routing process condensates to stripper bef

>NA ‐ applicable emission and parameter limits no

during shutdown>emission unit and control device operates during 

necessarily in compliance with all NSPS/NESHAP p

>Temperature drops below ____F

SD_MarkBegin

What marks the end of normal operating conditions and beginning of emission unit shutdown?

Write in response specifying when shutdown begins and normal operation ends (e.g., Shutdown begins when material throughput ceases to flow.)

SU_SD_Recommend

Optional: Do you wish to recommend a standard that would apply during startup or shutdown of this emission unit? If so, please describe the event to which the standard would apply; the recommended standard (this could be an emission limitation, work practice, or operational standard) that would apply during the period; the basis for the recommended standard; why and how the standard would minimize emissions during the event; and how would compliance be determined and/or monitored. Supply as a separate attachment to your survey response if necessary.

OPTIONAL QUESTION. Input on appropriate standards that would be reasonable for your pulp and paper source category emission units is requested. Supply recommendations for the specific equipment (including collection systems or APCDs) appearing in the Emission Unit ID column.

SSM_MEMO_S_Appendices.xlsx 
Appendix A

Control Device Startup and Shutdown Questions from Part I of the ICRData base field Survey Question Survey Spreadsheet Notes

Spreadsheet menu choices

(in additon to write in option)

APCD_SU_Duration_hrs Approximate duration of control device startup (hours)

Supply startup/shutdown information for the equipment that appears in the APCD_ID column.Enter approximately how long it takes for the control device to startup. Use decimals if less than one hour (e.g., 18 minutes = 0.3 hr). Supply information for routine startup and shutdown events such as events associated with planned mill downtime. (Do not provide information for startup/shutdown events associated with control device or emission unit malfunctions)."Startup" means the setting in operation of an affected source or portion of an affected source for any purpose.

APCD_SU_Integration

Explain how control device startup is integrated with (dependent upon) emission unit startup/operation

Select from menu, expand on menu response, and/or write in. For example, is a certain gas flow rate from the emission unit required before the control device operating parameter limits can be met? Is a certain heating value from the emission unit exhaust gas required to achieve control device temperature?

>Control device is started up and meets required 

before emission unit is started up.

>Control device cannot be started prior to emissio

issue or risk of property damage. {Explain}>Control device cannot function as designed unle

acfm from the emission unit is achieved.

APCD_SU_ParamDeviation

List any control device continuous emissions monitoring or operating parameter limits that cannot be met during control device startup

List any control device parameter limits that cannot be met during control device startup. Certain parameters may be "instant on" while others are more transient in nature. Examples could include control device temperature that must heat up to a set point, or pressure drop that cannot be achieved due to low exhaust gas flow from the emission unit. The EPA is particularly interested in emission limits or parameter limits originating from the pulp and paper NSPS or NESHAP that cannot be met during control device startup or shutdown.Select from menu if the applicable emission and parameter limits are expected to be met during 

startup.

The applicable emission and parameter limits are 

startup

APCD_SU_EmissRednMeas

Measures employed to reduce air emissions during control device startup (if any) Write in response (if any).

APCD_SU_MarkEnd

What marks the end of control device startup and beginning of normal operating conditions?

Write in response specifying when control device startup ends and normal operation begins (e.g., Startup ends when oxidizer temperature set point of 1200F is reached.)

APCD_SD_Duration_hrs Approximate duration of control device shutdown (hours)

Enter approximately how long it takes for the control device to shutdown. Use decimals if less 

than one hour (e.g., 18 minutes = 0.3 hr)."Shutdown" means the cessation of operation of an affected source or portion of an affected source for any purpose.

APCD_SD_Integration

Explain how control device shutdown is integrated with (dependent upon) emission unit shutdown

Select from menu, expand on menu response, and/or write in. For example, is a certain gas flow rate from the emission unit required for the control device operating parameter limits to be met? Is a certain heating value from the emission unit exhaust gas required to achieve control device temperature?

>Control device continues to operate and meets r

emission unit is shut down.

>Control device cannot operate during emission u

or risk of property damage. {Explain}>Control device cannot function as designed unle

acfm from the emission unit is achieved.

APCD_SD_ParamDeviation

List any control device continuous emissions monitoring or operating parameter limits that cannot be met during control device shutdown

List any control device parameter limits that cannot be met during control device shutdown. Certain parameters may be "instant off" while others are more transient in nature. Examples could include control device temperature that decreases from the set point as shutdown progresses, or pressure drop that cannot be achieved due to low exhaust gas flow from the emission unit. The EPA is particularly interested in emission limits or parameter limits originating from the pulp and paper NSPS or NESHAP that cannot be met during control device startup or shutdown.Select from menu if the applicable emission and parameter limits are expected to be met during 

shutdown.

The applicable emission and parameter limits are 

shutdown

APCD_SD_EmissRednMeas

Measures employed to reduce air emissions during control device shutdown (if any) Select from menu or write in

APCD_SD_MarkBegin

What marks the end of normal operating conditions and beginning of control device shutdown?

Write in response specifying when shutdown begins and normal operation ends (e.g., Shutdown begins when the burners are shut off.)

APCD_SU_SD_Recommend

Optional: Do you wish to recommend a standard that would apply during startup or shutdown of this control device? If so, please describe the event to which the standard would apply; the recommended standard (this could be an emission limitation, work practice, or operational standard) that would apply during the period; the basis for the recommended standard; why and how the standard would minimize emissions during the event; and how would compliance be determined and/or monitored. Supply as a separate attachment to your survey response if necessary.

OPTIONAL QUESTION. Input on appropriate standards that would be reasonable for your pulp and paper source category control system is requested. Supply recommendations for the specific APCD appearing in the APCD_ID column.

SSM_MEMO_S_Appendices.xlsx 
Appendix B

Matrix of Subpart S Standards, Control Systems, and 

Initial and Continuous Compliance Demonstration Requirements
Appendix B

Appendix B. Summary of MACT Subpart S Standards, Test Methods, and Monitoring Requirements

Subpart S Standards Typical source control systems Control system Gaseous organic HAP standard Emissions Testing Method 

(1) Reduce total HAP emissions by ≥98 wt%; or Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat. 

(2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O2 (dry basis); 

or

Methanol. Method 308 (Part 63) outlet. Initial test + 5-year repeat. 

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600°F and ≥0.75 sec residence time; 

or

None 

(1) Reduce total HAP emissions by ≥98 wt%; or Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat. (4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or

None 

(5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the combustion air

None 

(1) Reduce total HAP emissions by ≥98 wt%; or Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat. 

(2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O2 (dry basis); 

or

Methanol. Method 308 (Part 63) outlet. Initial test + 5-year repeat. 

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600°F and ≥0.75 sec residence time; 

or

None 

(4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or

None 

(1) Reduce total HAP emissions by ≥98 wt%; or Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat. 

(2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O2 (dry basis); 

or

Methanol. Method 308 (Part 63) outlet. Initial test + 5-year repeat. 

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600°F and ≥0.75 sec residence time; 

or

None 

(4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or

None 

(5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the combustion air

None 

(1) Reduce total HAP emissions by ≥98 wt%; or Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat. 

(2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O2 (dry basis); 

or

Methanol. Method 308 (Part 63) outlet. Initial test + 5-year repeat. 

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600°F and ≥0.75 secs residence time; 

or

None 

(1) Reduce total HAP emissions by ≥98 wt%; or Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat. (4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or

None 

(5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the combustion air

None 

(1) Reduce total HAP emissions by ≥98 wt%; or Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat. 

(2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O2 (dry basis); 

or

Methanol. Method 308 (Part 63) outlet. Initial test + 5-year repeat. 

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600°F and ≥0.75 secs residence time; 

or

None 

(4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or

None 

(1) Reduce total HAP emissions by ≥98 wt%; or Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat. 

(2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O2 (dry basis); 

or

Methanol. Method 308 (Part 63) outlet. Initial test + 5-year repeat. 

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600°F and ≥0.75 secs residence time; 

or

None 

(4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or

None 

(5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the combustion air

None 

Kraft pulping vent gases3:

Existing sources: LVHC system1; 

knotter or screen (above HAP cutoffs), pulp washing, decker (using contaminated water), and O2 delignification.New sources: Same as existing, except applies for all knotters, screens, and deckers plus weak liquor storage tanks.

Route through a closed 

vent collection system to 

a boiler, lime kiln, 

recovery furnace, or 

thermal oxidizer

Thermal oxidizer

Lime kiln

BoilerBoiler

Lime kiln

Recovery furnaceRecovery furnace

Soda or semichemical pulping vent 

gases

3

:

Existing sources: LVHC system1

New sources: Same as existing, plus pulp washing system.

Route through a closed vent collection system to a boiler, lime kiln, recovery furnace, or thermal oxidizer

Thermal oxidizer

AppB_Matrix 
Appendix B

Subpart S Standards Typical source control systems Control system Gaseous organic HAP standard Emissions Testing Method 

(1a) Ca- or Na-based: Emit total HAP (as methanol) ≤0.89 lb/ton ODP, or Methanol. Method 308 (Part 63). Initial test + 5-year repeat.

(1b) Ca- or Na-based: Reduce total HAP (as methanol) by ≥92%; Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat.

(2a) NH3- or Mg-based: Emit total HAP (as methanol) ≤2.2 lb/ton ODP, or Methanol. Method 308 (Part 63). Initial test + 5-year repeat.

(2b) NH3- or Mg-based: Reduce total HAP (as methanol) by ≥87%. Methanol. Method 308 (Part 63) inlet/outlet. Initial test + 5-year repeat.

(1) Reduce total chlorinated HAP (except chloroform) limit≥99 wt%, or

(2) Meet ≤10 ppmv of total chlorinated HAP (except chloroform) at control device outlet, or(3) Meet ≤0.002 lb total chlorinated HAP (except chloroform)/ton ODP at control device outlet.(4) Work practice for chloroform - either meet effluent guideline OR use no hypochlorite or chlorine for bleaching. NA (initial notification only) 

Enclosures, openings, and 

hoods

--Maintain negative pressure, and--If closed during the initial performance test, must be closed during operation except for sampling, inspection, maintenance, or repairs

Demonstrate negative pressure by using anemometer or smoke tubeto demonstrate flow into the enclosure opening; measuring static pressure across the opening; or using another administrator-approveindustrial ventilation test method. Initial and annual test.

Components operated at 

positive pressure Operate with no detectable leaks (<500 ppmv VOC above background) Method 21 (Part 60), Leak Detection. Initial and annual test.

Bypass lines that could 

divert vent streams 

containing HAPs to the 

atmosphere

--Operate computer-controlled flow indicator to monitor for presence of gas stream flow in the bypass line at least once every 15 minutes, OR--Maintain bypass line valves that are not computer controlled in the closed position, sealed so that the valve or closure mechanism cannot be opened without breaking the seal.

Chlorine (surrogate for chlorinated HAP, except chloroform). Meth26A as modified by 63.457(b)(5). Initial + 5-year repeat test. 

Sulfite pulping vent gases3:

Existing sources: Digester vent, evaporator vent, and pulp washing.New sources: Same as existing, plus strong and weak liquor storage tanks, and acid condensate storage tanks.

Route through a closed vent collection system to a scrubber or other control device (emission limits apply to combined emissions from vents, control device wastewater, and condensates)

Scrubber

(One co-located kraft and 

Na-sulfite mill uses lime 

kiln for incineration of 

sulfite pulping vent gases)

New and existing bleaching vent 

gases

4: Chlorine bleaching systems, 

kraft/sulfite/soda bleaching with any chlorinated compounds, and mechanical/secondary fiber/non-wood bleaching with ClO2. 

Route through a closed vent collection system to a caustic scrubber or similar device6

Caustic Scrubber

Closed-vent system (for gas collection from pulping or bleaching vents)

AppB_Matrix 
Appendix B

Subpart S Standards Typical source control systems Control system Gaseous organic HAP standard Emissions Testing Method 

(1) Reduce total HAP emissions by ≥98 wt%; or(2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O2 (dry basis); 

or

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600°F and ≥0.75 secs residence time; 

or

(1) Reduce total HAP emissions by ≥98 wt%; or(4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or(5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream 

is introduced with the combustion air

(1) Reduce total HAP emissions by ≥98 wt%; or(2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O2 (dry basis); 

or

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600°F and ≥0.75 secs residence time; 

or

(4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or(1) Reduce total HAP emissions by ≥98 wt%; or(2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O2 (dry basis); 

or

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600°F and ≥0.75 secs residence time; 

or

(4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or(5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream 

is introduced with the combustion air

(1) Reduce total HAP ≥92 wt%; or

(2a) For mills without bleaching, remove ≥6.6 lb total HAP/ton ODP, or

(2b) For mills without bleaching, meet≤210 ppmw total HAP at control device outlet; or

(3a) For mills with bleaching, remove ≥10.2 lb total HAP/ton ODP, or(3b) For mills with bleaching, meet≤330 ppmw total HAP at control device outlet

(Nonthoroughly Mixed)

Open Biological Treatment 

(e.g., ASB, AST)

(1) Reduce total HAP ≥92 wt%; or

(2a) For mills without bleaching, remove ≥6.6 lb total HAP/ton ODP, or

(2b) For mills without bleaching, meet ≤210 ppmw total HAP at control device outlet; or(3a) For mills with bleaching, remove ≥10.2 lb total HAP/ton ODP, or(3b) For mills with bleaching, meet ≤330 ppmw total HAP at control device outlet.

Initial & subsequent performance test - (1) The value of the biorate constant, Ks;(2) The number and characteristics of each zone in the open biologic

treatment unit (depth, area, characterization parameters for surface aeration, submerged aeration rates, biomass concentration, concentrations of organic compounds, dissolved oxygen (DO), dissolved solids, temperature, and other relevant variables); and (3) The recycle ratio of internal recirculation between the zones. The number of zones and the above characterization of the zones are also used to determine the performance of the unit under the unsafe sampling conditions of concern.

(1) Reduce total HAP ≥92 wt%; or

(2a) For mills without bleaching, remove≥6.6 lb total HAP/ton ODP, or(3a) For mills with bleaching, remove≥10.2 lb total HAP/ton ODP, or(2b) For mills without bleaching, meet ≤210 ppmw total HAP at control device outlet; or(3b) For mills with bleaching, meet≤330 ppmw total HAP at control device outlet(1) Reduce total HAP ≥92 wt%; or

(2a) For mills without bleaching, remove ≥6.6 lb total HAP/ton ODP, or

(3a) For mills with bleaching, remove ≥10.2 lb total HAP/ton ODP, or(2b) For mills without bleaching, meet≤210 ppmw total HAP at control device outlet; or

(3b) For mills with bleaching, meet ≤330 ppmw total HAP at control device outlet.

Boiler

Lime kiln

Kraft pulping process condensates (process liquids) from digester, turpentine recovery, evaporator, LVHC system1, and HVLC system 2 

(some exceptions)Collection and Control must include one of the following:1) All Condensate Streams2) Volume Reduction option 1: Treat all LVHC & HVLC collection system streams plus streams that contain 65% of the total HAP mass from the digester system, turpentine recovery system, and evaporator system (only condensates from weak liquor feed vapors and vacuum system)3)Volume Reduction option 2: Treat any subset of the regulated streams that contain in total 7.2 lbs HAP per ODT pulp that do not perform bleaching or 11.1 lbs HAP per ODT pulp at mills that perform bleaching

Recycling: Route condensates through a closed vent collection systems to pulping equipment controlled by kraft pulping vent gas standardsRoute to biological treatment/steam stripper or other control device

Other equipment serving 

same function as stripper 

(e.g., in-process 

biotreatment unit)

Thermal oxidizer

NA - For the recycle treatment option, the performance test would consist only of verifying that no leaks were present in the condensatclosed collection system, and confirming closed vent gas system and control device requirements.See Kraft pulping vent gases standards. 

(Throughly Mixed)

Biological Treatment (e.g., 

ASB, AST)

Steam Stripper

Recovery furnace

Initial M305 for total HAP concentration & value of "R", and Part 63 App C (WATER 8/9) for fraction of total HAPs removed, Fbio. Total HAP = methnaol, acetetaldehyde, MEK, and propionaldehye.Quarterly - M305 for methanol, and use percent reduction methanoprocedureInitial M305 for total HAP (as MeOH). Outlet only.Initial M305 for total HAP (as MeOH). Inlet and outlet.Initial M305 for total HAP (as MeOH). Inlet and outlet.Initial M305 for total HAP (as MeOH). Outlet only.

AppB_Matrix 
Appendix B

Subpart S Standards Typical source control systems Control system Gaseous organic HAP standard Emissions Testing Method 

Indiviual Drain system

(1) Covers, water seals, and other air emission control equipment (2) Hard-piping.(3) Venting of the individual drain system through a closed vent system to a control device in accordance with the following requirements: (i) The individual drain system is designed and operated such that an internal pressure in the vapor headspace in the system is maintained at a level less than atmospheric pressure when the control device is operating, and

Closed collection systems used to transport pulping process condensates containing HAPs must meet all of the individual drain system requirements specified in §63.960, 63.961, and 63.962 of Subpart RR except that any air vents in the collection system must meet standards of §63.443 (c) and (d) for the closed vent systems anHAP reductions for kraft pulping system vent emissions. Subpart RR of 40 CFR 63 (National Emission Standards for Individual Drain Systems) establishes design, operating, inspection, and monitoring requirement standards for controlling air emissions from individual drain systems. The standards control emissions from individual draisystems using covers or seals, or hard-piping. Subpart RR also requires inspections of water seals and closure devices for defects or damage initially and establishes repair requirements for individual drain systems. The NESHAP requires inspection every 30 days.

Condensate Tank

i) The fixed roof and all openings (e.g., access hatches, sampling ports, gauge wells) shall be designed and operated with no detectable leaks as indicated by an instrument reading of less than 500 parts per million above background, and vented into a closed-vent system that meets the requirements in §63.450 and routed to a control device that meets the requirements in §63.443(d); and(ii) Each opening shall be maintained in a closed, sealed position (e.g., covered by a lid that is gasketed and latched) at all times that the tank contains pulping process condensates or any HAP removed from a pulpin

process condensate stream except when it is necessary to use the opening for sampling, removal, or for equipment inspection, maintenance, or repair.

Closed Vent system See Closed Vent System Standards See Closed Vent System Standards 

Control Device See Kraft Pulping Vent Gases Standards See Kraft Pulping Vent Gases Standards 

Clean condensate alternative (CCA) is an emissions averaging approach to offset emissions from certain existing kraft pulping sources.

Install and operate clean condensate alternative technology.

Install and operate clean condensate alternative technology.

Emissions reductions from CCA ≥ emissions reductions achieved through kraft pulping HVLC system standards

Initial performance test (before and after CCA implementation to document baseline emissions and emissions reductions)

1The LVHC system includes digester, turpentine recovery, evaporator, and steam strippers2The HVLC system includes pulp washing, knotter, screen, decker, O2 delignification, weak liquor storage tanks

3New & Existing sources shall be enclosed and vented into a closed-vent system and routed to a control devic4New & existing sources shall be enclosed and vented into a closed-vent system and routed to a control device but, if process modifications are used to achieve compliance with the bleaching emission limits (2) or (3), enclosures and closed-vent systems are not required5Based on the 2011 ICR Survey results no mills are using methanol CEMS6Some mills may be able to meet the outlet concentration or mass limits through use of a process modifications (i.e., 100 percent chlorine dioxide substitution). In these cases, enclosures and closed-vent systems are not requiNotes:Methanol is the surrogate (alternative) HAP represetnative of "total HAP" for pulping vent gases. The ICR data did not reflect any mills measuring "total HAP" so we refer to methanol in the table above.M305 measures process liquid HAP concentration

Closed collection system for kraft 

condensates

The mill can meet the closed collection system requirements in two ways:• Hardpiping• Use existing drains, but cover all openings and route all open vents through a closed-vent collection system to a control device meeting the NESHAP requirements for pulping system vents.If there are air vents off the closed collection system, these vents must be routed to a closedvent system. These air vents must comply with the kraft pulping system standards for closed-vent systems and HAP emissions.

AppB_Matrix 
Appendix C

ICR Data Relevant for the 

Kraft, Soda, and Semichemical Pulping Vent Gas Standards

Appendix C1 - Counts of Compliance Options Reported in PI Equip detail for Kraft, 

Soda, and Semichemical Pulping Vent Gases

Appendix C2 - Query of Part I Survey Data Base (PI Equip detail tab) for NCGGenerating Processes and Collection Systems

Appendix C3 - Query of Part I Survey Data Base (PI Equip detail tab) for Equipment 

that Burns NCGs (Boilers, Incineration Control Devices, Lime Kilns, and DCE or NDCE 

Recovery Furnaces) 

Appendix C4 - Startup and Shutdown Responses for Incineration Controls in the PI 

Controls tab of the ICR
Appendix C1

Counts of Compliance Options Reported in PI Equip detail for Kraft, Soda, and 

Semichemical Pulping Vent Gases
Appendix C

Appendic C1. Counts of Compliance Options Reported in PI Equip detail for Kraft, Soda, and Semichemical Pulping Vent Gases Counts transposed to gauge how common each NCG complinace option is used

RTI_SCompOption CountOfRTI_SCompOption

(1) Reduce total HAP

emissions by ≥98 wt%

(2) Reduce total

HAP concentration

at the outlet of

thermal oxidizer to

≤20 ppmv @ 10%

O2 (dry basis); or

(3) Reduce total HAP

emissions using a

thermal oxidizeroperating ≥1600°Fand ≥0.75 sec

residence time; or

(4) Use a b

RF in whic

gas stream 

introduce

primary fu

flame zon

63.443(d)(4) ‐ NCGs into combustion zone, minimum time and temperature 46 46

Collect >7.2 Lb/ODTP of HAP from kraft & NSSC and route to hard pipe system; introduce vent gas stream with the primary fuel

or into the flame zone of power boiler 12, power boiler 13, lime kiln 3, and/or lime kiln 4 via closed vent system 49 

Incineration control 55 

Incineration control (boiler) 9 

Incineration control (HVLC, RF) 13 

Incineration control (LVHC, boiler) 20 

Reduce total HAP concentration at the outlet of thermal oxidizer to <20 ppmv @ 10% O2 (dry basis) 293 293

Reduce total HAP emissions by 98 wt% 194 194

Reduce total HAP emissions by 98 wt%; Treat condensates to remove 6.6 lb HAP per ton ODP 1 1

Reduce total HAP emissions using a thermal oxidizer operating >1600F and >.75 secs residence time 235 235

Remove at least 11.1 lb/ODTP (approved alternate) and control remaining offgas as LVHC. Reduce total HAP concentration at

the outlet of thermal oxidizer to <20 ppmv @ 10% O2 (dry basis). 3 3

Total HAP emissions from equipment shall be controlled and vented into a closed vent system and routed to a control device. 24 

Total HAP emissions from equipment shall be controlled and vented into a closed vent system and routed to a control device.

Condensates shall be collected and treated to meet requirements. 25 

Use a boiler or RF with a heat input capacity >150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the

combustion air 339 Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone [Satisfies incineration‐

based HAP limits for sulfite‐Na pulping] 1 

Use a boiler, LK, or RF in which the HAP gas stream is introduced with the primary fuel into the flame zone 1299 1

WESP control 1

Total 195 296 281 1

Conuts correspond to individual emission units, as listed in the PI Equip Detail tab. Percentage of total 8% 12% 11% 5

Query: RTI_SCompOption_count Total rows where Subpart S compliance option specified 

These two options do not require any testing/monitoring ‐ used for 69% of em

AppC1_RTI_SCompOpt_query 
Appendix C2

Query of Part I Survey Data Base (PI Equip detail tab) for NCG-Generating Processes 

and Collection Systems
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Condenser

Condenser INC_LK 226 1 0.25 0.25 ensure primary and backup control are available HPD stripper is in operation 0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Condenser INC_LK/SCBR 121 1 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Chips are being cooked NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Condenser INC_LK/SCBR 177 1 6‐8 hours

(range

includes

startup of

evaporator

process

equipment)

8 continue routing emissions to EU0905 or EU1151 When evaporators are at target

production rate and product

liquor is being pumped to theheavy liquor storage tank.

6‐8 hours

(range

includes

shutdown of

evaporator

process

equipment)

8 continue routing emissions to EU0905 or EU115

Condenser INC1 116 1 ~3 hrs 3 BEFORE startup of the Steam Stripper Off‐Gas

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.

Dependant on equipment

systems feeding tank

~3 hrs 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Condenser INC1 139 1 0.1 0.1 LVHC in service. Digester relief/blow valves

open

0.1 0.1 LVHC in service. 

Kraft Pulp Storage

Kraft Pulp Storage INC1 181 1 0.1 0.1 emissions collected and routed to a control

device during startup (except following cold

outage)

Reject pump starts 0.1 0.1 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: BL Tanks HVLC

Kraft Pulping: BL Tanks HVLC COND/INC_BOIL 112 8 Collection and control systems operating before

start‐up

When liquor enters tank continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: BL Tanks HVLC INC_BOIL 131 1 10 10 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Fiberlizers and stock pump on 10 10 continue routing emissions to HV01 collection

system and primary or backup control system

Kraft Pulping: BL Tanks HVLC INC_BOIL 154 1 0.25 0.25 Emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Reactor is dischargingcontinuous stock flow

1 1 Continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: BL Tanks HVLC INC_BOIL 154 3 0.25 0.25 the emission unit is collected by the HVLC system When there is product in the

tank.

0.25 0.25 the emission unit is collected by the HVLC syste

Kraft Pulping: BL Tanks HVLC INC_BOIL 154 1 1 1 the emission unit is collected by the HVLC system Liquor feed in to and out of

tank established.

2 2 the emission unit is collected by the HVLC syste

Kraft Pulping: BL Tanks HVLC INC_BOIL 177 2 6‐20 hours

(range which

includes

startup of

digester

system

equipment).

20 continue routing emissions to EU1151 or EU0804 When digester reaches target

production rates and normal

cooking cooking conditions are

established.

6‐20 hours

(range which

includes shut

down ofdigester

system

equipment).

20 continue routing emissions to EU1151 or EU080

Kraft Pulping: BL Tanks HVLC INC_BOIL1 148 1 NA NA NA NA NA

Kraft Pulping: BL Tanks HVLC INC_BOIL1 148 3 NA NA NA NA NA 

Kraft Pulping: BL Tanks HVLC INC_BOIL1 600 6 Hot Startup:

2‐4 hours;

Cold Startup:

6‐12 hours

12 BEFORE Start Up (1) Confirm the LVHC System

control device is ready to accept gases and (2)Ensure equip is properly valved to the LVHC

Collection System.**Cut out hogging jet before

starting regular feed of liquor.

Operation has stabilized and

evaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hours;

Cold

Shutdown: 6‐

8 hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: BL Tanks HVLC INC_LK 117 1 1.5 1.5 Operate NCG Collection System during Start‐UP Target production rate reached 1.5 1.5 Operate kiln ‐ P36 while generating NCGs 

Kraft Pulping: BL Tanks HVLC INC_LK 175 1 NA BEFORE startup of any of the equipment

systems: (1) Confirm the WBL System collection

device is ready to accept gases and (2) Ensure

equipment is properly valved to the WBL

Collection System.

NA Continuing routing emissions to the WBL

Collection System

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: BL Tanks HVLC INC_LK 197 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

black liquor is being supplied to

the tank

2 2 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: BL Tanks HVLC INC_LK 203 1 0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: BL Tanks HVLC INC_LK/ESP 105 1 Hot Startup:

2 to 4 hours;

Cold Startup:

16 to 24

hours

24 BEFORE startup of the Digester Equipment

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Digester begins to blow pulp

and pulp blow flow stabilizes

Hot

Shutdown: 1

to 2 hours;

Cold

Shutdown: 8

to 16 hours

16 (1) Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: BL Tanks HVLC INC_RF 140 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Black Liquor is at 150 F and theflow to the evaporator is 400

gpm. Liquor is going to the

weak and strong black liquor

storage tanks.

continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: BL Tanks HVLC INC_RF 155 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

when stock flow to knotters >

500 gpm for 1 hr

0.25 0.25 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: BL Tanks HVLC INC_RF 182 2 UK UK UK UK UK 

Kraft Pulping: BL Tanks HVLC INC_RF 202 3 Startup

requirement

not required

to be defined

in current

SSM Plans

NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Startup requirement not

required to be defined in

current SSM Plans

Startup

requirement

not required

to be defined

in current

SSM Plans

NA ‐ applicable emission and parameter limitsnot expected to be exceeded during shutdown

Kraft Pulping: BL Tanks HVLC INC_RF 615 3 na na na na na 

Kraft Pulping: BL Tanks HVLC INC_RTO/SCBR 610 7 0 0 Power House HVLC collection fan on liquor flowing into the tank 0 0 Power House HVLC collection fan on 

Kraft Pulping: BL Tanks HVLC INC_RTO/SCBR 610 2 8.333333333

33333E‐02

0.083333333 emission unit and control device operates in

compliance with parameter limits during

emission unit startup

Any liquor flow into or out ofthe tank

8.333333333

33333E‐02

0.083333333 continue routing emissions to HVLC‐1 collectio

system and primary control system

Kraft Pulping: BL Tanks HVLC INC1 116 2 NA BEFORE startup of any of the equipment systems Dependant on equipment NA Continuing routing emissions to the LVHC 

feeding condensate to the tank: 1) Confirm the

LVHC System control device is ready to accept

gases and 2) Ensure equipment is properly valved

to the LVHC Collection System.

systems feeding tank Collection System and Control Device 

Kraft Pulping: BL Tanks HVLC INC1 150 4 6 6 continue routing emissions to HVLC‐1 collection

system and primary or backup control system

Determined by HVLC system 6 6 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: BL Tanks HVLC INC1 181 1 0.1 0.1 emissions collected and routed to a control

device during startup (except following cold

outage)

Reject pump starts 0.1 0.1 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: BL Tanks HVLC INC1 181 1 0.1 0.1 emissions collected and routed to a control

device during startup (except following cold

outage)

Surge Tank Pump starts 0.1 0.1 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: BL Tanks HVLC INC1 185 3 NA NA Tank Level NA NA 

Kraft Pulping: BL Tanks HVLC INC1/SCBR 136 17 NA NA NA NA NA 

Kraft Pulping: BL Tanks HVLC INC1_BOIL 149 4 0 0 rout emissions to HVLC collection system and

primary or backup control system

Not empty 0 0 rout emissions to HVLC collection system and

primary or backup control system

Kraft Pulping: Decker

Kraft Pulping: Decker INC_BOIL 154 2 0.25 0.25 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow 1 1 Continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Decker INC_BOIL 205 1 0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Completion of 30 minutes of

stock flow to knotter systemand 30 minutes of operation ofscreen feed pump

0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Decker INC_RF 119 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When No.21 Rec. Blr. is firing

black liquor, is stable and safety

interlocks are satisfied.

4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shut down

Kraft Pulping: Decker INC_RF 198 1 0.033 0.033 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

stock flow stable, pumps

running, no alarms, no rupture

disk failures

8 8 continue routing emissions to LVHC‐1 and HVLC

1 collection system and primary or backup

control system

Kraft Pulping: Decker INC_RF 615 2 1 1 Unit is only started if the associated collection

system is operating

Stock flow is established

through entire washer line

0.5 0.5 Associated collection system is operated throu

duration of shutdown

Kraft Pulping: Decker INC1 103 2 20 20 To minimize emissions during startup, the HVLC

NCG system is collecting gases prior to system

startup, the source vent and collection valve

positions are verified using the preliminary

checklist, and condition monitoring routes

provide routine visual checks of the collectionsystem.

Completion of startup isverified using the facility DCSand Process Explorer tags to

verify that the pulp washing

and screenng systems have

atained normal operatingconidtions.

8 8 Emissions of the pulp washing and screening

system are minimized during shutdown by

completing shut down of the process units prio

to shutting down the HVLC collection system.

Kraft Pulping: Decker INC1 150 1 0.5 0.5 continue routing emissions to HVLC‐1 collection

system and primary or backup control system

All four washer level controls in"Auto"

0.5 0.5 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Decker INC1 179 2 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Flow of stock form discharge of

decker.

0.25‐1 1 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Decker INC1 189 2 0 0 NA NA NA NA 

Kraft Pulping: Decker SCBR 150 1 2 2 continue routing emissions to BL‐B collection

system and primary or backup control system

Startup complete after 4 blows

and knotter supply pump is

running

1 1 continue routing emissions to BL‐B collection

system and primary or backup control system

Kraft Pulping: Decker SCBR 207 1 0.17 0.17 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

all valves lined up, pumps

running and stock acrossdeckers

0.17 0.17 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Decker SCBR 525 1 0 0 NA NA 0 0 NA 

Kraft Pulping: Digester LVHC

Kraft Pulping: Pulping: Digester Digester LVHC COND/INC BOIL COND/INC_BOIL 112 1 0 5. 0 5. Collection Collection and control control systems systems operating operating before When pulp liquor and gasses 10 10 continue routing emissions to LVHC‐1 collectio

start‐up

When pulp, liquor, and gasses

exit tank

10 10 continue routing emissions to LVHC 1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC COND/TO 112 1 0.5 0.5 Collection and control systems operating before

start‐up

When pulp, liquor, and gasses

exit tank

10 10 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC COND/TO 112 1 6 6 Collection and control systems operating before

start‐up

When full pulp flow from the

digester is obtained

10 10 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC COND/TO/SCBR 143 13 Hot: 0.5 ‐ 1.0

hours Cold:

3.0 ‐4.0

hours

4 (1)Confirm HVLC System and Treatment Units are

operating and determine if HVLC gases may be

routed to LVHC Treatment Unit; (2) Confirm

LVHC System and Treatment Units are operating

and route LVHC gases to LVHC Treatment Unit

Steady state operations andStock to the High Density

Storage Tank

Hot and Cold

: 0.5 hours

0.5 Maintain LVHC and HVLC Collection and

Treatment Systems until after the Blow Heat

Accumulator is shutdown

Kraft Pulping: Digester LVHC INC 147 2 0.3 0.3 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends when steam isapplied to the digester

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: Digester LVHC INC 148 1 1.5 1.5 Incineration source is online before startup of

source

When accumulator is warmed

up to proper temerpature

0.5 0.5 Incineration source is still online until source is

shutdown

Kraft Pulping: Digester LVHC INC 148 1 10 10 Incineration source is online before startup of

source

When stable chip speed (rpm) is

reached

1 1 Incineration source is still online until source is

shutdown

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC 175 2 Hot Startup:

2‐4 Hours

Cold Startup:

16‐24 Hours

24 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

conditions are met.

Hot

Shutdown: 1‐

2 Hour

Cold

Shutdown: 8‐

16 Hours

16 (1) Continuing routing emissions to the LVHC

System and Control Device until all sourcessystems are shut down (2) Operate the DigesteSystem in such a way as to prevent over

pressurization of system during shutdown. (3)Maintain a chip level and switch to low pressur

fresh steam for chip bin pre‐steaming prior to

beginning the shutdown sequence.

Kraft Pulping: Digester LVHC INC 196 2 2.5 2.5 3 3 

Kraft Pulping: Digester LVHC INC 613 1 3 3 Per the SSM Plan:**Startup the digesters

following mill procedures. Insure that all NCG

vent gases are collected by the appropriate

colletion systems and sent to the appropriate

control device. Monitor the pressure relief

valves and other points where p

Per the SSM Plan:**Follow

procedures for Kiln/Oxidizer

System and NCG/SOG collection

system, found in the mill's SSMplan. Verify that the NCG/SOG

system is ready to accept vent

gases from the turpentine

system. Veryif y that the

turpentine recovery sys

3 3 Per the SSM Plan:

Shutdown as per mill operating procedures.Shutdown the digester system before shuttingdown the NCG vent gases collection system. Byvisual observation, the operator should insure

that vent gases are no longer being generated

before shutting down the NCG/SOG gas

collection system or diverting digester vent gas

to atmosphere.

Kraft Pulping: Digester LVHC INC 613 1 3 3 Per the SSM Plan:**Startup the digesters

following mill procedures. Insure that all NCG

vent gases are collected by the appropriate

colletion systems and sent to the appropriatecontrol device. Monitor the pressure relief

valves and other points where p

Per the SSM Plan:**Follow

procedures for Kiln/Oxidizer

System and NCG/SOG collection

system, found in the mill's SSMplan. Verify that the NCG/SOG

system is ready to accept vent

gases from the turpentine

system. Veryif y that theturpentine recovery sys

3 3 Per the SSM Plan:**Shutdown as per mill

operating procedures. Shutdown the digester

system before shutting down the NCG vent gas

collection system. By visual observation, theoperator should insure that vent gases are no

longer being generated before

Kraft Pulping: Digester LVHC INC (see note) 182 12 10 10 Verify cooling water system is operational,

operate NCG and foul condensate systems

properly

When pulp is transferred to the

blow tank

10 10 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Digester LVHC INC (see note) 182 4 30 30 Operate NCG and foul condensate systems

properly

When pulp is transferred to theblow tank

30 30 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Digester LVHC INC_BOIL 114 1 24 24 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

Digester production rate is>1000 ADMT/day

24 24 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

limits during emission unit startup

Kraft Pulping: Digester LVHC INC_BOIL 127 9 0.5 0.5 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

All valves in normal position 0.5 0.5 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Kraft Pulping: Digester LVHC INC_BOIL 127 3 0.75 0.75 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Blow tanks in normal operation 0.75 0.75 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Kraft Pulping: Digester LVHC INC_BOIL 145 1 0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

when full pulp flow from the

digester is obtained

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_BOIL 145 12 0.3 0.3 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

when full pulp flow from the

digester is obtained

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_BOIL 152 4 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

One hour of continuous

discharge to the blow tank

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_BOIL 154 2 0.1 0.1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous gas flow to

condenser is achieved

0.1 0.1 Continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_BOIL 154 1 0.1 0.1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Liquor feed to evaporator 8 8 Continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_BOIL 154 1 0.33 0.33 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Start of chip meter 0.5 0.5 Continue routing emissions to HVLC collection

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC_BOIL 154 2 0.5 0.5 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow 1 1 Continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_BOIL 154 1 0.5 0.5 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Liquor feed to evaporator 10 10 Continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_BOIL 154 1 0.5 0.5 Emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Liquor feed to evaporator 8 8 Continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_BOIL 173 1 3 ‐ 12 12 BEFORE startup of the Digester Equipment

System:1) Confirm the LVHC System control device is

ready to accept gases and 2) Ensure equipment

is properly valved to the LVHC Collection

System**Operate the Digester Equipment

System in such a way as to prevent over

pressurization of system upon startup.

Established blow flow, stock is

going across washers and

deckers, pulp going to high

density storage.

4 ‐ 12 12

1. Continuing routing emissions to the LVHCCollection System and Control Device

2. Operate the Digester Equipment System in

such a way as to prevent over pressurization of

system during shutdown.

Kraft Pulping: Digester LVHC INC_BOIL 173 1 3 ‐ 12 12 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

4 ‐ 12 12

1. Continuing routing emissions to the LVHCCollection System and Control Device

2. Operate the Digester Equipment System in

such a way as to prevent over pressurization of

system during shutdown.

Kraft Pulping: Digester LVHC INC_BOIL 173 1 3 ‐ 12 12 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System**Operate the Digester Equipment

System in such a way as to prevent over prevent

over pressurization of system upon startup.

Blow heat system standard

operating conditions are met

and digester is routinely

blowing

4 ‐ 12 12 1. Continuing routing emissions to the HVLC

Collection System and Control Device

2. Operate the Digester Equipment System in

such a way as to prevent over pressurization of

system during shutdown.

3.During emergency shutdowns, the should be

put on hold

Kraft Pulping: Digester LVHC INC_BOIL 173 1 3 ‐ 12 12 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

Blow heat system standard

operating conditions are met

4 ‐ 12 12 1. Continuing routing emissions to the HVLC

Collection System and Control Device**2.

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System**Operate the Digester EquipmentSystem in such a way as to prevent over prevent

over pressurization of system upon startup.

and digester is routinely

blowing

Operate the Digester Equipment System in suc

a way as to prevent over pressurization of

system during shutdown.**3.During emergenc

shutdowns, the should be put on hold

Kraft Pulping: Digester LVHC INC_BOIL 174 1 Hot Startup:

2 Hours

Cold Startup:

16 Hours

2 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

condition are met

Hot

Shutdown: 1

Hours

Cold

Shutdown:

12 Hours

12 (1) Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC INC_BOIL 174 1 Hot Startup:

2 Hours

Cold Startup:

4 Hours

2 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System.**Operate the Digester Equipment

System in such a way as to prevent over prevent

over pressurization of system upon startup.

Blow heat system standard

operating conditions are met

and digesters are routinely

blowing

Hot

Shutdown: 3

Hours

Cold

Shutdown: 3

Hours

3 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend thecooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC_BOIL 177 1 6‐20 hours

(range which

includes

startup of

digester

system

equipment).

20 continue routing emissions to EU1151 or EU0804 When digester reaches target

production rates and normal

cooking cooking conditions are

established.

6‐20 hours

(range which

includes shut

down ofdigester

system

equipment).

20 continue routing emissions to EU1151 or EU080

Kraft Pulping: Digester LVHC INC_BOIL 182 2 10 10 Verify cooling water system is operational,

operate NCG and foul condensate systems

properly

When pulp is transferred to theblow tank

10 10 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Digester LVHC INC_BOIL 195 1 0.5 0.5 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Chips feeding 1 1 All Control Equipment remain on‐line until

source is shut down.

Kraft Pulping: Digester LVHC INC_BOIL 200 1 6 6 At least one combination boiler should be fully

operational before the generation of theregulated pollutants is initiated

Chip system operating,

circulation pumps online,

digester blowing,and no alarms

6 6 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_BOIL1 600 2 Hot Startup:

2‐4 hours;

Cold Startup:

16‐24 hours

24 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System**Operate the Digester

Equipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

conditions are met and the

Digester System production

rate is greater than 20

ODTUP/day.

Hot

Shutdown: 1‐

2 hours; Cold

Shutdown: 8‐

16 hours

16 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester in such a way as to prevent overpressurization of system during shutdown

Kraft Pulping: Digester LVHC INC_BOIL1 600 24 Hot Startup:

2‐4 hours;

Cold Startup:

16‐24 hours

24 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevntover pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

conditions are met and the

Digester System production

rate is greater than 20

ODTUP/day.

Hot

Shutdown: 1‐

2 hours; Cold

Shutdown: 8‐

16 hours

16 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester in such a way as to prevent overpressurization of system during shutdown

Kraft Pulping: Digester LVHC INC_LK 115 1 13 13 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Digester Blowing stock to

storage

0.25 0.25 continue routing emissions to LVHC‐2 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK 117 1 4.5 4.5 Operate NCG Collection System during Start‐UP After 3 batch digester cycles 6 6 Operate kiln ‐ P36 while generating NCGs 

Kraft Pulping: Digester LVHC INC_LK 117 1 8 8 Operate NCG Collection System during Start‐UP All batch digesters on‐line and

completion of one cook cycle

6 6 Operate kiln ‐ P36 while generating NCGs 

Kraft Pulping: Digester LVHC INC_LK 132 8 <1 hour 1 Emissions collected in a closed system Simultaneous <1 hour 1 Emissions collected in a closed system 

Kraft Pulping: Digester LVHC INC_LK 132 1 1 hour 1 Emissions collected in a closed system Condensate flow > 30 gpm 1 hour 1 Emissions collected in a closed system 

Kraft Pulping: Digester LVHC INC_LK 157 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When the digester outlet ball

valve is open (V‐81)

4 4 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK 157 1 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Feeding sawdust 4 4 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK 178 1 NA Ensure the condensate collection system and

control device are in operation and all system

values are in the appropriate position before

initiating startup on the digesters or turpentinesystem

Standard operating conditions

are met and digesters are

gassing off routinely

NA Continuing routing condensates to the

Condensate System and Control Device

Kraft Pulping: Digester LVHC INC_LK 178 1 NA NA NA NA NA 

Kraft Pulping: Digester LVHC INC_LK 186 1 2 2 2 2Kraft Pulping: Digester LVHC INC_LK 186 1 2 2 When the chip meter is 5 rpm

for 15 minutes.

2 2 

Kraft Pulping: Digester LVHC INC_LK 186 8 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Chips present in any digester

and the Chemiwasher primary

screen accepts flow is greater

than 500 gpm.

2 2 

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC_LK 188 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Accumulator Temperature (hot

zone) approximately 200 ° F**Primary Condenser Pressure0.7 to 2.0 psig **

Entrainment Separator Pressure

Drop less than 2 psig**

Visible Emissions none

3 3 LVHC gases continue to be collected and

incinerated unitl shutdown is complete.

Kraft Pulping: Digester LVHC INC_LK 188 2 NA ‐ 

Equipment

Startup and

Shutdown is

dependent

on upstream

and

downstream

operations

emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

NA ‐ Equipment Startup and

Shutdown is dependent on

upstream and downstreamoperations

NA ‐ 

Equipment

Startup and

Shutdown is

dependent

on upstream

and

downstream

operations

NA ‐ Equipment Startup and Shutdown isdependent on upstream and downstream

operations

Kraft Pulping: Digester LVHC INC_LK 188 1 NA ‐ see

equipment

list within

EU126

NA ‐ see equipment list within EU126 NA ‐ see equipment list within

EU126

NA ‐ see

equipment

list within

EU126

NA ‐ see equipment list within EU126 

Kraft Pulping: Digester LVHC INC_LK 197 1 1.5 1.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

140# steam being supplied and

pulp mill running

1.5 1.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC INC_LK 199 2 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Digester system steam flow >

15,000 lb/hr for 1 hour

1 1 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK 202 2 See LVHC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup‐ 

with venting allowances for HVLC and LVHC

sources

See LVHC System ‐ not further

defined

See LVHC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

with venting allowances for HVLC and LVHCsources

Kraft Pulping: Digester LVHC INC_LK 203 1 0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC INC_LK 203 1 2.5 2.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Impregnation vessel feed screw

on

2.5 2.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK 203 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

wood feed on 4 4 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK 203 2 8 8 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

wood feed on 8 8 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK 205 1 4.0 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Completion of sixth digesterblow

1.0 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK 226 2 1 1 ensure primary and backup control are available White liquor flow to digester

>100 gpm + steaming vessel

pressure >3 PSI + chip meter > 5

RPM

0.3 0.3 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK 208228535 1 8 8 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Completion of 8 hours of chip

feed to digester system andproduction of digester blow

flow

1 1 continue routing emissions to LVHC‐7 collectio

system and primary control device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC_LK/ESP 105 1 Hot Startup:

2 to 4 hours;

Cold Startup:

16 to 24

hours

24 BEFORE startup of the Digester Equipment

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

condition are met.

Hot

Shutdown: 1

to 2 hours;

Cold

Shutdown: 8

to 16 hours

16 (1)Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC INC_LK/MC/SCBR 120 2 1 1 Kiln ready/Condensates to hard pipe Steam on digester initiates

beginning of normal operations.A steady building of pressure

inside the digester and a

corresponding rise in

temperature notifies theoperator of normal cooking

operations

1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC INC_LK/SCBR 121 2 24 24 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Chips are being cooked 8 8 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK/SCBR 121 4 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Chips are being cooked NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK/SCBR 159 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

when digesters are fully loaded 0.5 0.5 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK/SCBR 177 5 6‐20 hours

(range which

includes

startup of

digester

system

equipment).

20 continue routing emissions to EU0905 or EU1151 When digester reaches target

production rates and normal

cooking cooking conditions are

established.

6‐20 hours

(range which

includes shut

down ofdigester

system

equipment).

20 continue routing emissions to EU0905 or EU115

Kraft Pulping: Digester LVHC INC_LK1 197 1 1.5 1.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When the digester is loaded

with steam and chips

1.5 1.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK1 197 1 2.5 2.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When the digester is loaded

with steam and chips

2.5 2.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_LK1 600 7 Hot Startup:

0.5‐1 hours;

Cold Startup:

4‐6 hours

6 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevntover pressurization of system upon startup.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

Hot

Shutdown:

0.5‐1 hours;

Cold

Shutdown: 4‐

8 hours

8 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester in such a way as to prevent overpressurization of system during shutdown

Kraft Pulping: Digester LVHC INC_RF 104 1 Startup Hot ‐ 

3, Startup

Cold ‐ 24

24 BEFORE startup of the Digester Equipment

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Shutdown

Hot ‐ 4,

Shutdown

Cold ‐ 4

4 Continuing routing emissions to the NCG

Collection System and Control Device.

Operate the Digester Equipment System in suc

a way as to prevent over pressurization of

system during shutdown.

Kraft Pulping: Digester LVHC INC_RF 104 2 Startup Hot ‐ 

3, Startup

Cold ‐ 24

24 BEFORE startup of the Digester Equipment

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

No.1 Digester chip feed is at or

above 1150 BDT, No.2 Digester

chip feed is at or above 550

BDT, and the Dilute and

Concentrated NCG’s are being

incinerated.

Shutdown

Hot ‐ 4,

Shutdown

Cold ‐ 4

4 Continuing routing emissions to the NCG

Collection System and Control Device.

Operate the Digester Equipment System in suc

a way as to prevent over pressurization of

system during shutdown.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC_RF 108 2 Hot = 3‐4

Cold = 3‐4

4 BEFORE startup of the Digester Equipment

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

Hot = 3‐4

Cold = 3‐4

4 Continuing routing emissions to the LVHC

Collection System and Control Device; Operate

the Digester Equipment System in such a way a

to prevent over pressurization of system during

shutdown.

Kraft Pulping: Digester LVHC INC_RF 108 1 Hot = 3‐4

Cold = 3‐4

4 BEFORE startup of the Digester System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester System in such a

way as to prevent over pressurizati

Blow heat system standard

operating conditions are met

and digesters are routinely

blowing

Hot = 3‐4

Cold = 3‐4

4 Continuing routing emissions to the LVHC

Collection System and Control Device; Operate

the Digester Equipment System in such a way a

to prevent over pressurization of system during

shutdown; During emergency shutdowns, all

digesters should be put on hold to suspend thecooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Digester LVHC INC_RF 119 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When No.21 Rec. Blr. is firing

black liquor, is stable and safety

interlocks are satisfied.

4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shut down

Kraft Pulping: Digester LVHC INC_RF 140 3 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Motor status of the feed screw

in the pre‐steamer bin and the

hydraulic pressure of the screw

is on. Indicates the Wood is on

to the digesters.

continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_RF 180 2 0 0 Vented to Accumulator Fiber Discharge to Solvos 0 0 Vented to Accumulator Kraft Pulping: Digester LVHC INC_RF 180 9 0.1 0.1 Accumulator in service prior to start up, gas off

system and turpentine system in service prior to

startup.

Chip Loading 0.267 0.267 Accumulator in service during entire digester

cycle, gas off system and turpentine system in

service during entire digester cycle.

Kraft Pulping: Digester LVHC INC_RF 182 1 30 30 Operate NCG and foul condensate systems

properly

When pulp is transferred to theblow tank

30 30 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Digester LVHC INC_RF 198 1 0.016 0.016 emission unit and control device operates in stock flow stable, pumps 8 8 continue routing emissions to LVHC‐1 and HVLC

compliance with NSPS and NESHAP parameterlimits during emission unit startup

running, no alarms, no rupture

disk failures

1 collection system and primary or backup

control system

Kraft Pulping: Digester LVHC INC_RF 198 2 0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digester system temperatures

and pressures within normal

ranges, no alarms, no rupturedisk failures.

8 8 continue routing emissions to LVHC‐1 and HVLC

1 collection system and primary or backup

control system

Kraft Pulping: Digester LVHC INC_RF 615 2 1 1 Unit is only started if the associated collection

system is operating

Stock flow is established

through entire washer line

0.5 0.5 Associated collection system is operated throu

duration of shutdown

Kraft Pulping: Digester LVHC INC_RF 615 5 2 2 Unit is only started if the associated collection

system is operating

Sawdust belt turned on 1 1 Associated collection system is operated throu

duration of shutdown

Kraft Pulping: Digester LVHC INC_RF 615 4 4 4 Unit is only started if the associated collection

system is operating

Chip meter turned on 1 1 Associated collection system is operated throu

duration of shutdown

Kraft Pulping: Digester LVHC INC_RTO/SCBR 610 1 1 1 Use fresh steam on the chip bin and route to

HVLC‐1 when the chip bin is full

digester extraction flow > 150

gpm

1.25 1.25 Use fresh steam on the chip bin 

Kraft Pulping: Digester LVHC INC_TO 112 1 0.5 0.5 Collection and control systems operating before

start‐up

When gasses and condensate

exit condensers

10 10 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_TO 146 2 0.3 0.3 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends when steam is

applied to the digester

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC_TO 178 1 3 3 BEFORE startup of the Digester Equipment

System: 1) Confirm the LVHC System control

device is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection SystemOperate the Digester Equipment System in sucha way as to prevent over pressurization of

system upon startup.

3 3 Continuing routing emissions to the LVHC

Collection System and Control DeviceOperate

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown.

Kraft Pulping: Digester LVHC INC_TO 178 1 6 6 BEFORE startup of the Digester Equipment

System: 1) Confirm the LVHC System control

device is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System**Operate the Digester Equipment System in sucha way as to prevent over pressurization of

system upon startup.

3 3 Continuing routing emissions to the LVHC

Collection System and Control DeviceOperate

the Digester Equipment System in such a way a

to prevent over pressurization of system during

shutdown.

Kraft Pulping: Digester LVHC INC_TO 178 1 6 6 BEFORE startup of the Digester System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment is

properly valved to the LVHC Collection

System**Operate the Digester System in such a

way as to prevent over pressurization

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

3 3 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend thecooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Digester LVHC INC_TO 178 1 6 6 BEFORE startup of the Digester System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment isproperly valved to the LVHC Collection System.**

Operate the Digester System in such a way as to

prevent over pressurizat

Blow heat system standard

operating conditions are met

and digesters are routinely

blowing

3 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Operate the Digester Equipment System in suc

a way as to prevent over pressurization of

system during shutdown.During emergency

shutdowns, all digesters should be put on hold 

suspend the cooking process and blowing shou

be held until the Blow Heat System is back und

normal operating conditions.

Kraft Pulping: Digester LVHC INC_TO 178 1 NA BEFORE startup of the Digester System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment is

Blow heat system standard

operating conditions are met

and digesters are routinely

NA (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way a

properly valved to the LVHC Collection

System**Operate the Digester System in such a

way as to prevent over pressurization

blowing to prevent over pressurization of system during

shutdown (3)During emergency shutdowns, all

digesters should be put on hold to suspend the

cooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Digester LVHC INC_TO 178 5 NA BEFORE startup of the Digester System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester System in such a

way as to prevent over pressurizatio

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

NA (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way a

to prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend the

cooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Digester LVHC INC_TO/SCBR 137 1 1 1 FOLLOW SSM PLAN Screen Pump Load > 20% for 2

hours

12 12 FOLLOW SSM PLAN 

Kraft Pulping: Digester LVHC INC_TO/SCBR 137 2 6 6 FOLLOW SSM PLAN Metering Screw Feeder > 1 rpm

for 3 hours

12 12 FOLLOW SSM PLAN 

Kraft Pulping: Digester LVHC INC_TO/SCBR 138 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

A digester is blown. 1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_TO/SCBR 138 5 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Steam flow to the digesters

reaches 20 Mlbs/hr.

0.5 0.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC_TO/SCBR 143 5 Hot: 0.5 ‐ 1.0

hours Cold:

3.0 ‐4.0

hours

4 (1)Confirm HVLC System and Treatment Units are

operating and determine if HVLC gases may be

routed to LVHC Treatment Unit; (2) Confirm

LVHC System and Treatment Units are operating

and route LVHC gases to LVHC Treatment Unit

Steady state operations andStock to the High Density

Storage Tank

Hot and Cold

: 0.5 hours

0.5 Maintain LVHC and HVLC Collection and

Treatment Systems until after the Blow Heat

Accumulator is shutdown

Kraft Pulping: Digester LVHC INC_TO/SCBR 149 1 2 2 route emissions to LVHC collection system and

primary or backup control system

Blow first batch digester 1 1 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_TO/SCBR 155 13 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

when steam flow to digesters >20,000 lbs/hr for 4 hrs

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_TO/SCBR 243 1 0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digester begins blowing 0.25 0.25 continue routing emissions to NCG collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC_TO/SCBR 243 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

When digester begins steaming

process

1 1 continue routing emissions to NCG collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 100 6 ~4 hrs 4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating astartup on the digester system.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing.

~4 hrs 4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position until completing the

shutdown of the digester system.

Kraft Pulping: Digester LVHC INC1 100 2 ~4 hrs 4 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating astartup on the digester system.

Blow heat system standard

operating conditions are met

and digesters are routinely

blowing.

~4 hrs 4 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position until completing the

shutdown of the digester system.

Kraft Pulping: Digester LVHC INC1 100 3 ~8 hrs 8 Stop liquor flow and steam flow to the

evaporators prior to initiating shutdown of the

LVHC collection system.

Operation has stabilized andevaporator product is at target

percent solids.

~6 hrs 6 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position until completingshutdown of the Evaporator System(s).

Kraft Pulping: Digester LVHC INC1 102 1 24 24 Use low‐pressure fresh steam for chip bin pre‐ the digester operations are 1 1 Shut down the continuous digester system, 

steaming until a steady level is maintained and

the digester is running normally. Flash steam

may be used during normal operation. Check for

proper water seal levels and flows and verify all

pressure and vacuum seals. HVLC NCG system is

in a collect mode unless the system is down orlocked and tagged out. LVHC NCG vent gas

pressure is monitored. Pulping condensates are

sent to the appropriate collection systems.

stablethe Digester chip feed is above4.5 rpmblow flow greater than 1,100

gpmthe HVLC and LVHC NCG’s are

being collected

including associated tanks and other equipmenbefore shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condensates.

Kraft Pulping: Digester LVHC INC1 102 4 See DIG See DIG See DIG See DIG See DIG 

Kraft Pulping: Digester LVHC INC1 102 1 See PDW See PDW See PDW See PDW See PDW 

Kraft Pulping: Digester LVHC INC1 103 6 20 20 Use low‐pressure fresh steam for chip bin pre‐

steaming until a steady level is maintained and

the digester is running normally. Check for

proper water seal levels and flows and verify all

pressure and vacuum seals. HVLC NCG system is

in a collect mode unless the system is down orlocked and tagged out. LVHC NCG process source

or collection system may be vented duringstartup until it is safe to collect the gases.

Pulping condensates are sent to the appropriatecollection systems. Follow the proper startup

sequence and procedures outlined in the

appropriate sections for collection systems and

control devices. Due to NC Air Toxics limits, no

foul condensates are sewered.

The Continuous Digester

system startup is consideredcomplete when the digester

operations are stable, the No. 6

Digester chip feed is above 4.5

rpm, the No. 7 Digester chip

feed is above 6 rpm, and the

HVLC and LVHC NCGs are beign

incinerated.

8 8 Shutdown the continuous digester system,

including associated tanks and other equipmenbefore shutting down the respective collection

system.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC1 111 1 1.5 1.5 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless thesystem is down or locked and tagged out. LVHC

NCG process source or collection system may be

vented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSM

plan for collection systems and control devices.

The Continuous Digester

system startup is considered

complete target flow rateachieved.

3.5 3.5 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condenstates.

Kraft Pulping: Digester LVHC INC1 111 1 1.5 1.5 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless the

system is down or locked and tagged out. LVHC

NCG process source or collection system may bevented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSMplan for collection systems and control devices.

The Continuous Digester

system startup is consideredcomplete whentarget flow rate

achieved.

3.5 3.5 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condenstates.

Kraft Pulping: Digester LVHC INC1 116 1 Hot Startup:

3‐4 hrs

Cold Startup:

3‐4 hrs

4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating a

startup on the digester system(s).

Blow line flow and extraction

flow standard operating

condition are met.

Hot

Shutdown: 3‐

4 hrs

Cold

Shutdown: 3‐

4 hrs

4 Maintain a chip level and switch to low pressur

fresh steam for chip bin pre‐steaming prior to

beginning the shutdown sequence.Ensure the HVLC collection and treatmentsystem is in operation and all system valves are

in the appropriate position before initiating a

startup on the digester system(s).

Kraft Pulping: Digester LVHC INC1 116 2 Hot Startup:

3‐4 hrs

4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

Blow line flow and extraction

flow standard operating

Hot

Shutdown: 3‐

4 Maintain a chip level and switch to low pressur

fresh steam for chip bin pre‐steaming prior to

Cold Startup:

3‐4 hrs

in the appropriate position before initiating astartup on the digester system(s).

condition are met. 4 hrs

Cold

Shutdown: 3‐

4 hrs

beginning the shutdown sequence.

Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position until completingshutdown of the digester system(s).

Kraft Pulping: Digester LVHC INC1 116 2 Hot Startup:

3‐4 hrs

Cold Startup:

3‐4 hrs

4 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating a

startup on the digester system(s).

Blow line flow and extraction

flow standard operating

condition are met.

Hot

Shutdown: 3‐

4 hrs

Cold

Shutdown: 3‐

4 hrs

4 Maintain a chip level and switch to low pressur

fresh steam for chip bin pre‐steaming prior to

beginning the shutdown sequence.Ensure the LVHC collection and treatmentsystem is in operation and all system valves are

in the appropriate position until completingshutdown of the digester system(s).

Kraft Pulping: Digester LVHC INC1 116 1 Hot Startup:

3‐4 hrs

Cold Startup:

3‐4 hrs

4 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating a

startup on the digester system(s).

Blow line flow and extraction

flow standard operating

condition are met.

Hot

Shutdown: 3‐

4 hrs

Cold

Shutdown: 3‐

4 hrs

4 Maintain a chip level and switch to low pressur

fresh steam for chip bin pre‐steaming prior to

beginning the shutdown sequence.Ensure the LVHC collection and treatmentsystem is in operation and all system valves are

in the appropriate position before initiating a

startup on the digester system(s).

Kraft Pulping: Digester LVHC INC1 133 1 14 14 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

established flow of acceptable

pulp from the bottom of the

digester

5 5 continue routing emissions to LVHC collection

system until shutdown completed

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC1 135 1 17 17 Digester System: The LVHC and HVLC is

operating prior to startup of the digester system.

Digester System: Pulp is

blowing out of the digester at

the same rate chips are going

in. Level of chip bin is stable

and above lower pocket vent.

Black liquor is being extracted

to flash tanks and the reliefcondensors are operating atstable temp and flow. The

digester is drawing white liquorand steam in continuous/stablemanner.

5 5 Digester System: The LVHC and HVLC continues

to operate during shutdown.

Kraft Pulping: Digester LVHC INC1 139 1 1 1 LVHC in service. Digester relief valves open 2 2 LVHC in service. 

Kraft Pulping: Digester LVHC INC1 139 1 1 1 LVHC in service. Digester relief/blow valves

open

0.1 0.1 LVHC in service. 

Kraft Pulping: Digester LVHC INC1 139 1 2.5 2.5 LVHC in service. Digester relief valves open 0.75 0.75 LVHC in service. 

Kraft Pulping: Digester LVHC INC1 142 9 1 1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Digester systems are fully

operational, condensate and

vent gas systems are fully

operational, digester is filled

and capped, and cooking has

commenced.

1 1 Continue routing emissions to G0914 collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 142 8 3 3 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Digester systems are fully

operational, condensate and

vent gas systems are fully

operational, digester is filled

and capped, and cooking has

commenced.

3 3 Continue routing emissions to G0914 collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 150 1 2 2 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Startup complete after 4 blows

and knotter supply pulp is

running

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 150 3 2 2 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Startup complete after 4 blows

and knotter supply pump is

running

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 150 2 2.5 2.5 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Pressure Diffuser Operating,

Sustained flow on diffuser

0.75 0.75 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 156 1 2.5 2.5 follow SSM manual procedures When the blowing into the

blow tank starts

6 6 follow SSM manual procedures 

Kraft Pulping: Digester LVHC INC1 156 2 4 4 follow SSM manual procedures Flash Liquor pump is running 4 4 follow SSM manual procedures 

Kraft Pulping: Digester LVHC INC1 162 1 4‐26 26 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

conditions are met.

(1)Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC INC1 162 1 4‐26 26 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

conditions are met.

1‐3 3 (1)Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC INC1 163 1 12 12 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

condition are met

6 to 8 8 (1)Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC1 163 5 12 12 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester EquipmentSystem in such a way as to prevent over

pressurization of system upon startup such as:

(1) Do not blow a digester or cook a digester

until all pieces of the blow heat system arerunning and within acceptable control limits, and(2) Ensure critical pumps on the blow heatsystem are running prior to blowing a digester. Ifblow heat pressure is too high and the vent has

opened, do not attempt to blow anotherdigester until the problem can be found and

repaired.

Blow heat system standard

operating conditions are met

and digesters are routinely

blowing

6 to 8 8 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend thecooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Digester LVHC INC1 163 2 24 24 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the Digester

Equipment System in such a way as topressurization of system upon startup.

Blow line flow and extraction

flow standard operating

condition are met

6 to 8 8 (1)Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC INC1 163 1 24 24 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester EquipmentSystem in such a way as to prevent over prevent

over pressurization of system upon startup suchas: (1) Do not blow a digester or cook a digester

until all pieces of the blow heat system are

running and within acceptable control limits, and(2) Ensure critical pumps on the blow heatsystem are running prior to blowing a digester. Ifblow heat pressure is too high and the vent has

opened, do not attempt to blow anotherdigester until the problem can be found and

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

6 to 8 8 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend thecooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

repaired.

Kraft Pulping: Digester LVHC INC1 163 10 24 24 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester EquipmentSystem in such a way as to prevent over

pressurization of system upon startup such as:

(1) Do not blow a digester or cook a digester

until all pieces of the blow heat system arerunning and within acceptable control limits, and(2) Ensure critical pumps on the blow heatsystem are running prior to blowing a digester. Ifblow heat pressure is too high and the vent has

opened, do not attempt to blow anotherdigester until the problem can be found and

repaired.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

6 to 8 8 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend thecooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Digester LVHC INC1 165 3 Hot Startup:

3‐4 hours

Cold Startup:

3‐4 hours

4 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

Hot

Shutdown 3‐

4 hours

Cold

Shutdown: 3‐

4 hours

4 (1) Continuing routing emissions to the LVHC

Collection System and Control Device. (2)

Operate the Digester Equipment System in suc

a way as to prevent over pressurization of

system during shutdown

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC1 165 13 Hot Startup:

3‐4 hours

Cold Startup:

3‐4 hours

4 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

Hot

Shutdown 3‐

4 hours

Cold

Shutdown: 3‐

4 hours

4 (1) Continuing routing emissions to the LVHC

Collection System and Control Device. (2)

Operate the Digester Equipment System in suc

a way as to prevent over pressurization of

system during shutdown

Kraft Pulping: Digester LVHC INC1 165 4 Hot Startup:

3‐4 hours

Cold Startup:

3‐4 hours

4 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester System in such a

way as to prevent over pressurization of system

upon startup such as: (1) Do not blow a digester

or cook a digester until all pieces of the blow

heat system are running and within acceptablecontrol limits, and (2) Ensure critical pumps on

the blow heat system are running prior to

blowing a digester. If blow heat pressure is too

high and the vent has opened, do not attempt to

blow another digester until the problem can be

found and repaired.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

Hot

Shutdown 3‐

4 hours

Cold

Shutdown: 3‐

4 hours

4 (1) Continuing routing emissions to the LVHC

Collection System and Control Device. (2)

Operate the Digester Equipment System in suc

a way as to prevent over pressurization of

system during shutdown.(3) During emergency

shutdowns, all digesters should be put on hold

to suspend the cooking process and blowing

should be held until the Blow Heat System is

back under normal operating conditions.

Kraft Pulping: Digester LVHC INC1 166 1 Hot Startup:

2‐4 Hours

Cold Startup:

16‐24 Hours

24 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

conditions are met.

Hot

Shutdown: 1‐

2 Hours

Cold

Shutdown: 8‐

16 Hours

16 (1) Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC INC1 166 1 Hot Startup:

3‐4 Hours

Cold Startup:

3‐4 Hours

4 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester EquipmentSystem in such a way as to prevent over

pressurization of system upon startup such as:

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

Hot

Shutdown: 3‐

4 Hours

Cold

Shutdown: 3‐

4 Hours

4 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend thecooking process and blowing should be held un

(1) Do not blow a digester or cook a digester

until all pieces of the blow heat system arerunning and within acceptable control limits, and(2) Ensure critical pumps on the blow heat

system are running prior to blowing a digester. Ifblow heat pressure is too high and the vent has

opened, do not attempt to blow anotherdigester until the problem can be found and

repaired.

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Digester LVHC INC1 169 3 Hot ‐ 2‐4;

Cold 16‐24

24 BEFORE startup of the Digester Equipment

System (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the Digester

Equipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

condition are met.

Hot ‐ 1‐2;

Cold 8‐16

16 (1) Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC INC1 172 3 Hot Startup:

3‐4 hrs

Cold Startup:

3‐4 hrs

4 BEFORE startup of the Digester Equipment

System (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the Digester

Equipment System in such a way as to prevent

over pressurization of system upon startup.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

Hot

Shutdown: 3‐

4 hrs

Cold

Shutdown: 3‐

4 hrs

4 * Continuing routing emissions to the LVHC

Collection System and Control Device

* Operate the Digester Equipment System in

such a way as to prevent over pressurization of

system during shutdown.

Kraft Pulping: Digester LVHC INC1 176 1 3 3 Minimize number of blows necessary to remove

tramp air from BHR

When the accumulator reaches

operating temperature

Three hours

from the last

digester blow

3 Shut down the pulp mill before incineration po

shuts down

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC1 179 2 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

< 0.083 0.083 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 179 2 0.5‐1.5 1.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

0.5‐1 1 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 179 1 1.5‐3 3 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

2‐3 3 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 179 1 10‐12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

3‐5 5 continue routing emissions to LVHC/HVLC

collection system and primary or backup contro

system

Kraft Pulping: Digester LVHC INC1 179 1 1‐2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

1‐2 2 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 179 1 20‐24 24 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

9‐10 10 continue routing emissions to LVHC/HVLC

collection system and primary or backup contro

system

Kraft Pulping: Digester LVHC INC1 179 2 NA emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

NA continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 179 1 NA emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

NA continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 181 2 0.1 0.1 emissions collected and routed to a control

device during startup (except following cold

outage)

Blow tank pump starts 0.1 0.1 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: Digester LVHC INC1 181 1 0.1 0.1 emissions collected and routed to a control

device during startup (except following cold

outage)

Chip level 0.1 0.1 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: Digester LVHC INC1 181 1 0.1 0.1 emissions collected and routed to a control Reject pump starts 0.1 0.1 continue routing emissions to collection system 

device during startup (except following cold

outage)

and control device until unit down

Kraft Pulping: Digester LVHC INC1 181 1 0.2 0.2 emissions collected and routed to a control

device during startup (except following cold

outage)

Primary Screen Pump starts 0.2 0.2 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: Digester LVHC INC1 181 2 0.7 0.7 emissions collected and routed to a control

device during startup (except following cold

outage)

Blow tank flow established 0.3 0.3 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: Digester LVHC INC1 181 1 1.5 1.5 emissions collected and routed to a control

device during startup (except following cold

outage)

Blow tank flow established 0.5 0.5 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: Digester LVHC INC1 184 4 0.5 0.5 Continue routing emissions to LVHC collection

system.

When chip and liquor levels

stabilize.

0.5 0.5 Continue routing emissions to LVHC collection

system.

Kraft Pulping: Digester LVHC INC1 184 5 0.5 0.5 Continue routing emissions to LVHC collection

system.

When initial blow sequence is

begun.

0.5 0.5 Continue routing emissions to LVHC collection

system.

Kraft Pulping: Digester LVHC INC1 185 2 4.0 4 Unit is only started if the associated collection

system is operating.

Sawdust feed screws arerunning and sawdust is feeding

into the digester from the

hopper.

1.5 1.5 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

Kraft Pulping: Digester LVHC INC1 185 1 4.5 4.5 Unit is only started if the associated collection

system is operating.

Chip flow from the surge silo

into the digester feed end, blow

flow from the digester vesselinto #57 Tank, and good chip

column movement in the

digester vessel has been

established.

1.0 1 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC1 185 5 Integrated

with K5

Digester

Startup ‐ 4.5

hours

4.5 Unit is only started if the associated collection

system is operating.

Integrated with K5 Digester

Startup ‐ See Cell DS22

Integrated

with K5

Digester

Shutdown ‐ 

1.0 hour

1 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

Kraft Pulping: Digester LVHC INC1 185 2 Integrated

with Pandia

Digester

Startup ‐ 4.0

hours

4 Unit is only started if the associated collection

system is operating.

Integrated with Pandia Digester

Startup ‐ See Cells DS20 andDS21

Integrated

with Pandia

Digester

Shutdown ‐ 

1.5 hour

1.5 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

Kraft Pulping: Digester LVHC INC1 186 1 2 2 2 2Kraft Pulping: Digester LVHC INC1 189 2 0 0 NA NA NA NA 

Kraft Pulping: Digester LVHC INC1 189 2 1.5 1.5 Per the SSM Plan, Ensure LVHC/HVLC Systems

are operating. Started up the Digester System

following standard mill operating procedures andinitiated the digester blow sequence as required.

After starting up the Digester System, insured

that all NCG vent gases were being collected by

Comp I.

Per the SSM Plan, collection of

HVLC/LVHC System. Full Pulp

Flow rate is obtained.

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System. Verify that Com

I was collecting the LVHC vent gases until the

Digester System was shutdown.

Kraft Pulping: Digester LVHC INC1 190 1 1 1 Verify that all NCG gases are collected by the

appropriate collection system and sent to the

appropriate control device. Verify that thedigester system is operating in normal operating

temperatures, pressures, and flows.

After completing 4 digesterblows (blow 4 digesterssequentially)

0.5 0.5 Continue to operate the NCG collection system

Kraft Pulping: Digester LVHC INC1 190 2 1 1 Verify that all NCG gases are collected by the

appropriate collection system and sent to the

appropriate control device. Verify that the

digester system is operating in normal operating

temperatures, pressures, and flows.

After completing 4 digester

blows (blow 4 digesterssequentially)

1 1 Continue to operate the NCG collection system

Kraft Pulping: Digester LVHC INC1 190 1 2 2 Verify that all NCG gases are collected by the

appropriate collection system and sent to the

appropriate control device. Verify that thedigester system is operating in normal operating

temperatures, pressures, and flows.

Stock starts flowing to the NSSC

blow tank

1 1 Continue to operate the NCG collection system

Kraft Pulping: Digester LVHC INC1 240 1 14 14 (1) Insure that all water seal levels are indicated

on DCS. Verify that all seals are in place. (2)

Verify accumulator temp is within normaloperating ranges and that flows to/fromaccumulator are available.**Verify that alltemper are normal for turpent

Normal operation begins when

NCG vent to atmosphere is

closed and NCGs are divered to

the powerhouse and the firstdigester blows.

4 4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC INC1 240 1 18 18 (1) Insure that all water seal levels are indicated

on DCS. Verify that all seals are in place. (2)

Verify accumulator temp is within normal

operating ranges and that flows to/fromaccumulator are available .**Verify that alltemper are normal for turpen

Normal operation begins when

NCG vent to atmosphere is

closed and NCGs are divered to

the powerhouse and the firstdigester blows.

6 6 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC INC1 240 1 8 8 (1) Insure that all water seal levels are indicated

on DCS. Verify that all seals are in place. (2)

Verify accumulator temp is within normaloperating ranges and that flows to/fromaccumulator are available**Verify that alltemper are normal for turpenti

Normal operation begins when

NCG vent to atmosphere is

closed and NCGs are divered to

the powerhouse and the firstdigester blows.

4 4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC INC1 240 1 UK (1) Start blow heat recovery system per 22.02‐

BHR Start‐up; (2) Start blow heat evaporators per

22.01‐Blow Heat Evaporator Start‐up; (3) Close

manual valve to hogging jet and place car seal

back on valve.**Note that startup procedures for

the blow heat re

The blow heat evaporators and

the blow heat recovery systemsare on line.

UK Shutdown blow heat recovery system per 23.02

BHR system Shutdown. Applicable emission an

parameter limits not expected to be exceeded

during shutdown.

Kraft Pulping: Digester LVHC INC1 242 1 1.5 1.5 backup/alternate control When full pulp flow from the

digester is obtained

0.5 0.5 continue routing emissions to LVHC‐ AA‐026

collection system and primary or backup contro

system

Kraft Pulping: Digester LVHC INC1 340 2 8 8 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Accumulator Temp is 130+ for

8 hours

2 2 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Digester LVHC INC1 531 2 Hot Startup:

2‐4 hours

Cold Startup:

16‐24 hours

24 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow line flow and extraction

flow standard operating

condition are met.

Hot

Shutdown: 1‐

2 hours

Cold

Shutdown: 8‐

16 hours

16 (1)Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC INC1 531 1 Hot Startup: 24 BEFORE startup of the Digester Equipment Standard operating conditions Hot 16 (1)Continuing routing emissions to the LVHC 

2‐4 hours

Cold Startup:

16‐24 hours

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

are met Shutdown: 1‐

2 hours

Cold

Shutdown: 8‐

16 hours

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC INC1 613 2 NA NA 0 0 NA 

Kraft Pulping: Digester LVHC INC1 613 2 2 2 Per the SSM Plan, Monitor the pressure relief

valves and other points where possible excess

emissions could occure due to a malfunction.

Per the SSM Plan, Follow

procedures for Kiln/Oxidizer

System and NCG/SOG collection

system, found in the mill's SSMplan. Verify that the NCG/SOG

system is ready to accept vent

gases from the turpentine

system. Veryif y that the

turpentine recovery system is

ready to accept blow tank

gases.

2 2 Per the SSM Plan, By visual observation, the

operator should insure that vent gases are no

longer being generated before shutting downthe NCG/SOG gas collection system or diverting

blow tank vent gases to atmosphere.

Kraft Pulping: Digester LVHC INC1/SCBR 136 5 NA NA NA NA NA 

Kraft Pulping: Digester LVHC SCBR/INC_BOIL 131 2 10 10 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Any of the eight digesters is

steaming, cooking, holding,

ready, or blowing

10 10 continue routing emissions to LV01 collection

system and primary or backup control system

Kraft Pulping: Digester LVHC SCBR/INC_BOIL 131 1 10 10 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Chip meter clutch and blow

flow on

10 10 continue routing emissions to LV01 collection

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC SCBR/INC_BOIL 131 8 10 10 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chip meter clutch and blow

flow on

10 10 continue routing emissions to LV01 collection

system and primary or backup control system

Kraft Pulping: Digester LVHC SCBR/INC_BOIL 131 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Any of the eight digesters is

steaming, cooking, holding,

ready, or blowing

4 4 continue routing emissions to LV01 collection

system and primary or backup control system

Kraft Pulping: Digester LVHC SCBR/INC_BOIL 207 1 0.50 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

When digester is loaded and

steam is on

2.75 2.75 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC SCBR/INC_BOIL 207 1 2.00 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Blow heat recovery system is

online and >115 deg F

1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC SCBR/INC_BOIL 207 1 2.00 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Stock / black liquor in blow

tower and agitator running

5 5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC SCBR/INC_LK 226 4 0.75 0.75 ensure primary and backup control are available White liquor flow to digester

>100 gpm + steaming vessel

pressure >3 PSI + chip meter > 5

RPM

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Digester LVHC SCBR/INC_LK 226 3 1 1 ensure primary and backup control are available White liquor flow to digester

>100 gpm + steaming vessel

pressure >3 PSI + chip meter > 5

RPM

0.3 0.3 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Digester LVHC SCBR/INC_LK 610 1 1 1 emission unit and control device operates in

compliance with NESHAP parameter limits during

emission unit startup

digester extraction flow > 150gpm

1.25 1.25 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC SCBR/INC_LK 610 1 1 1 use fresh steam on the chip bin until it is full and

gases can be collected and controlled in LVHC‐2

digester extraction flow > 200gpm

1.5 1.5 switch to fresh steam during shutdown 

Kraft Pulping: Digester LVHC SCBR/INC_LK 610 1 1.5 1.5 emission unit and control device operates in

compliance with NESHAP parameter limits during

emission unit startup

digester extraction flow > 200gpm

1.5 1.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC SCBR/INC_LK/ESP 151 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

A blow or steamed out digesterhas been sent to C Blow Tank, if

continue routing emissions to LVHC‐1 collectiosystem and primary or backup control system

limits during emission unit startup in service, to purge air from the

system. (C Blow Tank is the

furthermost away from batchdigesters. If this tank is not in

service the next most distant

blow tank should be used.). At

least five digesters have been

blow. The Hot WaterAccumlator conductivity is

below 2000 micromhos. The

Hot Water Accumlatory

Pressure is within 30" of set

point.

Kraft Pulping: Digester LVHC SCBR/INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Contents of kamyr digesterhave turned over. Startup pul

has been blown from the

Kamyr. Blow Line Temperatureis under good control and

below 200F. Extraction flow isabove 300 gpm. The Hot WaterAccumulator conductivity is

below 2000 micromhos. All

pressure relief devices are not

venting (are collecting). The Hot

Water Accumulator Pressure is

within 30" of set point.

continue routing emissions to LVHC‐1 collectiosystem and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Digester LVHC SCBR/INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Determination of Startup 1.

**A digester blow or a steamed

out digester has been sent to C

Blow Tank, if in service, to

purge air from system (C Blow

Tank is the furthermost away

from If this tank is not in

service the next most distant

blow tank shoul

continue routing emissions to LVHC‐1 collectiosystem and primary or backup control system

Kraft Pulping: Digester LVHC SCBR/INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

same as above

Kraft Pulping: Digester LVHC SCBR/INC_LK/ESP 151 3 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

same as above continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Digester LVHC SCBR/INC_LK/SCBR 167 2 3 ‐ 16

Routine/Ann

ual

16 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Established blow flow, stock is

going across washers, pulp

going to high density storage.

2 ‐ 8

Routine/Ann

ual

8 (1) Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Digester LVHC SCBR/INC_LK/SCBR 167 3 3 ‐ 16

Routine/Ann

ual

16 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester Equipment

System in such a way as to prevent over

pressurization of system upon startup such as:

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

2 ‐ 8

Routine/Ann

ual

8 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend thecooking process and blowing should be held un

(1) Do not blow a digester or cook a digester

until all pieces of the blow heat system arerunning and within acceptable control limits, and(2) Ensure critical pumps on the blow heat

system are running prior to blowing a digester. Ifblow heat pressure is too high and the vent has

opened, do not attempt to blow anotherdigester until the problem can be found and

repaired.

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Digester LVHC SCBR/INC_TO/SCBR 130 16 3 ‐ 4 4 Emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup ‐ BEFOREstartup of the Digester Equipment System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment isproperly valved to the LVHC Collection System

Digester is blowing stock, stock

is flowing across brown stockwashers, washed pulp is flowing

to high density storage.

3‐4 4

1. Continuing routing emissions to the LVHCCollection System and Control Device

2. Operate the Digester Equipment System in

such a way as to prevent over pressurization of

system during shutdown.

Kraft Pulping: Digester LVHC SCBR/INC_TO/SCBR 525 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

the NCG Collection System is

ready to accept vent gases to

the Blow Heat Accumulator

System and IncinerationSystem..

2.5 2.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC SCBR/INC_TO/SCBR 525 1 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

NCG Collection System is readyto accept vent gases from the

Blow Heat Accumulator System.

NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Digester LVHC WW 133 1 14 14 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

established flow of acceptable

pulp from the bottom of the

digester

5 5 continue routing foul condensate to UNOX unit

shutdown completed

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC

Kraft Pulping: Evaporator LVHC COND/INC_BOIL 112 1 Collection and control systems operating before

start‐up

When condensate enters tank continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC COND/INC_BOIL 112 1 Collection and control systems operating before

start‐up

When condensate enters tank continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC COND/INC_BOIL 112 1 Collection and control systems operating before

start‐up

When liquor enters tank continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC 147 3 4 4 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends when liquor is

diverted to the heavy liquorside

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: Evaporator LVHC INC 148 2 5 5 emission unit and control device operates in

compliance parameter limits during emission

unit startup

When producing product solids 2 2 Incineration source is still online until source is

shutdown

Kraft Pulping: Evaporator LVHC INC 175 1 Hot Startup:

2‐4 Hours

Cold Startup:

6‐12 Hours

12 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

Operation has stabilized andevaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 Hour

Cold

Shutdown: 6‐

8 Hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC 196 2 1.5 1.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Product solids > 55% 0.25 0.25 

Kraft Pulping: Evaporator LVHC INC (see note) 182 6 5 5 Verify cooling water system is operational,

operate NCG and foul condensate systems

properly

When liquor at 48% is being

produced

2 2 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Evaporator LVHC INC_BOIL 127 1 0.75 0.75 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Blow tanks in normal operation 0.75 0.75 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Kraft Pulping: Evaporator LVHC INC_BOIL 127 1 3 3 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Establish desired black liquor

solids concentration fromEvaporator Set

1 1 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Kraft Pulping: Evaporator LVHC INC_BOIL 145 1 4 4 confirm that the condensate bypass valves are

closed

Vacumn reaches 20" Hg or

greater, steam valve open, seal

tank pressure controlled at setpoint, product solids are 48% or

greater

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_BOIL 152 3 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

steam and liquor flow in

automatic control

0.25 0.25 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_BOIL 154 1 10 10 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Discharge of black liquor withsolids greater than 44%

10 10 Continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_BOIL 154 2 8 8 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Discharge of black liquor with

solids greater than 44%

8 8 Continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_BOIL 173 1 3 ‐ 12 12 BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases and (2) Ensure equipment is properly

valved to the LVHC Collection System.

Dependant on equipment

systems feeding tank

4 ‐ 12 12 1. Continuing routing emissions to the

HVLC/LVHC Collection System and Control Devi

Kraft Pulping: Evaporator LVHC INC_BOIL 173 2 4 ‐ 8 8 BEFORE startup of the Evaporator System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment isproperly valved to the LVHC Collection System

Discontinue use of hogger before putting steam

on the evaporators.

Operation has stabilized andevaporator product (blackliquor solids) is at target

percent solids.Condensate streams are free of

any liquor contamination.

2 ‐ 12 12 Continuing routing emissions to the LVHC

Collection System and Control Device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC_BOIL 174 1 Hot Startup:

4 Hours

Cold Startup:

6 Hours

4 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System.**Cut out hogging jet before starting

regular feed of liquor.

Operation has stabilized and

evaporator product is at targetpercent solids

Hot

Shutdown:

0.5 Hours

Cold

Shutdown: 6

Hours

6 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_BOIL 182 3 5 5 Verify cooling water system is operational,

operate NCG and foul condensate systems

properly

When liquor at 48% is being

produced

2 2 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Evaporator LVHC INC_BOIL 201 1 3 3 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Product black liquor flow from

evaporator system to 50% blackliquor storage tank

0.5 0.5 continue routing emissions to LVHC collection

system to primary or backup control system

Kraft Pulping: Evaporator LVHC INC_BOIL 201 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Completion of 4 hours with

steam flow to digester system

greater than 75,000 lb/hr

1 1 continue routing emissions to LVHC collection

system to primary or backup control system

Kraft Pulping: Evaporator LVHC INC_BOIL1 148 1 NA NA NA NA 

Kraft Pulping: Evaporator LVHC INC_BOIL1 600 19 Hot Startup:

2‐4 hours;

Cold Startup:

6‐12 hours

12 BEFORE Start Up (1) Confirm the LVHC System

control device is ready to accept gases and (2)Ensure equip is properly valved to the LVHC

Collection System.**Cut out hogging jet before

starting regular feed of liquor.

Operation has stabilized and

evaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hours;

Cold

Shutdown: 6‐

8 hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_BOIL1 600 1 Hot Startup:

2‐4 hours;

Cold Startup:

6‐12 hours

12 BEFORE Start Up (1) Confirm the LVHC System

control device is ready to accept gases; and (2)

Ensure equip is properly valved to the LVHC

Collection System.**Cut out hogging jet beforestarting regular feed of liquor.

Operation has stabilized andevaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hours;

Cold

Shutdown: 6‐

8 hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_LK 115 2 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Feed flow > 1000 gpm 0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Evaporator LVHC INC_LK 117 1 6 6 Operate NCG Collection System as soon as

possible during Start‐UP

Product Liquor solids at target 8 8 Operate kiln ‐ P36 while generating NCGs 

Kraft Pulping: Evaporator LVHC INC_LK 117 1 8 8 Operate NCG Collection System during Start‐UP Full Foul Condenste Production

pumping rate is achieved

8 8 Operate WWTP (UNOX) ‐ F06 until shutdown 

Kraft Pulping: Evaporator LVHC INC_LK 132 3 1 hour 1 Emissions collected in a closed system Condensate flow > 30 gpm 1 hour 1 Emissions collected in a closed system 

Kraft Pulping: Evaporator LVHC INC_LK 132 6 1 hour 1 Emissions collected in a closed system Evaporator steam flow > 50,000

lb/hr for 15 minutes

<1 hour 1 Emissions collected in a closed system 

Kraft Pulping: Evaporator LVHC INC_LK 157 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

50% liquor solids being

produced

4 4 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK 186 1 2 2 When the vacuum in the

system reaches 22.5 inches of

mercury and when all

evaporator bodies and the

accumulator are filled and

returned to service.

2 2 

Kraft Pulping: Evaporator LVHC INC_LK 188 1 3 3 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Product Solids 48 ‐ 52 %

Weak Liquor Flow) 700 ‐ 2500gpmProduct Liquor Flow 150 ‐ 500gpmFourth Effect Vacuum 20‐28

inches Hg

4 4 LVHC gases continue to be collected and

incinerated unitl shutdown is complete.

Condensates continue to be collected until

shutdown is complete.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC_LK 188 2 NA ‐ 

Equipment

Startup and

Shutdown is

dependent

on upstream

and

downstream

operations

NA ‐ Equipment Startup and Shutdown is

dependent on upstream and downstreamoperations

NA ‐ Equipment Startup and

Shutdown is dependent on

upstream and downstreamoperations

NA ‐ 

Equipment

Startup and

Shutdown is

dependent

on upstream

and

downstream

operations

NA ‐ Equipment Startup and Shutdown is

dependent on upstream and downstream

operations

Kraft Pulping: Evaporator LVHC INC_LK 188 1 NA ‐ Tank

Startup and

Shutdown is

dependent

on upstream

and

downstream

operations

None Tank receives material NA ‐ Tank

Startup and

Shutdown is

dependent

on upstream

and

downstream

operations

None 

Kraft Pulping: Evaporator LVHC INC_LK 197 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Filtrate circulation begins/

switched on

0.1 0.1 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK 197 1 1.5 1.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Condensor is running whenever

pulp mill is running and water

valve is open

1.5 1.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK 197 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Solids content of liquor

produced reaches 46%

2 2 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK 197 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

When solids out of evaporators

reach 46%

2 2 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK 197 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When solids reach 46% 2 2 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK 199 1 0.3 0.3 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Product liquor flow to storage

tank from the evaporator

system

0.3 0.3 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Kraft Pulping: Evaporator LVHC INC_LK 202 5 See LVHC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup‐ 

with venting allowances for HVLC and LVHC

sources

See LVHC System ‐ not further

defined

See LVHC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

with venting allowances for HVLC and LVHCsources

Kraft Pulping: Evaporator LVHC INC_LK 203 2 0 0 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Evaporator LVHC INC_LK 203 1 0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Evaporator LVHC INC_LK 203 1 0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

All liquor pumps running, steam

flow > 20 kpph, 3rd effectcondensate conductivity less

than 1000 umhos

0.5 0.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK 203 3 0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

All liquor pumps running, steam

flow > 30 kpph, seal tank

condensate conductivity less

than 1000 umhos, 5th effect

condensate conductivity less

than 1000 umhos.

0.5 0.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC_LK 205 1 1.0 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Product black liquor transfer

from evaporator system to

storage commences

0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Evaporator LVHC INC_LK 206 1 8 8 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Outlet black liquor solids reach

at least 40% and conductivity

drops below 2000 microohms

for 30 minutes on the

condensate streams

8 8 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK 208228535 1 8 8 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Completion of 8 hours duringwhich weak black liquor is fed

to evaporator system and

system operates under propervacuum

0.1 0.1 continue routing emissions to LVHC‐7 collectio

system and primary control device

Kraft Pulping: Evaporator LVHC INC_LK 208228535 1 8 8 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Completion of 8 hours duringwhich weak black liquor is fed

to evaporator system and

system operates under proper

vacuum

0.1 0.1 continue routing emissions to LVHC‐8 collectio

system and primary control device

Kraft Pulping: Evaporator LVHC INC_LK 208228535 1 8 8 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Completion of 8 hours of chipfeed to digester system and

weak black liquor feed to pre‐

evaporator system and pre‐

evaporator system operatesunder proper vacuum

1 1 continue routing emissions to LVHC‐8 collectio

system and primary control device

Kraft Pulping: Evaporator LVHC INC_LK/ESP 105 1 Hot Startup:

0.5 to 1

hours; Cold

Startup: 4 to

6 hours

6 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection System.

Operation has stabilized and

evaporator product is at targetpercent solids

Hot

Shutdown:

0.5 to 2

hours; Cold

Shutdown: 4

to 8 hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_LK/ESP 105 1 Hot Startup:

2 to 4 hours;

Cold Startup:

6 to 12 hours

12 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection System.

Operation has stabilized and

evaporator product is at targetpercent solids

Hot

Shutdown:

0.5 to 2

hours; Cold

Shutdown: 6

to 8 hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_LK/ESP 105 1 Hot Startup:

2 to 4 hours;

Cold Startup:

6 to 12 hours

12 Close atmospheric vent as soon as practical after

air is purged from VCE. LVHC system must be on

line before you start pulling vacuum or steam is

used to begin startup on any evaporator.

Steady state operation with

vacuum and pressures in

normal range

Hot

Shutdown:

0.5 to 2

hours; Cold

Shutdown: 6

to 8 hours

8 LVHC system must continue on line until the

vacuum pumps and steam to the unit is shut

down.

Kraft Pulping: Evaporator LVHC INC_LK/MC/SCBR 120 2 <1 1 Kiln ready/Condensates to hard pipe 19% solids <1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Evaporator LVHC INC_LK/MC/SCBR 120 1 <1 1 Kiln ready/Condensates to hard pipe 45 %solids <1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Evaporator LVHC INC_LK/MC/SCBR 120 1 <1 1 Kiln ready/Condensates to hard pipe 45% solids <1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Evaporator LVHC INC_LK/MC/SCBR 120 2 <1 1 Kiln ready/Condensates to hard pipe 70% solids <1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Evaporator LVHC INC_LK/SCBR 121 2 6 6 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Operating parameters are in

line with the values shown in

the SSM plan

6 6 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC_LK/SCBR 121 2 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

NA NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK/SCBR 121 1 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Operating parameters are in

line with the values shown in

the SSM plan

NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK/SCBR 159 1 1.5 1.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

production begins based on

appropriate percent solids

0.75 0.75 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_LK/SCBR 177 2 6‐20 hours

(range which

includes

startup of

digester

system

equipment).

20 continue routing emissions to EU0905 or EU1151 When digester reaches target

production rates and normal

cooking cooking conditions are

established.

6‐20 hours

(range which

includes shut

down ofdigester

system

equipment).

20 continue routing emissions to EU0905 or EU115

Kraft Pulping: Evaporator LVHC INC_LK/SCBR 177 1 6‐8 hours

(range

includes

startup of

evaporator

process

equipment)

8 continue routing emissions to EU0905 or EU1151 When evaporators are at target

production rate and product

liquor is being pumped to theheavy liquor storage tank.

6‐8 hours

(range

includes

shutdown of

evaporator

process

equipment)

8 continue routing emissions to EU0905 or EU115

Kraft Pulping: Evaporator LVHC INC_LK1 600 14 Hot Startup:

2‐4 hours;

Cold Startup:

6‐12 hours

12 BEFORE Start Up (1) Confirm the LVHC System

control device is ready to accept gases and (2)Ensure equip is properly valved to the LVHC

Collection System.**Cut out hogging jet before

starting regular feed of liquor.

Operation has stabilized and

evaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hours;

Cold

Shutdown: 6‐

8 hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_RF 104 1 Startup Hot ‐ 

0, Startup

Cold ‐ 0.5

0.5 BEFORE startup of the Evaporator System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment isproperly valved to the LVHC Collection System.

Cut out hogging jet before starting regular feedof liquor.

Operation has stabilized andevaporator product is at targetpercent solids

Shutdown

Hot ‐ 0,

Shutdown

Cold ‐ 0

0 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_RF 108 4 Hot = 2‐4

Cold = 6‐12

12 BEFORE startup of the Evaporator System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment isproperly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

Operation has stabilized andevaporator product is at targetpercent solids

Hot = 0.5‐2

Cold = 6‐8

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_RF 119 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

When No.21 Rec. Blr. is firing

black liquor, is stable and safety

interlocks are satisfied.

4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shut down

Kraft Pulping: Evaporator LVHC INC_RF 119 3 6 6 backup/alternate control When No.21 Rec. Blr. Is firing

black liquor, is stable and safety

interlocks are satisfied. When

kiln front end temperature is1900‐2200 deg.F and kiln is

producing lime

4 4 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_RF 119 1 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When No.21 Rec. Blr. is firing

black liquor, is stable and safety

interlocks are satisfied.

4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shut down

Kraft Pulping: Evaporator LVHC INC_RF 140 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Black Liquor is at 150 F and the

flow to the evaporator is 400

gpm. Liquor is going to the

weak and strong black liquorstorage tanks.

continue routing emissions to LVHC collection

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC_RF 180 1 16 16 Minimize use of the hogging jet to start the

vacuum, ensure NCG system in service

Strong liquor flow of 1,850 gpm

at evaporator exit 73% solids,

conductivities in range.

2 2 Continue routing emission to NCG collection

system

Kraft Pulping: Evaporator LVHC INC_RF 615 3 4 4 emission unit and control device operates in

compliance NESHAP parameter limits during

emission unit startup

product flow 1 1 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_RF 615 3 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

product flow 1 1 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_TO 107 2 <1 hr 1 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Gases are collected and controldevice is operating withingrequired range.

<1 hr 1

Kraft Pulping: Evaporator LVHC INC_TO 109 2 Emission unit is not started up if APCD is not

operational

Kraft Pulping: Evaporator LVHC INC_TO 112 1 12 12 Collection and control systems operating before

start‐up

When gasses exit condensers 14.5 14.5 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_TO 112 1 13 13 Collection and control systems operating before

start‐up

When evaporator stabilizes 14.5 14.5 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_TO 138 1 2.5 2.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Target solids are obtained. 3 3 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_TO 146 1 0.3 0.3 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends when steam is

applied to the digester

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: Evaporator LVHC INC_TO 146 3 4 4 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends when liquor is

diverted to the heavy liquorside

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: Evaporator LVHC INC_TO 146 1 6 6 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends when liquor is

diverted to the heavy liquorside

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: Evaporator LVHC INC_TO 178 1 0 0 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment is

Operation has stabilized andevaporator product is at targetpercent solids

0 0 Continuing routing emissions to the LVHC

Collection System and Control Device

properly valved to the LVHC Collection System

.**Cut out hogging jet before starting regular

feed of liquor.

Kraft Pulping: Evaporator LVHC INC_TO 178 12 0 0 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System.**Cut out hogging jet before starting

regular feed of liquor.

Operation has stabilized andevaporator product is at target

percent solids

0 0 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_TO 178 2 3 3 BEFORE startup of the Digester System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment isproperly valved to the LVHC Collection

System.**Operate the Digester System in such a

way as to prevent over pressurizatio

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

3 3 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend thecooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Evaporator LVHC INC_TO 178 2 6 6 BEFORE startup of the Evaporator System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment is

properly valved to the LVHC Collection System.**

Cut out hogging jet before starting regular feedof liquor.

Operation has stabilized and

evaporator product is at target

percent solids

4 4 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC_TO 243 1 8 8 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Production of heavy liquor 0.25 0.25 continue routing emissions to NCG collection

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC_TO/SCBR 137 1 6 6 FOLLOW SSM PLAN Evaporator Steam Flow >

50,000 lb/hr for 15 minutes

12 12 FOLLOW SSM PLAN 

Kraft Pulping: Evaporator LVHC INC_TO/SCBR 138 1 0.2 0.2 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

A digester is blown. 1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_TO/SCBR 138 1 2.5 2.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Target solids are obtained. 3 3 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_TO/SCBR 138 2 2.5 2.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Target solids are obtained. 3 3 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_TO/SCBR 143 7 Hot: 3.0 ‐ 8.0

hours Cold:

8.0 ‐ 12.0

hours

12 (1) Confirm LVHC System and Treatment Units

are operating and route LVHC gases to LVHC

Treatment Unit; (2) Confirm Foul Condensate

Systems are operating and ready to accept foul

condensate; (3) Level out the System andstabilize the vacuum

Establish system consistency

with a stabilized vacuum, cleancondensates and target solids

level.

Hot and Cold:

0.5 ‐ 2.5

hours

2.5 Maintain LVHC and HVLC Collection and

Treatment Systems until after steam is taken o

the Evaporator Set

Kraft Pulping: Evaporator LVHC INC_TO/SCBR 143 9 Hot: 3.0 ‐ 8.0

hours Cold:

8.0 ‐ 12.0

hours

12 (1) Confirm LVHC System and Treatment Units

are operating and route LVHC gases to LVHC

Treatment Unit; (2) Confirm Foul Condensate

Systems are operating and ready to accept foul

condensate; (3) Level out the System andstabilize the vacuum.

Establish system consistency

with a stabilized vacuum, cleancondensates and target solids

level.

Hot and Cold:

0.5 ‐ 2.5

hours

2.5 Maintain LVHC and HVLC Collection and

Treatment Systems until after steam is taken o

the Evaporator Set

Kraft Pulping: Evaporator LVHC INC_TO/SCBR 143 1 Hot: 3.0 ‐ 8.0

hours Cold:

8.0 ‐ 12.0

hours

12 (1) Confirm LVHC System and Treatment Units

are operating and route LVHC gases to LVHC

Treatment Unit; (2) Confirm Foul Condensate

Systems are operating and ready to accept foul

condensate; (3) Level out the System andstabilize the vacuum.

Establish system consistency

with a stabilized vacuum, cleancondensates and target solids

level.

Hot and Cold:

0.5 ‐ 2.5

hours

2.5 Maintain LVHC and HVLC Collection and

Treatment Systems until after steam is taken o

the Evaporator Set.

Kraft Pulping: Evaporator LVHC INC_TO/SCBR 149 1 12 12 route emissions to LVHC collection system and

primary or backup control system

Liquour flow to heavy liquor

tank

0 0 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC_TO/SCBR 155 3 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

when weak black liquor feed

temp > 150 F for 4 hrs

0.1 0.1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 100 2 ~8 hrs 8 Stop liquor flow and steam flow to the

evaporators prior to initiating shutdown of the

HVLC collection system.

Operation has stabilized andevaporator product is at targetpercent solids.

~6 hrs 6 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position until completing

shutdown of the Evaporator System(s).

Kraft Pulping: Evaporator LVHC INC1 100 10 ~8 hrs 8 Stop liquor flow and steam flow to the

evaporators prior to initiating shutdown of theLVHC collection system.

Operation has stabilized andevaporator product is at targetpercent solids.

~6 hrs 6 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position until completingshutdown of the Evaporator System(s).

Kraft Pulping: Evaporator LVHC INC1 102 1 24 24 The sequence for evaporator system startup to

minimize emissions is 1) LVHC NCG is collecting

and being incinerated 2) establish vacuum and 3)

startup feed to evaporators.

Making Solids Mode: ProductSolids at 48‐55%, CleanCondensate Conductivity <1500 μmhos Feed & Product

Flows Stable, steam flow over45 kpph. Standyby Mode:

Product Solids less than 35%,

Clean Condensate Conductivity< 1500 μmhos Feed & Product

Flows Stable, steam flow below

35 kpph.

4 4 Maintain collection of the LVHC NCG sources as

long as the LVHC system is online unless safety maintenance SRMs require otherwise.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC1 102 1 24 24 The sequence for evaporator system startup to

minimize emissions is 1) LVHC NCG is collecting

and being incinerated 2) establish vacuum and 3)

startup feed to evaporators.

Pre‐Evaporators: Product Solids20‐30% BPR, Condensate

Conductivity <1500 μmhos,

Feed & Product Flows Stable.

Crystallizer: Product Solids 70‐

75%, Feed & Product Flows

Stable.

4 4 Maintain collection of the LVHC NCG sources as

long as the LVHC system is online unless safety maintenance SRMs require otherwise.

Kraft Pulping: Evaporator LVHC INC1 102 1 24 24 The sequence for evaporator system startup to

minimize emissions is 1) LVHC NCG is collecting

and being incinerated 2) establish vacuum and 3)

startup feed to evaporators.

Product Solids at 48‐55%, Clean

Condensate Conductivity <

1500 μmhos Feed & Product

Flows Stable

4 4 Maintain collection of the LVHC NCG sources as

long as the LVHC system is online unless safety 

maintenance SRMs require otherwise.

Kraft Pulping: Evaporator LVHC INC1 103 1 8 8 Use the proper sequence for evaporator and

concentrator system startup to minimize

emissions. This sequence includes venting the

hotwells for up to 2 hours to prevent an

explosion (safety precaution). Verify that theevaporator system is operating within normal

ranges for process temperatures, pressures,

flows, and conductivity. The conductivity

diversion system will automatically send foul

condensates with a high conductivity to eitherthe boil out or save all tanks. Due to NC Air

Toxics limits, no foul condensates are sewered.

The transition from startup to

normal operations will be

considered complete when the

listed conditions have been

achieved.

3 3 Follow the standard operating procedures for

shutdown of the evaporator and concentrator

systems. Maintain collection of the LVHC NCG

sources as long as the LVHC system is online

unless safety or maintenance SOP requires

otherwise.

Kraft Pulping: Evaporator LVHC INC1 111 1 1.185564663 1.185564663 HVLC NCG system is collecting gases prior to

startup of sources. Source vent and/or collection

valves positions are verified during lock‐out/tag‐

out process.

The Oxygen Delignificationsystem is considered started up

when target flow rate achieved.

0.839480874

32

0.839480874 HVLC NCG system is collecting gases during

shutdown of sources.

Kraft Pulping: Evaporator LVHC INC1 111 1 1.5 1.5 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless the

The Continuous Digester

system startup is consideredcomplete when target flow rate

achieved.

3.5 3.5 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

system is down or locked and tagged out. LVHC

NCG process source or collection system may bevented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSM

plan for collection systems and control devices.

and pulping condenstates. 

Kraft Pulping: Evaporator LVHC INC1 116 11 Hot Startup:

6‐12 hrs

Cold Startup:

4‐6 hrs

6 Stop liquor flow and steam flow to the

evaporators prior to intiating shutdown of the

LVHC collection system.

Operation has stabilized andevaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hrs

Cold

Shutdown: 6‐

8 hrs

8 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position until completingshutdown of the Evaporator System(s).

Kraft Pulping: Evaporator LVHC INC1 133 3 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

the evaporator product is

switched to the product storagetank

5 5 continue routing emissions to LVHC collection

system until shutdown completed

Kraft Pulping: Evaporator LVHC INC1 135 1 10 10 Multiple Effect Evaporator System: The LVHC is

operating prior to startup of the multiple effect

evaporator system.

Multiple Effect EvaporatorSystem: When the heavy black

liquor density is up to targetpercent solids and product

liquor is going to the

appropriate storage tank.

16 16 Multiple Effect Evaporator System: The LVHC

continues to operate during shutdown.

Kraft Pulping: Evaporator LVHC INC1 139 1 0.1 0.1 LVHC in service. Flow out of tank with level in

control.

0.1 0.1 LVHC in service. 

Kraft Pulping: Evaporator LVHC INC1 139 1 0.1 0.1 LVHC in service. Target vacuum is achieved 0.1 0.1 LVHC in service. 

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC1 139 2 4 4 LVHC in service. exit liquor solids at target (>50

or 70%)

8 8 LVHC in service. 

Kraft Pulping: Evaporator LVHC INC1 142 2 1 1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Liquor flow is within normal

range, vacuum flow is stable,

condensate conductivity is

within acceptable range, and

liquor solids is within

acceptable range, and foul

condensates is being sent tothe foul condensate system.

8 8 Continue routing emissions to G0914 collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 142 2 1 1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Stop feeding condensates to

the tank

1 1 Continue routing emissions to G0914 collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 142 1 1 1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stop feeding condensates to

the tank

4 4 Continue routing emissions to G0914 collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 142 3 1 1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Stop feeding condensates to

the tank

8 8 Continue routing emissions to G0914 collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 142 3 20 20 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Liquor flow is within normal

range, vacuum flow is stable,

condensate conductivity is

within acceptable range, and

liquor solids is within

acceptable range, and foul

condensates is being sent to

the foul condensate system.

8 8 Continue routing emissions to G0914 collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 142 4 6 6 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Liquor flow is within normal

range, vacuum flow is stable,

condensate conductivity is

within acceptable range, and

8 8 Continue routing emissions to G0914 collection

system and primary or backup control system

liquor solids is within

acceptable range, and foul

condensates is being sent tothe foul condensate system.

Kraft Pulping: Evaporator LVHC INC1 150 1 168 168 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Making black liquor product >45% and producting acceptable

condensate cleanliness for >

than 4 hours.

168 168 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 150 1 24 24 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Making > 25% BLS product

liquor

24 24 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 150 1 6 6 continue routing emissions to HVLC‐1 collection

system and primary or backup control system

Determined by HVLC system 6 6 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 156 3 4 4 follow SSM manual procedures Adequate sample flow to

Conductivity Pot

4 4 follow SSM manual procedures 

Kraft Pulping: Evaporator LVHC INC1 156 1 8 8 follow SSM manual procedures Spill Tank pressure control is in

operation and set at setpoint

8 8 follow SSM manual procedures 

Kraft Pulping: Evaporator LVHC INC1 162 1 1 1 1 1

Kraft Pulping: Evaporator LVHC INC1 162 1 1 1 BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases and (2) Ensure equipment is properly

valved to the LVHC Collection System.

Dependant on equipment

systems feeding tank

1 1 Continuing routing emissions to the LVHC

Collection System and Control Device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC1 162 1 6 6 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System.**Cut out hogging jet before starting

regular feed of liquor.

Operation has stabilized andevaporator product is at target

percent solids

4 4 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 162 1 8 8 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System.**Cut out hogging jet before starting

regular feed of liquor.

Operation has stabilized andevaporator product is at target

percent solids

0.25 0.25 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 163 1 3 to 4 4 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection System.**

Cut out hogging jet before starting regular feedof liquor.

Operation has stabilized andevaporator product is at targetpercent solids

4 to 5 5 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 163 3 3 to 4 4 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

Operation has stabilized andevaporator product is at targetpercent solids

3 to 4 4 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 163 1 3 to 4 4 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

Operation has stabilized andevaporator product is at targetpercent solids

4 to 5 5 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 165 2 0 0 BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases; and (2) Ensure equipment is properly

valved to the LVHC Collection System.

Dependant on equipment

systems feeding tank

0 0 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 165 2 Hot Startup:

1.5‐3 hours

Cold Startup:

4 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment is

Operation has stabilized andevaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hours

6 Continuing routing emissions to the LVHC

Collection System and Control Device

2‐4 hours properly valved to the LVHC Collection

System.**Cut out hogging jet before starting

regular feed of liquor.

Cold

Shutdown: 2‐

6 hours

Kraft Pulping: Evaporator LVHC INC1 165 2 Hot Startup:

1.5‐3 hours

Cold Startup:

2‐4 hours

4 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

Operation has stabilized andevaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hours

Cold

Shutdown: 2‐

6 hours

6 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 166 1 Hot Startup:

2‐4 Hours

Cold Startup:

6‐12 Hours

12 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor (cold star

Operation has stabilized andevaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 Hours

Cold

Shutdown: 6‐

8 Hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 169 1 BEFORE startup of any of the equipment systems

feeding condensate to the tank (1) Confirm the

HVLC System control device is ready to accept

gases; and (2) Ensure equipment is properly

valved to the HVLC Collection System.

Dependant on equipment

systems feeding tank

Continuing routing emissions to the HVLC Systeand Control Device

Kraft Pulping: Evaporator LVHC INC1 169 1 BEFORE startup of the Evaporator System (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

When the product valves are

switched to the intermediatetanks.

Continuing routing emissions to the LVHC

Collection System and Control Device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC1 169 1 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System.**Cut out hogging jet before starting

regular feed of liquor.

When the product valves are

switched to the intermediate

tanks.

Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 169 4 Hot ‐ 2‐4;

Cold 6‐12

12 BEFORE startup of the Evaporator System (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

When the product valves are

switched to the intermediatetanks.

Hot ‐ 0.5‐2;

Cold 6‐8

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 172 11 Hot Startup:

2‐4 hrs

Cold Startup:

6‐12 hrs

12 BEFORE startup of the Evaporator System (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

Operation has stabilized andevaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hrs

Cold

Shutdown: 6‐

8 hrs

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 172 1 Startup

duration will

depend on

the time it

takes to

startup the

equipment

feeding the

tank: 1 to 8

hrs

8 BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases; and (2) Ensure equipment is properly

valved to the LVHC Collection System.

Dependant on equipment

systems feeding tank

Shutdown

duration will

depend on

the time it

takes to shut

down the

equipment

feeding the

tank:

approximatel

y 3 hrs

3 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 176 2 5 5 Close hog ejector as soon as vacuum established. Either evaporator density above

50% or concentrator density

above 65%

2 2 na 

Kraft Pulping: Evaporator LVHC INC1 179 1 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

< 0.083 0.083 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 179 1 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

Washed stock off of final stage

washer.

< 0.083 0.083 continue routing emissions to HVLC collection

system and primary or backup control system

limits during emission unit startup

Kraft Pulping: Evaporator LVHC INC1 179 1 10‐12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Introduction of black liquor into

the strong black liquor tank.

2‐5 5 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 181 1 1 1 emissions collected and routed to a control

device during startup (except following cold

outage)

tank full and valved in to ASB 3 3 continue routing emissions to collection system

and control device until start of Hotwell drain

(unit only shutdown during cold outage)

Kraft Pulping: Evaporator LVHC INC1 181 1 6 6 emissions collected and routed to a control

device during startup (except following cold

outage)

unit making product liquor at

density target

5 5 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: Evaporator LVHC INC1 184 1 1 1 Continue routing emissions to LVHC collection

system.

When flows and pressures

stabilize.

1 1 Continue routing emissions to LVHC collection

system.

Kraft Pulping: Evaporator LVHC INC1 184 1 3 3 Continue routing emissions to LVHC collection

system.

When product solids, steampressure, liquor flow and

condensate conductivity all

stabilize within established

operating ranges.

1 1 Continue routing emissions to LVHC collection

system.

Kraft Pulping: Evaporator LVHC INC1 185 1 4.0 4 NCG system is operating before steam

application

Product liquor to 50% storage,condensates clean fordesignated use, stable (liquor

flow, steam flow, 1st effect

pressure & surface condensorvacuum)

6.0 6 NCG system in service while feeding liquor and

steam ‐ typically in service during shutdown

activities

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC1 185 1 8.0 8 NCG system is operating before steam

application

Product liquor to 50% storage,

condensates clean for

designated use, stable (liquor

flow, steam flow, 1st effect

pressure & surface condensorvacuum)

10.0 10 NCG system in service while feeding liquor and

steam ‐ typically in service during shutdown

activities

Kraft Pulping: Evaporator LVHC INC1 185 1 8.0 8 NCG system is operating before steam

application

Product liquor to 70% storage,

condensates clean for

designated use, stable (liquor

flow, steam flow, 1st effect

pressure & surface condensorvacuum)

8.0 8 NCG system in service while feeding liquor and

steam ‐ typically in service during shutdown

activities

Kraft Pulping: Evaporator LVHC INC1 185 1 Integrated

with No. 2

Evaporator

Startup ‐ 4.0

hours

4 Integrated with No. 2 Evaporator ‐ NCG system is

operating before steam application

Integrated with No. 2

Evaporator

Integrated

with No. 2

Evaporator

Shutdown ‐ 

6.0 hours

6 Integrated with No. 2 Evaporator 

Kraft Pulping: Evaporator LVHC INC1 185 1 Integrated

with No. 4

Evaporator

Startup ‐ 8.0

hours

8 Integrated with No. 4 Evaporator ‐ NCG system is

operating before steam application

Integrated with No. 4

Evaporator

Integrated

with No. 4

Evaporator

Shutdown ‐ 

10.0 hours

10 Integrated with No. 4 Evaporator 

Kraft Pulping: Evaporator LVHC INC1 189 1 0.5 0.5 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. Begin to bring water into Effects per

mill standard operation procedures. Introducesteam, per mill standard operating procedures,

to bring the Evaporator Set up to temperature.

Using the hogging ejector, bring vacuum up to

required level for vacuum pumps to start per mill

standard operating procedures. Follow mill

standard operating procedures to introduceliquor flow to the Evaporator System once

required temperature has been reached. Insure

that the Evaporator System is operating within

normal ranges for process temperatures,

pressures, flows, and conductivity. Start up

Concentrators per mill standard operating

procedures. **Startup Note: Typically theHogging ejector will not be run after liquor has

Per the SSM Plan, collection of

HVLC/LVHC System. Follow the

proper startup procedures and

operating procedures outlinedin the Incinerator System, Lime

Kiln, or 9A Power Boiler, as

defined in mills standard

operating procedures. Followthe proper startup procedures

and operating procedures as

outlined in the LVHC Collection

System, as defined in mills

standard operating procedures.

Follow the Pre‐Startup Checklist

for the Evaporator System as

defined in the mills standard

operating procedures.

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System. Shutdown the

Evaporator System and all associated equipme

following standard operating procedures. Theoperator will insure that all vent gases and

pulping condensates are no longer being

generated by the Evaporator System by verifyin

that feed liquor and steam is no longer beingintroduced into the system.

been introduced, however the Crossett mill mayuse the hogging ejector during startup but willrevert back to the vacuum pumps as the vacuumis obtained.

Kraft Pulping: Evaporator LVHC INC1 190 2 3.75 3.75 Verify NCG system is operational. Verify the

hogging ejector is valved off before liquor is put

into the evaporators. Verify evaporator system

is operating within normal operating ranges for

temperatures, pressures, and flows.

Introduction of black liquor into

the 50% black liquor tank.

6 6 continue routing emissions to NCG collection

system until shutdown complete

Kraft Pulping: Evaporator LVHC INC1 190 1 8 8 Verify NCG system is operational. Verify the

hogging ejector is valved off before liquor is put

into the evaporators. Verify pre‐evaporator andevaporator system is operating within normal

operating ranges for temperatures, pressures,

and flows.

Firing black liquor in Recovery

Boiler and acceptable product

liquor quality.

12 12 continue routing emissions to NCG collection

system until shutdown complete

Kraft Pulping: Evaporator LVHC INC1 240 1 UK Verify incinerator or kiln is ready to accept gases

from evaps per shift supervisors.**Verify that

condensate conductivity systems are operating

normally, and have the operator #2 check in the

field.**Verify the level in the cooling tower and

make sure we

Startup ends and normal

opeation begins when all of the

startup emission minimizationchecklist items have been

verified.

UK (1)Maintain collection of NCG gases while the

evaporators are on line. (2)Check level of proce

condensate storage tank add raw water if

needed to maintain level. Applicable emissionand parameter limits not expected to be

exceeded during shutdownd raw water if need

to maintain level. Applicable emission andparameter limits not expected to be exceeded

during shutdown

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC1 242 1 0.5 0.5 continue routing emissions to LVHC‐ AA‐026

collection system and primary or backup control

system

Strong liquor flow to heavy

liquor tank

0.25 0.25 continue routing emissions to LVHC‐ AA‐026

collection system and primary or backup contro

system

Kraft Pulping: Evaporator LVHC INC1 340 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Conductivity of condensate isless than 2000 umhos for 8

hours

4 4 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC INC1 531 2 Hot Startup:

2‐4 hours

Cold Startup:

6‐12 hours

12 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

Operation has stabilized andevaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hours

Cold

Shutdown: 6‐

8 hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 531 1 NA BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases and (2) Ensure equipment is properly

valved to the LVHC Collection System.

Dependant on equipment

systems feeding tank

NA Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC INC1 613 1 2 2 Per the SSM Plan, Begin to recirculate water

through the evaporator set per mill standard

operating procedures. Begin pulling vacuum on

MEEs with hogging ejectors after water is

introduced. Introduce the steam, per millstandard operating procedures to bring the

evaporator set up to temperature. Introduceblack liquor and immediately insure the MEE

NCG gases are being sent to the appropriate

collection systems. Establish a minimum flow of

liquor until the solids content of the black liquor

from the first effect increases up to the set point.

Follow procedures to adjust liquor flow and

steam to balance the evaporator in support of

mill operations. Insure that the evaporator

system is operating within normal ranges forprocess pressures, flows, and conductivity.

Per the SSM Plan:

46‐53% Product solids. <80 psig1st effect steam pressure. <15

umhos clean condensate.

<2000 umhos foul condensates.1000‐2000 weak liquor flow,

gpm. 350‐1100 product liquorflow, gpm. >23 inHg vacuum.

2 2 Per the SSM Plan:

Shutdown following standard operating

procedures. The operator will insure that all

vent gases are no longer being generated by th

Evaporator System by verifying that feed liquor 

no longer being introduced into the system.

Kraft Pulping: Evaporator LVHC INC1 613 1 2 2 Per the SSM Plan, Verify that the NCG vent valve

will route vent gases the the NCG collection

system and NOT to the atmosphere. Startup

following mill prcedures. Insure that the flas

evaps is opertating within normal ranges for

process temps, pressures, flows, andconductivity. Insure the NCG gases and pulping

condensates are being sent tot he approprate

collection systems after the flas evaps has

reached normal operations.

Per the SSM Plan:**Product

Solids: 20‐25% Feed liquor

solids: 17‐24% Foul condensate

conductivity: <1000 umhos.

1000‐2400 gpm weak liquor

flow. 800‐1700 gpm product

liquor flow. 200‐215 F weak

liquor temperature. 120‐140 F

product liquor temperature

2 2 Per the SSM Plan:

The operator will insure that all vent gases and

pulping condensates are no longer being

generated by the flas evap system before

allowing system to vent to atmosphere.

Kraft Pulping: Evaporator LVHC INC1 617 2 4 hours 4 start up LVHC‐1 collection system prior to

emission unit start‐up

steam flow @ 20 kpph, solids @

27 baume, liquor flow @ 300

gpm, vacuum >23 in. Hg,

condensates collected

2 hours 2 continue routing emissions to LVHC‐1 collectio

system

Kraft Pulping: Evaporator LVHC INC1 617 1 6 hours 6 start up LVHC‐1 collection system prior to

emission unit start‐up

steam flow @ 20 kpph, solids

65%, liquor flow @ 150 gpm,

vacuum >1.5 in. Hg

3 hours 3 continue routing emissions to LVHC‐1 collectio

system

Kraft Pulping: Evaporator LVHC INC1/SCBR 136 6 NA NA NA NA NA 

Kraft Pulping: Evaporator LVHC SCBR 184 3 3 3 Continue routing emissions to LVHC collection

system.

When product solids, 1st effect

steam pressure, weak liquor

flow and vacuum all stabilize

within established operating

ranges.

1 1 Continue routing emissions to LVHC collection

system.

Kraft Pulping: Evaporator LVHC SCBR/INC_BOIL 131 12 15 15 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Steam pressure and liquor flow 15 15 continue routing emissions to LV01 collection

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC SCBR/INC_BOIL 207 1 5.00 5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Producing >63% solids 3 3 continue routing emissions to 127 LVHC

collection system and primary or backup contro

syste

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 226 1 1 1 ensure primary and backup control are available #1 or #2 Kraft digesters are in

operation and receiving flow

from K1 or K2

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 226 1 1 1 ensure primary and backup control are available #1 or #2 Kraft digesters are in

operation and flow from 2nd

stage flash tank > 500 GPM and

flash evaporator surface

condenser > 15' Hg vacuum

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 226 2 1 1 ensure primary and backup control are available Flash evaporators are in

operation

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 226 3 1 1 ensure primary and backup control are available Liquor flow to evaporator is

>200 gpm and surfacecondenser > 15" Hg vacuum

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 226 2 12 12 ensure primary and backup control are available Liquor flow to evaporator is

>200 gpm and surfacecondenser > 15" Hg vacuum

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 226 1 4 4 ensure primary and backup control are available Liquor flow to evaporator is

>200 gpm and surfacecondenser > 15" Hg vacuum

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 226 2 6 6 ensure primary and backup control are available Liquor flow to evaporator is

>200 gpm and surfacecondenser > 15" Hg vacuum

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 226 3 8 8 ensure primary and backup control are available Liquor flow to evaporator is

>200 gpm and surface

condenser > 15" Hg vacuum

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 610 1 1 1 emission unit and control device operates in

compliance with NESHAP parameter limits during

emission unit startup

lime kiln > 1600 F and gas

collection steam ejectoroperating

2 2 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 610 1 5 5 emission unit and control device operates in

compliance with NESHAP parameter limits during

emission unit startup

Steam > 11 MPPH and greater

than 50% liquor flow and

condensates are clear

1 1 emission unit and control device operates in

compliance with NESHAP parameter limits duri

emission unit shutdown

Kraft Pulping: Evaporator LVHC SCBR/INC_LK 610 1 6 6 emission unit and control device operates in

compliance with NESHAP parameter limits during

emission unit startup

Steam > 10 MPPH and greater

than 50% liquor flow and

condensates are clear

1 1 emission unit and control device operates in

compliance with NESHAP parameter limits duri

emission unit shutdown

Kraft Pulping: Evaporator LVHC SCBR/INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Condensates designated for

collection in the Evaporator

Foul Condesnsate tank arebelow 800 micromhos..Evaporator steam and liquor

flows are stable. Foulcondensate flow sent to

Condensate Stripper Feed Tank.

All pressure relief devides are

not venting.

continue routing emissions to LVHC‐1 collectiosystem and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK/ESP 151 1 4‐8 8 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

When NCG collection begins =>

when the steam ejectors are

placed in service (MEE 1&2) or

the vacuum pump is started(MEE 3 &4)

1.5 1.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC SCBR/INC_LK/ESP 151 1 6‐8 8 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Hogging jet gas and steam

valves are closed. The Hotwell

pump is running and the tank is

not overflowing. Hot well

condensate conductivity is

below 1400 micromhos and is

diverted to Fiber Filter or Foul

Condensate Tank. WHE second

effect vacuum is stable and

above 20" Hg. Weak Liquor

Flows are stable and above 400

gpm per effect. Hot Water

Accumulator Water Tem to First

Effect above 190F. Combinedcondensate conductivity below

1000 micromhos andcondensate diverted to HotWater Tank.

6‐10 10 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Evaporator LVHC SCBR/INC_LK/SCBR 167 1 3 ‐ 16

Routine/Ann

ual

16 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Established blow flow, stock is

going across washers, pulp

going to high density storage.

2 ‐ 8

Routine/Ann

ual

8 (1) Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Evaporator LVHC SCBR/INC_LK/SCBR 167 6 4 ‐ 12

Routine/Ann

ual

12 BEFORE startup of the Evaporator System: (1)

Confirm the LVHC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Cut out hogging jet before startingregular feed of liquor.

Black liquor solids target is metand condensate streams are

free of any liquorcontamination.

2 ‐ 8

Routine/Ann

ual

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC SCBR/INC_TO 198 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Product solids, steam pressure,vacuum system, liquor and

condensate flows within normaloperating ranges, no alarms, no

rupture disk failures

8 8 continue routing emissions to LVHC‐1 and HVLC

1 collection system and primary or backup

control system

Kraft Pulping: Evaporator LVHC SCBR/INC_TO/SCBR 130 6 2 ‐ 6 6 BEFORE startup of the Evaporator System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment isproperly valved to the LVHC Collection System

Cut out hogging jet before starting regular feedof liquor.

Operation has stabilized andevaporator product (blackliquor solids) is at target

percent solids.Condensate streams are free of

any liquor contamination.

0.5 ‐ 8 8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Evaporator LVHC SCBR/INC_TO/SCBR 198 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Product solids, steam pressure,vacuum system, liquor andcondensate flows within normaloperating ranges, no alarms, no

rupture disk failures

8 8 continue routing emissions to LVHC‐1 and HVLC

1 collection system and primary or backup

control system

Kraft Pulping: Evaporator LVHC SCBR/INC_TO/SCBR 525 9 6 6 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

System is operating within

normal ranges for process

temperatures, pressures, flows,

and conductivity

0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Evaporator LVHC SCRB/INC_BOIL/CYC/ 200 1 6 6 At least one combination boiler should be fully

operational before the generation of theregulated pollutants is initiated

product solids (%) at targetlevels and no alarms

6 6 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC STRIP/INC_TO/SCBR 243 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Production of intermediateliquor

0.25 0.25 continue routing emissions to NCG collection

system and primary or backup control system

Kraft Pulping: Evaporator LVHC WW 133 3 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

the evaporator product is

switched to the product storagetank

5 5 continue routing foul condensate to UNOX unit

shutdown completed

Kraft Pulping: Evaporator LVHC WW 610 1 NA NA

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: HVLC

Kraft Pulping: HVLC COND/TO/SCBR 206 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When all three blowers are in

operation and the RTO

temperature have stabilizedabove the minimum required

operating temperature.

0.1 0.1 emission unit and control device operates durin

emission unit shutdown (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Kraft Pulping: HVLC INC/SCBR 136 1 0 0 Do not start process until collection system

operational

Vent valves closed and

emissions routed to IQS/PowerBoilers

0 0 Shut down process before collection system

shutdown

Kraft Pulping: HVLC INC_BOIL 103 1 0.1 0.1 Source vent and/or collection valves positions

are verified using preliminary checklist. Basic

Care and Condition Monitoring Routes provide

routine visual checks of the collection system.

DCS hand switches vent/auto at each of theHVLC sources must be in AUTO position, andindividual hand switches on Hog Fuel Boiler DCS

vent/collect must be in COLLECT. LVHC and

HVLC NCG Continuous Operation – SOP No.

COOP.5.44

Startup has been achievedwhen all the safety and

permissive interlocks have been

met. DCS data and the mill

information managementsystem, Process Explorer,

provide data in regards to HVLC

collection system startup

events.

1 1 Operators receive DCS alarms for opening of ve

valves or collect valve closing during shutdown

indicating process conditions have fallen out of

normal operating ranges for the purpose of

shuting down the process.

Kraft Pulping: HVLC INC_BOIL 112 4 Collection and control systems operating before

start‐up

When NCG generating systemsstabilize

continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: HVLC INC_BOIL 116 1 ~4 hrs 4 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not the

collection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit ~4 hrs 4 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: HVLC INC_BOIL 131 1 24 24 Boilers in operation Washers fully operational 24 24 Boilers in operation 

Kraft Pulping: HVLC INC_BOIL 135 1 0.5 0.5 HVLC System: The No1, No2 Power Boiler, or

Recovery Boiler is operating and ready to accept

HVLC gases for combustion.

HVLC System: The safety vent

valve has closed and the HVLC

fan rate is steady and gases arebeing combusted in the No1 orNo2 Power Boiler.

0.5 0.5 HVLC System: All emission units have been shu

down prior to shutting down the HVLC collectiosystem.

Kraft Pulping: Pulping: HVLC INC BOIL INC_BOIL 143 1 Hot: 0 5. ‐ 1 0. 4 (1) Confirm HVLC System and Treatment Units HVLC Collection System and Hot or Cold: 1.5 Other Regulated Condensates: Maintain No 4 

hours Cold:

3.0 ‐4.0

hours

4 (1) Confirm HVLC System and Treatment Units

are operating and determine if HVLC gases may

be routed to the NCG TO (2) Confirm HVLC

Collection System fan to the NCG TO isoperational

HVLC Collection System and

Treatment Units are operatingand gases are being collected.

Hot or Cold:

0.5 ‐ 1.5

hours

1.5 Other Regulated Condensates: Maintain No. 4

Chemiwasher and HVLC Collection and

Treatment System until after Other Regulated

Condensates are stopped being fed to the No. 4

Chemiwasher.

Kraft Pulping: HVLC INC_BOIL 145 1 0.1 0.1 shut down the brownstock stock pumps maintain negative set point for

the collection system @ the

HVLC Fan

NA ‐ applicable emission and parameter limitsnot expected to be exceeded during shutdown

Kraft Pulping: HVLC INC_BOIL 147 1 NA NA NA NA NA 

Kraft Pulping: HVLC INC_BOIL 148 3 NA NA NA NA 

Kraft Pulping: HVLC INC_BOIL 150 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Boiler permissives met 0.25 0.25 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: HVLC INC_BOIL 152 1 0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

fan is started 0.25 0.25 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: HVLC INC_BOIL 154 1 7 7 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Furnace temperature above

1700deg F

0.5 0.5 Continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: HVLC INC_BOIL 156 1 8.333333333

33333E‐02

0.083333333 follow SSM manual procedures Weak NCG flow into one or

more Kiln/Boiler, Weak NCG

Vent is closed to atmosphere

8.333333333

33333E‐02

0.083333333 follow SSM manual procedures 

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: HVLC INC_BOIL 165 1 0 0 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit 0 0 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: HVLC INC_BOIL 167 1 0.5/0.5

Routine/Ann

ual

0.5 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not the

collection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit 0.5/0.5

Routine/Ann

ual

0.5 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: HVLC INC_BOIL 173 1 1 ‐ 2 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

HVLC system is in service and

lined up to power boiler

1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: HVLC INC_BOIL 176 1 1 1 Restrict washer startup until PB1 is on line Switching valve is opened to

allow introduction of NCGs

1 1 Incineration point in operation until washers

reach non‐emit state

Kraft Pulping: HVLC INC_BOIL 179 1 NA NA NA NA NA 

Kraft Pulping: HVLC INC_BOIL 181 1 0.1 0.1 NA ‐ collection system to be operated at all times

sources operating (except following cold outage)

HVLC fan operating 0.1 0.1 NA ‐ collection system to be operated at all tim

sources operating

Kraft Pulping: HVLC INC_BOIL 200 1 2 2 At least one combination boiler should be fully

operational before the generation of theregulated pollutants is initiated

Combination boiler No. 1 or No.

2 online, rupture disks intact,no alarms

1 1 continue routing emissions to primary or backu

control system

Kraft Pulping: HVLC INC_BOIL 205 1 0.01 0.01 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

HVLC gas flow into control

device

0.01 0.01 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: HVLC INC_BOIL 207 1 0.50 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

when washers, screens or

knotters start up

8 8 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: HVLC INC_BOIL 340 1 4 4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

0.1 0.1 

Kraft Pulping: HVLC INC_BOIL 525 1 8 8 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

DNCG introduced into one of

the two boilers

0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: HVLC INC_BOIL 531 1 NA There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit NA There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: HVLC INC_LK 117 1 1 1 Operate NCG Collection System during Start‐UP Target production rate reached 1.5 1.5 Operate kiln ‐ P36 while generating NCGs 

Kraft Pulping: HVLC INC_LK 197 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Gases are being collected and

routed to the kiln for

destruction

2 2 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: HVLC INC_LK 199 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Initiation of startup of the pulp

washing system (production of

HVLC gases)

0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Kraft Pulping: HVLC INC_LK 226 2 0.25 0.25 ensure primary and backup control are available Any digester set is operating

and HVLC blower speed is

satisfied, and HVLC flow is >0.0

and HVLC vent valve is closed.

0.25 0.25 

Kraft Pulping: HVLC INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

The HVLC Gas System operation

is stable and all operating

problems have been addressed.

shut down the HVLC Gas sytem sources before

venting the Lean Gas System gases.

Kraft Pulping: HVLC INC_LK/SCBR 121 1 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

NA NA continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: HVLC INC_LK/SCBR 121 1 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

NA NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: HVLC INC_LK/SCBR 121 1 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

NA ‐ not an emission unit NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: HVLC INC_LK/SCBR 121 1 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Operating parameters are in

line with the values shown in

the SSM plan

NA continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: HVLC INC_LK/SCBR 137 1 36 36 FOLLOW SSM PLAN All HVLC sources are being

burned in a lime kiln

24 24 FOLLOW SSM PLAN 

Kraft Pulping: HVLC INC_RF 107 1 <1 hr 1 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Gases are collected and controldevice is operating withingrequired range.

<1 hr 1

Kraft Pulping: HVLC INC_RF 109 1 7 7 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When the unit is at target

temperature after completingthe start up curve.

7 7 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: HVLC INC_RF 111 1 0.17 0.17 Source vent and/or collection valves positions

are verified during lock‐out/tag‐out process.

Routine Operation visual checks of the collection

system.

Startup has been achived whenall the interlocks (permissives)have been met.

0.17 0.17 Operators receive alarm for opening of vent

valves or collect valve closing.

Kraft Pulping: HVLC INC_RF 133 1 0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

HVLC fan is operational 0.25 0.25 continue routing emissions control system unti

all sources are shut down

Kraft Pulping: HVLC INC_RF 155 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

when stock flow to knotters >

500 gpm for 1 hr

0.25 0.25 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: HVLC INC_RF 182 1 16 16 Ensure that recovery boiler is operational prior to

startup.

When incineration device

permissives are met

4 4 Shutdown sources of NCGs prior to shutdown. 

Kraft Pulping: HVLC INC_RF 185 1 0.1 0.1 Operators verify that the valves on the collection

lines are arranged to allow HVLC's into the

collection system

Vent valves closed and thevalve to the combustion unit is

open

0.1 0.1 NA ‐ Collection system only shutdown when

incineration device is no longer operating

Kraft Pulping: HVLC INC_RF 202 1 4 Based on

HVLC SSM

4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup‐ 

First Stage Repulper (425‐041‐024.F1)

4 hours

based on

4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Plan with venting allowances for HVLC and LVHC

sources

in operation for 4 hours SSM Plan with venting allowances for HVLC and LVHC

sources

Kraft Pulping: HVLC INC_RF 243 1 0 0 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

HVLC gas coolers operational

and collection system meets

safety parameters required

before entry to boiler

0 0 Make sure all emission units are down before

shutting down collection system

Kraft Pulping: HVLC INC_RF 615 1 NA NA NA NA NA 

Kraft Pulping: HVLC INC_RF 617 1 1 hour 1 start up recovery boiler prior to HVLC gas

collection system start‐up, when possible

gases are routed to recovery

boiler

.5 hour 0.5 continue routing emissions to recovery boiler

until HVLC process is shut down

Kraft Pulping: HVLC INC_RF 208228535 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

0.1 0.1 continue routing emissions to HVLC‐7 collectio

system and primary control device

Kraft Pulping: HVLC INC_RF 208228535 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

0.1 0.1 continue routing emissions to HVLC‐8 collectio

system and primary control device

Kraft Pulping: HVLC INC_RTO/SCBR 610 1 NA NA

Kraft Pulping: HVLC INC_RTO/SCBR/WES 166 1 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: HVLC INC_TO 107 1 <1 hr 1 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Gases are collected and controldevice is operating withingrequired range.

<1 hr 1

Kraft Pulping: HVLC INC_TO/SCBR 100 1 ~2 hrs 2 There are no HAP emissions as a result of starting

up the collection system. HAPs are only

generated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit ~1 hr 1 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: HVLC INC_TO/SCBR 102 1 1 1 Source vent and/or collection valves positions

are verified during lock‐out/tag‐out removal

process and system startup SRM. Preventive

Maintenance checks provide routine visualchecks of the collection system.

Startup has been achievedwhen all the interlocks have

been met, fans are running and

header flows are established.

1 1 Shut down sources before shutting down

collection & control systems.

Kraft Pulping: HVLC INC_TO/SCBR 169 1 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA ‐ Not an emissions unit There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: HVLC INC_TO/SCBR 189 1 0.25 0.25 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. I started up the HVLC System

Collection fan. I have verified that all gas

collection points have been checked for no

visible emissions. (If gases are not being drawn to

the collection system, make adjustments to

balancing dampers.) I have verified that the HVLC

Collection Valve is sending the gases to the

Incinerator.

Per the SSM Plan, collection of

HVLC/LVHC System. I haveverified that the Incinerator isrunning and is ready to accept

the HVLC vent gases. I have

verified that the Gas Cooler

cooling water valve (TV‐003) is

operational. I have verified that

the vent

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System. Proceed to

shutdown all HVLC system equipment.

Kraft Pulping: HVLC INC1 103 2 20 20 Use low‐pressure fresh steam for chip bin pre‐

steaming until a steady level is maintained and

the digester is running normally. Check for

proper water seal levels and flows and verify all

pressure and vacuum seals. HVLC NCG system is

The Continuous Digester

system startup is considered

complete when the digester

operations are stable, the No. 6

Digester chip feed is above 4.5

8 8 Shutdown the continuous digester system,

including associated tanks and other equipmenbefore shutting down the respective collection

system.

in a collect mode unless the system is down orlocked and tagged out. LVHC NCG process sourceor collection system may be vented duringstartup until it is safe to collect the gases.

Pulping condensates are sent to the appropriatecollection systems. Follow the proper startup

sequence and procedures outlined in the

appropriate sections for collection systems andcontrol devices. Due to NC Air Toxics limits, nofoul condensates are sewered.

rpm, the No. 7 Digester chip

feed is above 6 rpm, and the

HVLC and LVHC NCGs are beign

incinerated.

Kraft Pulping: HVLC INC1 111 1 1.343351548

3

1.343351548 HVLC NCG system is collecting gases prior to

startup of sources. Source vent and/or collection

valves positions are verified during lock‐out/tag‐

out process.

The Washing and Screeningsystem is considered started up

when target flow rate achieved.

0.095628415

301

0.095628415 HVLC NCG system is collecting gases during

shutdown of sources.

Kraft Pulping: HVLC INC1 165 4 Hot Startup:

0.5‐2 hours

Cold Startup:

1‐3 hours

3 BEFORE startup: (1) Confirm the HVLC System

control device is ready to accept gases and (2)Ensure equipment is properly valved to the HVLC

Collection System.

If A‐line washers stock flow has

reached the appropriate level.

Hot

Shutdown:

0.5‐2 hours

Cold

Shutdown: 1‐

3 hours

3 Continuing routing emissions to the HVLC

Collection System and Control Device

Kraft Pulping: HVLC INC1 165 2 Hot Startup:

0.5‐2 hours

Cold Startup:

1‐3 hours

3 BEFORE startup: (1) Confirm the HVLC System

control device is ready to accept gases and (2)Ensure equipment is properly valved to the HVLC

Collection System.

If B‐line washers stock flow hasreached the appropriate level.

Hot

Shutdown:

0.5‐2 hours

Cold

Shutdown: 1‐

3 hours

3 Continuing routing emissions to the HVLC

Collection System and Control Device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: HVLC INC1 185 2 Integrated

with Pandia

Digester

Startup ‐ 4.0

hours

4 Unit is only started if the associated collection

system is operating.

Integrated with Pandia Digester

Startup ‐ See Cells DS20 andDS21

Integrated

with Pandia

Digester

Shutdown ‐ 

1.5 hour

1.5 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

Kraft Pulping: HVLC INC1_BOIL 149 1 0 0 Primary or alternate control device on prior to

startup

HVLC fan on 0 0 Primary or alternate control device on

throughout shutdown

Kraft Pulping: Knotter

Kraft Pulping: Knotter INC (see note) 182 2 30 30 Operate NCG and foul condensate systems

properly

30 30 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Knotter INC_BOIL 177 1 1 1 continue routing emissions to EU1151 or EU0804 When Brown Stock Washers

have reached normal operating

rate and targeted shower flows.

1 1 continue routing emissions to EU1151 or EU080

Kraft Pulping: Knotter INC_BOIL 207 1 0.17 0.17 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

all valves lined up, pumps

running and stock goingthrough knotter

0.17 0.17 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Knotter INC_BOIL1 600 4 Hot Startup:

0.5‐4 hours;

Cold Startup:

0.5‐4 hours

4 BEFORE startup of the Brown stock washing

system: (1) Confirm the HVLC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the HVLC

Collection System.**Operate the Brown stock

washing equipment System in such a way as to

prevent over pressurization of system upon

startup.

Hot

Shutdown:

0.5‐4 hours;

Cold

Shutdown:

0.5‐4 hours

4 (1) Continuing routing emissions to the HVLC

System and Control Device (2) Operate the BS

washing in such a way as to prevent over

pressurization of system during shutdown.

Kraft Pulping: Knotter INC_LK 117 1 0.5 0.5 Operate NCG Collection System during Start‐UP Target production rate reached 1 1 Operate kiln ‐ P36 while generating NCGs 

Kraft Pulping: Knotter INC_RF 155 2 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

when stock flow to knotters >

500 gpm for 1 hr

0.25 0.25 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Knotter INC_RF 182 1 30 30 Operate NCG and foul condensate systems

properly

30 30 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Knotter INC_RF 615 2 1 1 Unit is only started if the associated collection

system is operating

Stock flow is established

through entire washer line

0.5 0.5 Associated collection system is operated throu

duration of shutdown

Kraft Pulping: Knotter INC1 103 2 20 20 To minimize emissions during startup, the HVLC

NCG system is collecting gases prior to system

Completion of startup isverified using the facility DCS

8 8 Emissions of the pulp washing and screening

system are minimized during shutdown by

NCG system is collecting gases prior to system 

startup, the source vent and collection valve

positions are verified using the preliminary

checklist, and condition monitoring routes

provide routine visual checs of the collection

system.

verified using the facility DCS

and Process Explorer tags to

verify that the pulp washing

and screenng systems have

atained normal operatingconidtions.

system are minimized during shutdown by

completing shut down of the process units prio

to shutting down the HVLC collection system.

Kraft Pulping: Knotter INC1 150 1 0.5 0.5 continue routing emissions to HVLC‐1 collection

system and primary or backup control system

All four washer level controls in

"Auto"

0.5 0.5 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Knotter INC1 150 2 2 2 continue routing emissions to HVLC‐1 collection

system and primary or backup control system

Startup complete after 4 blows

and knotter supply pump is

running

1 1 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Knotter INC1 151 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

A negative draft has been

established for the foul

condensate filter and F‐

secondary knotter Lean (HVLC)Gas Vent lines.

shut down the HVLC Gas system sources before

venting the lean gases

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Knotter INC1 162 2 1 1 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment isproperly valved to the LVHC Collection

System.**Operate the Digester System in such a

way as to prevent over pressurization of systemupon startup such as: (1) Do not blow a digester

or cook a digester until all pieces of the blow

heat system are running and within acceptablecontrol limits, and (2) Ensure critical pumps on

the blow heat system are running prior to

blowing a digester. If blow heat pressure is too

high and the vent has opened, do not attempt to

blow another digester until the problem can be

found and repaired.

Blow heat system standard

operating conditions are met

and digesters are routinely

blowing

1 1 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way a

to prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend thecooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Knotter INC1 184 1 0.5 0.5 Continue routing emissions to HVLC collection

system.

When flow stabilizes. 0.5 0.5 Continue routing emissions to HVLC collection

system.

Kraft Pulping: Knotter INC1 185 1 Integrated

with KBS

Washer Line

Startup ‐ 3.5

hours

3.5 Unit is only started if the associated collection

system is operating.

Integrated with KBS WasherLine Startup ‐ See Cell DS33.

Integrated

with KBS

Washer Line

Shutdown ‐ 

3.5 hours

3.5 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

Kraft Pulping: Knotter INC1/SCBR 136 1 NA NA NA NA NA 

Kraft Pulping: Knotter SCBR 186 3 2 2 2 2

Kraft Pulping: Knotter/Screen

Kraft Pulping: Knotter/Screen INC_BOIL 154 2 0.1 0.1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow 0.25 0.25 Continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Knotter/Screen INC_BOIL 177 1 1 1 When the oxygen reactor

reaches normal operating rate

and post oxygen washers are

operating at normal stock flow

and normal shower flow.

1 1 continue routing emissions to EU1151 or EU080

Kraft Pulping: Knotter/Screen INC_BOIL 200 1 6 6 At least one combination boiler should be fully

operational before the generation of the

stock flow stable, pumprunning no alarms

6 6 continue routing emissions to HVLC collection

system and primary or backup control system

operational before the generation of the 

regulated pollutants is initiated

running, no alarms system and primary or backup control system 

Kraft Pulping: Knotter/Screen INC_BOIL 205 1 0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Completion of 30 minutes of

stock flow to knotter systemand 30 minutes of operation ofscreen feed pump

0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Knotter/Screen INC_BOIL1 600 1 Hot Startup:

0.5‐4 hours;

Cold Startup:

0.5‐4 hours

4 BEFORE startup of the Brown stock washing

system: (1) Confirm the HVLC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the HVLC

Collection System**Operate the Brown stock

washing equipment System in such a way as to

prevent over pressurization of system upon

startup.

Hot

Shutdown:

0.5‐4 hours;

Cold

Shutdown:

0.5‐4 hours

4 (1) Continuing routing emissions to the HVLC

System and Control Device (2) Operate the BS

washing in such a way as to prevent over

pressurization of system during shutdown.

Kraft Pulping: Knotter/Screen INC_BOIL1 600 8 Hot Startup:

0.5‐4 hours;

Cold Startup:

0.5‐4 hours

4 BEFORE startup of the Brown stock washing

system: (1) Confirm the HVLC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the HVLC

Collection System.**Operate the Brown stock

washing equipment System in such a way as to

prevent over pressurization of system upon

startup.

Hot

Shutdown:

0.5‐4 hours;

Cold

Shutdown:

0.5‐4 hours

4 (1) Continuing routing emissions to the HVLC

System and Control Device (2) Operate the BS

washing in such a way as to prevent over

pressurization of system during shutdown.

Kraft Pulping: Knotter/Screen INC_LK 199 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stock flow to knotter system for

1 hour

0.5 0.5 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Knotter/Screen INC_LK/SCBR 137 2 1 1 FOLLOW SSM PLAN All HVLC sources are being

burned in a lime kiln

12 12 FOLLOW SSM PLAN 

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Knotter/Screen INC_RF 119 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When No.21 Rec. Blr. is firing

black liquor, is stable and safety

interlocks are satisfied.

4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shut down

Kraft Pulping: Knotter/Screen INC_RTO/SCBR 610 1 1 1 emission unit and control device operates in

compliance with NESHAP parameter limits during

emission unit startup

When the A knotter screen flow

is greater than 100 gpm for 10

minutes.

1.5 1.5 continue routing emissions to HVLC‐1 collectio

system and primary control system

Kraft Pulping: Knotter/Screen INC1 103 2 20 20 To minimize emissions during startup, the HVLC

NCG system is collecting gases prior to system

startup, the source vent and collection valve

positions are verified using the preliminary

checklist, and condition monitoring routes

provide routine visual checs of the collection

system.

Completion of startup isverified using the facility DCS

and Process Explorer tags to

verify that the pulp washing

and screenng systems have

atained normal operatingconidtions.

8 8 Emissions of the pulp washing and screening

system are minimized during shutdown by

completing shut down of the process units prio

to shutting down the HVLC collection system.

Kraft Pulping: Knotter/Screen INC1 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

A negative draft has been

established for the foul

condensate filter and F‐

secondary knotter Lean (HVLC)Gas Vent lines.

shut down the HVLC Gas system sources before

venting the lean gases

Kraft Pulping: Knotter/Screen INC1 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

The G‐Washer lean gases are

boing collected.

shut down the HVLC Gas system sources before

venting the lean gases

Kraft Pulping: Knotter/Screen INC1 185 3 Integrated

with KBS

Washer Line

Startup ‐ 3.5

hours

3.5 Unit is only started if the associated collection

system is operating.

Integrated with KBS WasherLine Startup ‐ See Cell DS33.

Integrated

with KBS

Washer Line

Shutdown ‐ 

3.5 hours

3.5 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

Kraft Pulping: Knotter/Screen INC1 189 2 0 0 NA NA NA NA 

Kraft Pulping: Knotter/Screen INC1/SCBR 136 4 NA NA NA NA NA 

Kraft Pulping: Knotter/Screen SCBR 157 1 0.5 0.5 NA ‐ applicable emission and parameter limits When decker vat level is 0.5 0.5 NA ‐ applicable emission and parameter limits 

not expected to be exceeded during startup controlling at normal operating

level

not expected to be exceeded during shutdown 

Kraft Pulping: LVHC

Kraft Pulping: LVHC INC 196 1 0.25 0.25 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

LVHC vapors collected in

system

0.25 0.25 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: LVHC INC/SCBR 136 1 0 0 Do not start process until collection system

operational

Vent valves closed and

emissions routed to IQS/Power

Boilers

0 0 Shut down process before collection system

shutdown

Kraft Pulping: LVHC INC_BOIL 115 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Precooked Chips going toDigester

0.5 0.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: LVHC INC_BOIL 127 1 3 3 Emissions routed to Thermal Oxidizer (Power

Boiler 3 as backup control)

Establish desired black liquor

solids concentration fromEvaporator Set

1 1 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Kraft Pulping: LVHC INC_BOIL 147 1 NA NA NA NA NA 

Kraft Pulping: LVHC INC_BOIL 150 1 2 2 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

satisfy control devicepermissives, opening steamvalves to the eductors, closing

bypass vent valves.

0.25 0.25 emission unit and control device operates durin

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Kraft Pulping: LVHC INC_BOIL 152 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

steam flow to eductor is begun

and temperature and flow

permissives met

0.25 0.25 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: LVHC INC_BOIL 154 1 7 7 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Furnace temperature above

1700deg F

0.2 0.2 Continue routing emissions to LVHC collection

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: LVHC INC_BOIL 156 1 8.333333333

33333E‐02

0.083333333 follow SSM manual procedures Strong NCG flow into one or

more Kiln/Boiler, Strong NCGVent is closed to atmosphere

8.333333333

33333E‐02

0.083333333 follow SSM manual procedures 

Kraft Pulping: LVHC INC_BOIL 173 1 1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

LVHC system is in service and

lined up to power boiler

1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: LVHC INC_BOIL 174 1 NA There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not the

collection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit NA There are no HAP emissions as a result of starti

up the collection system. HAPS are only

generated by the emission units and not the

collection system. The collection system andcontrol device must be operational prior to

startup of an emission source.

Kraft Pulping: LVHC INC_BOIL 179 1 NA NA NA NA NA 

Kraft Pulping: LVHC INC_BOIL 181 1 0.1 0.1 NA ‐ collection system to be operated at all times

sources operating (except following cold outage)

steam ejectors operating 0.1 0.1 NA ‐ collection system to be operated at all tim

sources operating

Kraft Pulping: LVHC INC_BOIL 182 1 12 12 Ensure that power boilers are operational prior

to startup.

When incineration device

permissives are met

2 2 Shutdown sources of NCGs prior to shutdown. 

Kraft Pulping: LVHC INC_BOIL 185 1 0.02 0.02 Seal tank valves on evaporators are arranged to

allow dilution air to be drawn into the seal tanks

to dilute NCGs

Vent valves closed and thevalve to the combustion unit is

open

0.02 0.02 NA ‐ Collection system only shutdown when

incineration device is no longer operating

Kraft Pulping: LVHC INC_BOIL 201 1 0.3 0.3 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Completion of 15 minutes with

steam flow to evaporator

system greater than 50,000

lb/hr

0.3 0.3 continue routing emissions to LVHC collection

system to primary or backup control system

Kraft Pulping: LVHC INC_BOIL 531 1 NA There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit NA There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC INC_BOIL 617 1 1 hour 1 start up boilers prior to collecting gases gases are routed to power

boilers

1 hour 1 continue routing emissions to power boiler unt

LVHC processes are down

Kraft Pulping: LVHC INC_LK 133 1 0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

LVHC system is conveying gases

and the collected gases are

incinerated in a lime kiln

0.25 0.25 continue routing emissions to primary or backu

control system until all sources are shut down

Kraft Pulping: LVHC INC_LK 135 1 0.5 0.5 LVHC System: The kiln is operating and ready to

accept LVHC gases for combustion. Or the No1

Boiler is operating and HVLC gases are being

combusted prior to diverting the LVHC gases intothe HVLC system for combustion.

LVHC System: The safety vent

valves have closed and the lime

kiln steam eductor rate issteady or the LVHC gases are

being diverted into the HVLC

system.

0.5 0.5 LVHC System: All emission units have been shu

down prior to shutting down the LVHC collectio

system.

Kraft Pulping: LVHC INC_LK 169 1 There are no HAP emissions as a result of starting

up the collection system. HAPS are only

generated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA ‐ Not an emissions unit There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC INC_LK 197 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Gases are being collected and

routed to the kiln for

destruction

2 2 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: LVHC INC_LK 199 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Initiation of startup of either

digester system or multiple‐effect evaporator system

(production of LVHC gases)

0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: LVHC INC_LK 202 1 variable ‐  

Based on

LVHC SSM

Plan ‐ In 2009

varied froim

4 hours to 21

hours

depending

on when

conditions

were met.

21 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup‐ with venting allowances for HVLC and LVHCsources

LVHC System normal operating

conditions are as follows:(1)

Batch Digester System (with

Blow Heat Recovery and

Turpentine Recovery) ‐ 

Completion of one sequence of

digester blows following startup

(exceeding minimum steam

flow to headers for Nos. 1‐4

digesters and Nos. 5‐8

digesters, 415‐FI‐005 and 415‐FI‐

128, respectively, for 4

consecutive hours of

operation), and (2) Pre‐Evaporator System 14% liquorflow to pre‐evaporators (500‐041‐002.F1 is ON) for 1 hourANDCompletion of one sequence ofdigester blows following startup

and (3) Multiple‐Effect

Evaporator System Weak black

liquor feed to evaporators (512‐

FIC‐704) > 700 gpm for 1 hour

(Winter months) Wintermonths startup canalternatively be verified when

k l fl l

variable ‐  

Based on

LVHC SSM

Plan ‐ In 2009

varied froim

2.5 hours to

7 hours

depending

on when

conditions

were met.

7 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

with venting allowances for HVLC and LVHCsources

Kraft Pulping: LVHC INC_LK 203 1 0.33 0.33 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

emission source isolation valves

open, emission source ventvalves closed, incineration pointisolation valve open (as per

SSM plan)

0.33 0.33 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: LVHC INC_LK 205 1 0.01 0.01 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

LVHC gas flow into control

device

0.01 0.01 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: LVHC INC_LK 206 1 NA emission unit and control device operates in

compliance with NSPS and NESHAP parameter

When any of the sources

feeding LVHC gases to the

NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

compliance with NSPS and N SHAP parameter limits during emission unit startup

feeding VHC gases to thesystem begin start‐up.

system and primary or backup control system 

Kraft Pulping: LVHC INC_LK 226 1 0.25 0.25 ensure primary and backup control are available The condensate stripper is

operating and SOG vent valve

at Kiln and Thermal Oxidizer is

closed.

0.25 0.25 

Kraft Pulping: LVHC INC_LK 208228535 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Commencement of LVHC gas

transfer to control device

(steam flow to LVHC ejectors at

proper ejector vacuum

conditions)

0.1 0.1 continue routing emissions to LVHC‐7 collectio

system and primary control device

Kraft Pulping: LVHC INC_LK 208228535 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Commencement of LVHC gas

transfer to control device

(steam flow to LVHC ejectors at

proper ejector vacuum

conditions)

0.1 0.1 continue routing emissions to LVHC‐8 collectio

system and primary control device

Kraft Pulping: LVHC INC_LK/ESP 105 1 Hot Startup:

2 to 4 hours;

Cold Startup:

6 to 12 hours

12 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

When stripper off gases arebeing burned in the destruction

device and the effective steam

ratio or process wastewater

feed rate, steam feed rate, and

process wastewater column

feed temperature conditionsare met.

Hot

Shutdown:

0.5 to 2

hours; Cold

Shutdown: 6

to 8 hours

8 LVHC system must continue on line until the

vacuum pumps and steam to the unit is shut

down.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: LVHC INC_LK/ESP 105 1 See the

emission

units in the

digester

system,

turpentine

system,

evaporator

system, etc)

There are no HAP emissions as a result of startingup the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit. See the

emission

units in the

digester

system,

turpentine

system,

evaporator

system, etc)

There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC INC_LK/SCBR 121 1 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

NA NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: LVHC INC_LK/SCBR 121 1 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

NA ‐ not an emission unit NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: LVHC INC_LK/SCBR 139 1 0.1 0.1 Combustion permissives satisfied prior to

startup.

NCG's introduced to

cumbustion unit.

0.1 0.1 Combustion permissives satisfied prior to

startup.

Kraft Pulping: LVHC INC_LK/SCBR 142 1 2 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Adequate vacuum ismaintained at essential inlets

and outlets of the LVHC system

for 60 minutes.

2 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: LVHC INC_LK/SCBR 340 1 0.2 0.2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

1 1 

Kraft Pulping: LVHC INC_LK/SCBR 613 1 2 2 Per the SSM Plan: Start NCG/SOG system as per

mill procedures. The area collection system foreach process system will be divertred into the

collection header. Insure that the lime kiln or

oxidizer is allowed to reach a normal operating

state prior to switching the next source into the

collection header. Startup each area source anddivert the NCG/SOG gases into the collection

header. Inusre that all rupture discs have beenchecked for integrity.

Per the SSM Plan:**NCG gas

temp, <160 F. NCG System

vacuum, in of H2O ‐22, NCGflow cfm >500, ejector steamflow pph >1100, lime kiln

incineration system 1600F, novisible/odor emissions. H2Smonitors, no alarms. SOG flowACFM >300, SOG temperature

170‐350F, SOG pressure <7 psig.

2 2 Per the SSM Plan:

Shutdown the NCG/SOG collection system

including asociate4d ejectors, coolers, scrubbe

and other equipment as per mill procedures.

Kraft Pulping: LVHC INC_LK1 124 1 N/A ‐ many

EU's feed

into the

LVHC

Have kiln to operating temperature and LVHC

system fully operational before starting any EU

All EU's colllected N/A ‐ many

EU's feed

into the

LVHC

Keep LVHC system operational until all EU's are

down

Kraft Pulping: LVHC INC_RF 108 1 NA BEFORE startup of any of the equipment systems

feeding condensate to the tank: 1) Confirm the

LVHC System control device is ready to accept

gases and 2) Ensure equipment is properly valved

to the LVHC Collection System

Dependant on equipment

systems feeding tank

NA Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: LVHC INC_RF 108 1 NA There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit NA There are no HAP emissions as a result of

shutting down the control device. HAPS are ongenerated by the emission units and not the

control device. The control device must be

operational while one or more emission units a

running.

Kraft Pulping: LVHC INC_RF 111 1 1.314663023

7

1.314663024 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless the

system is down or locked and tagged out. LVHC

NCG process source or collection system may bevented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSMplan for collection systems and control devices.

The Continuous Digester

system startup is consideredcomplete when target flow rate

achieved.

0.230874316

94

0.230874317 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condenstates.

Kraft Pulping: LVHC INC_RF 115 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Precooked Chips going toDigester

0.5 0.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: LVHC INC_RF 615 1 NA NA NA NA NA 

Kraft Pulping: LVHC INC_RTO/SCBR/WES 166 1 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC INC_TO 107 1 <1 hr 1 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Gases are collected and controldevice is operating withingrequired range.

<1 hr 1

Kraft Pulping: LVHC INC_TO 112 2 Collection and control systems operating before

start‐up

When NCG generating systemsstabilize

continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: LVHC INC_TO 112 1 1.5 1.5 Collection and control systems operating before

start‐up

When NCG generating systems

stabilize

continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: LVHC INC_TO 148 2 NA NA NA NA 

Kraft Pulping: LVHC INC_TO/SCBR 100 1 ~2 hrs 2 There are no HAP emissions as a result of starting

up the collection system. HAPs are only

generated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit ~1 hr 1 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC INC_TO/SCBR 116 1 ~16 hours

prior to

venting to

the NCG

Incinerator

16 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit ~0.5 hrs 0.5 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC INC_TO/SCBR 138 1 0.25 0.25 The emission units are not started up until the

LVHC collection system is at operting conditions.

Steam flow the the eductor

reaches setpoint.

0.25 0.25 Emission units are shutdown prior to the

shutdown of the LVHC collection system.

Kraft Pulping: LVHC INC_TO/SCBR 143 1 Hot: 3.0 ‐ 8.0

hours Cold:

8.0 ‐ 12.0

12 (1) Confirm LVHC System and Treatment Units

are operating and route LVHC gases to LVHC

Treatment Unit; (2) Confirm Foul Condensate

LVHC Collection System and

Treatment Units are operatingand gases are being collected.

Hot and Cold:

0.5 ‐ 2.5

hours

2.5 Foul Condensates: Maintain Condensate Stripp

System and SOG Collection and Treatment

Systems until after Foul Condensates are

hours Systems are operating and ready to accept foul

condensate; (3) Level out the System andstabilize the vacuum

stopped being fed to the Stripper Maintain LVH

Collection and Treatment System until after

steam is taken off the Evaporator.

Kraft Pulping: LVHC INC_TO/SCBR 143 1 Hot: 3.0 ‐ 8.0

hours Cold:

8.0 ‐ 12.0

hours

12 (1) Confirm LVHC System and Treatment Units

are operating and route LVHC gases to LVHC

Treatment Unit; (2) Confirm Foul Condensate

Systems are operating and ready to accept foul

condensate; (3) Level out the System andstabilize the vacuum.

LVHC Collection System and

Treatment Units are operatingand gases are being collected.

Hot and Cold:

0.5 ‐ 2.5

hours

2.5 Foul Condensates: Maintain Condensate Stripp

System and SOG Collection and Treatment

Systems until after Foul Condensates are

stopped being fed to the Stripper Maintain LVH

Collection and Treatment System until aftersteam is taken off the Evaporator.

Kraft Pulping: LVHC INC_TO/SCBR 149 1 0 0 Primary or alternate control device on prior to

startup

Steam flow to ejectors 0 0 Primary or alternate control device on

throughout shutdown

Kraft Pulping: LVHC INC_TO/SCBR 155 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

when steam flow >5,000 lbs/hr

for 4 hrs

0.25 0.25 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: LVHC INC_TO/SCBR 155 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

when steam flow to digesters >

20,000 lbs/hr for 4 hrs

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: LVHC INC_TO/SCBR 155 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

when weak black liquor feed

temp > 150 F for 4 hrs

0.1 0.1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: LVHC INC_TO/SCBR 165 1 0 0 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit 0 0 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC INC_TO/SCBR 189 1 0.25 0.25 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. Check the LVHC System and verifythat there are no visible emissions and no

noticeable odors from all possible excess

emission points. Startup each area sourcefollowing mill standard operating procedures and

divert the LVHC gases into the Collection Header.

Insure that the Incinerator is allowed to reach a

normal operating state prior to switching the

next source into the Collection Header.

Following mill standard operating procedures,

the area collection systems for each process

system will be diverted into the Collection

Header, per operating procedure.

Per the SSM Plan, collection of

HVLC/LVHC System. Follow the

LVHC Pre‐Startup checklist as

defined by the mills standard

operating procedures. Verify

the Incinerator, Lime Kiln, or 9A

Boiler is online and at a

temperature ready to accept

LVHC gases.

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System. Shutdown the

LVHC Collection System including associatedEjectors, Coolers, Scrubbers, and other

equipment following standard operating

procedures.

Kraft Pulping: LVHC INC1 111 1 1.329007286 1.329007286 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless thesystem is down or locked and tagged out. LVHC

NCG process source or collection system may bevented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSM

plan for collection systems and control devices.

The Continuous Digester

system startup is consideredcomplete when target flow rate

achieved.

0.163251366

12

0.163251366 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condenstates.

Kraft Pulping: LVHC INC1 149 1 0 0 Primary or alternate control device on prior to

startup

Stripper on 0 0 Primary or alternate control device on

throughout shutdown

Kraft Pulping: LVHC INC1 156 1 4 4 follow SSM manual procedures Gland water has been turned

onto the Tailwater Pump

4 4 follow SSM manual procedures 

Kraft Pulping: LVHC INC1 166 1 NA BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases and (2) Ensure equipment is properly

valved to the LVHC Collection System.

Dependant on equipment

systems feeding tank

NA Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: LVHC INC1 613 2 2 2 Per the SSM Plan: Begin to recirculate water

through the crystallizer per standard operating

procedures. Begin pulling vacuum on

crystallizers with hogging ejectors after water is

introduced. Introduce the steam, per millstandard operating procedures, , andimmediately verify the NCG gases are being senttot he appropriate collection systems. Establisha minimum flow of liquor untile the solids

content of the black liquor from the second

crystallizer body increases to the set pint. Follow

standard OPs to adjust liquor flow and steam to

balance the crystallizer. Ensure that the

crystallizer system is operating within normalranges for process pressures, flows, andconductivity.

Per the SSM Plan:

Product solids: 73‐78%, C1Arecirc temp: 270 F. C2B, C2A,

C1B levels: 10 ft. C1A level: 9 ft.

C1A, C1B heater pressure: 40

psig.

2 2 Per the SSM Plan:**Shutdown the crystallizer

system and all associated equipment followingstandard operating procedures. The operatorwill ensure that all vent gases are no longer

being generated by the crystallizer system by

verifying that feed liquor

Kraft Pulping: LVHC SCBR/INC_BOIL 131 1 24 24 Boilers in operation Normal operation of digesters

or evaporators

24 24 Boilers in operation 

Kraft Pulping: LVHC SCBR/INC_BOIL 207 1 0.50 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

When digesters start steaming

or evaps start up

15 15 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: LVHC SCBR/INC_BOIL/ESP 531 1 NA There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit NA There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC SCBR/INC_LK 103 1 0.1 0.1 Manual valve positions are verified using

preliminary checklist. Operators receive alarm

for opening of vent valves or collect valve

closing. Basic Care Routes provide routine visual

checks of the collection system. No. 7 Digester:

LVHC and HVLC NCG Continuous Operation SOP

No. COOP.5.44

Startup has been achievedwhen all the interlocks have

been met.

1 1 Operators receive alarm for opening of vent

valves or collect valve closing.

Kraft Pulping: LVHC SCBR/INC_LK 172 1 Approximatel

y 2 hrs if

gases are

vented to the

Incinerator;

Approximatel

y 18 hrs if

gases are

vented to the

Lime Kiln

18 There are no HAP emissions as a result of starting

up the collection system. HAPs are onlygenerated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source.

NA‐Not an emission unit Approximatel

y 0.5 hrs if

gases were

being vented

to the

Incinerator;

Approximatel

y 3 hrs if

gases were

being vented

to the Lime

Kiln

3 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC SCBR/INC_LK 226 1 0.25 0.25 ensure primary and backup control are available Any Digester set or evaporator

set is ioperating and steam flow

to NCG eductor >1520 lbs/hr

and steam pressure to NCG

eductor >45 psig, and LVHCvent valve is closed.

0.25 0.25 

Kraft Pulping: LVHC SCBR/INC_LK 610 1 NA NA

Kraft Pulping: LVHC SCBR/INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

All sources are being collected

or the equipment for theventing source is down and

continue routing emissions to LVHC‐1 collectiosystem and primary or backup control system

isolated from the LVHC Gas

System. The lime kiln burninggases is operating in a stable

manner and all apparent

startup problems have beenaddressed. The NCG Scrubberand NCG Cooler are perfroming

peoperly or gases are bypassed

directly to the lime kiln burning

gases.

Kraft Pulping: LVHC SCBR/INC_LK/SCBR 167 1 3 ‐ 12

Routine/Ann

ual

12 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit 0.17

Routine/Ann

ual

0.17 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: LVHC SCBR/INC_LK/SCBR 169 1 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA ‐ Not an emissions unit There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: LVHC SCBR/INC_TO/SCBR 102 1 1 1 Source vent and/or collection valves positions

are verified during lock‐out/tag‐out removal

process and system startup SRM.Preventive Maintenance checks provide routine

visual checks of the collection system.

See Startup SRM for LVHC system

Startup has been achievedwhen vacuum and LVHC NCG

flow are established.

1 1 Normal procedure is to operate the LVHC NCG

system for several hours after all processes are

shutdown to purge HAP’s from the system.

Kraft Pulping: LVHC SCBR/INC_TO/SCBR 525 1 8 8 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Startup of an area NCG source

and divert the NCG gases into

the Collection Header

0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: LVHC SCRB/INC_BOIL/CYC/ 200 1 6 6 At least one combination boiler should be fully

operational before the generation of theregulated pollutants is initiated

Combination boiler No. 1 or No.

2 online, rupture disks intact,no alarms

2 2 continue routing emissions to primary or backu

control system

Kraft Pulping: NCG System

Kraft Pulping: NCG System INC_BOIL 145 1 0.1 0.1 close and secure all system drains and sample

ports

NCG pressure @ 3psig and NCG

auto vent valve is closed

shutdown the NCG gas compressor and close th

discharge hand valve on the NCG compressor

Kraft Pulping: NCG System INC_BOIL 600 3 Hot/Cold

Startup: 0.5‐

2 hours

2 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit Hot/Cold

Shutdown:

0.5 hours

0.5 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: NCG System INC_LK 186 1 When NCG's can be safely

incinerated in the control

device

Kraft Pulping: NCG System INC_LK 600 3 Hot/Cold

Startup: 1‐2

hours

2 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit Hot/Cold

Shutdown: 1

hour

1 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: Pulping: NCG System INC LK/ESP INC_LK/ESP 105 1 See the There are no HAP emissions as a result of starting NA‐Not an emission unit See the There are no HAP emissions as a result of 

emission

units in the

digester

system

There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA Not an emission unit. See the

emission

units in the

digester

system

There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: NCG System INC_LK/SCBR 176 1 1 1 Restrict mill operation until incineration point is

on line

Either continuous or batch

NCGs have reached normal

operation

1 1 Maintian incineration point operation until all

mill operations are down

Kraft Pulping: NCG System INC_RF 108 1 NA There are no HAP emissions as a result of starting

up the collection system. HAPS are only

generated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit NA There are no HAP emissions as a result of

shutting down the control device. HAPS are on

generated by the emission units and not the

control device. The control device must be

operational while one or more emission units a

running.

Kraft Pulping: NCG System INC_TO 116 1 ~3 hrs 3 There are no HAP emissions as a result of starting

up the collection system. HAPS are only

generated by the emission units and not the

collection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit ~3 hrs 3 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: NCG System INC_TO 178 1 <1 1 N/A ‐ not an emissions unit N/A not an emissions unit <1 1 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: NCG System INC_TO 178 1 UK BEFORE startup of any of the equipment systems

feeding condensate to the tank: 1) Confirm the

LVHC System control device is ready to accept

gases and 2) Ensure equipment is properly valved

to the LVHC Collection System.

Dependant on equipment

systems feeding tank

UK Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: NCG System INC_TO 242 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When flow through by‐pass

ceases

0.1 0.1 continue routing emissions to LVHC‐ AA‐026

collection system and primary or backup contro

system

Kraft Pulping: NCG System INC_TO/SCBR 137 1 14 14 FOLLOW SSM PLAN Steam flow to the LVHC

ejectors and NCG Incinerator

temperature > 1324 deg.F orflame detection in either limekiln

12 12 FOLLOW SSM PLAN 

Kraft Pulping: NCG System INC_TO/SCBR 243 1 0 0 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Lines at desired

pressures/vacuums to meetsafety requirements

0 0 Make sure all emission units are down before

shutting down collection system

Kraft Pulping: NCG System INC_TO/SCBR 243 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Production of concentrated

heavy liquor

0.25 0.25 continue routing emissions to NCG collection

system and primary or backup control system

Kraft Pulping: NCG System INC_TO/SCBR 525 1 0 0 NA NA 0 0 NA 

Kraft Pulping: NCG System INC1 185 1 See "PI

Controls" Tab

See "PI Controls" Tab See "PI Controls" Tab See "PI

Controls" Tab

See "PI Controls" Tab 

Kraft Pulping: NCG System INC1 240 1 UK NCG system is not started until the NCG

Incinerator control device is started up.

Startup ends and normal

opeation begins when all of the

startup emission minimizationchecklist items have been

verified.

UK Shutdown NCG transport system and clean

condensate collection system per theConcentrated NCG System Shutdown. Applicab

emission and parameter limits not expected to

be exceeded during shutdown.

Kraft Pulping: NCG System SCBR/INC_TO/SCBR 190 1 0.25 0.25 Ensure adequate water flow to pressure/vacuum

breakers. Ensure all flame arrestors have been

checked for proper differential pressure at each

operating source. Divert the NCG vent gases for

each process source into collection header

following the startup procedures for each

process system.

NCG incineration device is

operating , meets safety

permissive, and NCG gases havebeen verified to be directed tothe incineration device.

0.25 0.25 Continue to operate the NCG collection system

until all process equipment that is a source of

NCG gases has been shutdown.

Kraft Pulping: O2 Delig HVLC

Kraft Pulping: O2 Delig HVLC COND/INC_BOIL 112 1 6 6 Collection and control systems operating before

start‐up

When pulp, liquor, and gasses

exit tank

6 6 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: O2 Delig HVLC INC (see note) 182 4 36 36 Ensure NCG system is operating properly 16 16 Shutdown NCG system only after source has

been shutdown

Kraft Pulping: O2 Delig HVLC INC (see note) 182 3 8 8 Ensure NCG system is operating properly 6 6 Shutdown NCG system only after source has

been shutdown

Kraft Pulping: O2 Delig HVLC INC_BOIL 177 3 1 1 continue routing emissions to EU1151 or EU0804 When the oxygen reactor

reaches normal operating rate

and post oxygen washers are

operating at normal stock flow

and normal shower flow.

1 1 continue routing emissions to EU1151 or EU080

Kraft Pulping: O2 Delig HVLC INC_BOIL 200 1 6 6 At least one combination boiler should be fully

operational before the generation of theregulated pollutants is initiated

stock flow stable, pumprunning, no alarms

6 6 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: O2 Delig HVLC INC_BOIL 525 3 0 0 NA NA 0 0 NA 

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: O2 Delig HVLC INC_BOIL 525 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

gases introduced into the boiler 1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: O2 Delig HVLC INC_BOIL1 600 1 Hot Startup:

0.5‐1 hours;

Cold Startup:

0.5‐1 hours

1 BEFORE startup of the Oxygen delignification

system: (1) Confirm the HVLC System controldevice is ready to accept gases and (2) Ensure

equipment is properly valved to the HVLC

Collection System.**Operate the Oxygendelignification equipment in such a wa

Hot

Shutdown:

0.5‐1 hours;

Cold

Shutdown:

0.5‐1 hours

1 (1) Continuing routing emissions to the HVLC

System and Control Device (2) Operate the

Oxygen delignification in such a way as to

prevent over pressurization of system during

shutdown.

Kraft Pulping: O2 Delig HVLC INC_BOIL1 600 24 Hot Startup:

0.5‐1 hours;

Cold Startup:

0.5‐1 hours

1 BEFORE startup of the Oxygen delignification

system: (1) Confirm the HVLC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the HVLC

Collection System.**Operate the Oxygendelignification equipment in such a way

Hot

Shutdown:

0.5‐1 hours;

Cold

Shutdown:

0.5‐1 hours

1 (1) Continuing routing emissions to the HVLC

System and Control Device (2) Operate the

Oxygen delignification in such a way as to

prevent over pressurization of system during

shutdown.

Kraft Pulping: O2 Delig HVLC INC_BOIL1 600 2 Hot Startup:

0.5‐1 hours;

Cold Startup:

0.5‐1 hours

1 BEFORE startup of the Oxygen delignification

system: (1) Confirm the HVLC System control

device is ready to accept gases(2) Ensure

equipment is properly valved to the HVLC

Collection System**Operate the Oxygen

delignification equipment in such a way as to

Hot

Shutdown:

0.5‐1 hours;

Cold

Shutdown:

0.5‐1 hours

1 (1) Continuing routing emissions to the HVLC

System and Control Device (2) Operate the

Oxygen delignification in such a way as to

prevent over pressurization of system during

shutdown.

Kraft Pulping: O2 Delig HVLC INC_RF 182 3 36 36 Ensure NCG system is operating properly 16 16 Shutdown NCG system only after source has

been shutdown

Kraft Pulping: O2 Delig HVLC INC_RF 182 2 8 8 Ensure NCG system is operating properly 6 6 Shutdown NCG system only after source has

been shutdown

Kraft Pulping: O2 Delig HVLC INC_RF 198 2 0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

stock flow stable, pumpsrunning, no alarms, no rupture

disk failures

8 8 continue routing emissions to LVHC‐1 and HVLC

1 collection system and primary or backup

control system

Kraft Pulping: O2 Delig HVLC INC_RF 243 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Brownstock flow to equipment 0 0 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: O2 Delig HVLC INC_RF 208228535 2 4 4 emission unit and control device operates in Completion of 4 hours of stock 1 1 continue routing emissions to HVLC‐8 collectio

compliance with NSPS and NESHAP parameterlimits during emission unit startup

flow to knotter system system and primary control device 

Kraft Pulping: O2 Delig HVLC INC_RTO/SCBR 610 1 1 1 emission unit and control device operates in

compliance with NESHAP parameter limits during

emission unit startup

When the MC1 (brown pulp)

pump amps are equal to or

greater than 30

1.5 1.5 continue routing emissions to HVLC‐1 collectio

system and primary control system

Kraft Pulping: O2 Delig HVLC INC_TO 146 3 0.25 0.25 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends 15 minutes after

startup of the knotter feedpump

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: O2 Delig HVLC INC_TO 178 1 3 3 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

3 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: O2 Delig HVLC INC1 102 1 1 1 Until the HVLC gases are diverted into the

collection system, provide fresh water on the

washer to minimize emissions resulting from the

use of process condensates (if applicable) as

shower water.

Divert the HVLC vent gases from the process

sources in a a deliberate manner. Since the HVLC

system is an air dilute system, the time required

to divert all sources is dependent only on theability of the equipment to accept the vent gaseswithout causing a carryover of liquor, foam, or

fiber into the HVLC vent gas system.

Product flow 1 1 Shutdown the process equipment in the oxyge

delignification system per mill standard

operating procedures.

Kraft Pulping: O2 Delig HVLC INC1 111 1 1.228597449

9

1.22859745 0.636612021

86

0.636612022

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: O2 Delig HVLC INC1 111 1 1.242941712

2

1.242941712 0.568989071

04

0.568989071

Kraft Pulping: O2 Delig HVLC INC1 111 1 1.271630236

8

1.271630237 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless thesystem is down or locked and tagged out. LVHC

NCG process source or collection system may bevented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSM

plan for collection systems and control devices.

The Continuous Digester

system startup is consideredcomplete target flow rate

achieved.

0.433743169

4

0.433743169 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condenstates.

Kraft Pulping: O2 Delig HVLC INC1 162 2 0.5‐4 BEFORE startup of any of the equipment

systems: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

1 1 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: O2 Delig HVLC INC1 165 1 Hot or Cold

Startup: 0.5‐

1 hours

1 BEFORE startup: (1) Confirm the HVLC System

control device is ready to accept gases; and (2)

Ensure equipment is properly valved to the HVLC

Collection System.

If the valve designated as "to

O2 system" is open

Hot or Cold

Shutdown:

0.5‐1 hours

1 Continuing routing emissions to the HVLC

Collection System and Control Device

Kraft Pulping: O2 Delig HVLC INC1 165 4 Hot or Cold

Startup: 0.5‐

1 hours

1 BEFORE startup: (1) Confirm the HVLC System

control device is ready to accept gases and (2)Ensure equipment is properly valved to the HVLC

Collection System.

If the valve designated as "to

O2 system" is open

Hot or Cold

Shutdown:

0.5‐1 hours

1 Continuing routing emissions to the HVLC

Collection System and Control Device

Kraft Pulping: O2 Delig HVLC INC1 165 1 Hot or Cold

Startup: 0.5‐

1 hours

1 BEFORE startup: (1) Confirm the HVLC System

control device is ready to accept gases; and (2)

Ensure equipment is properly valved to the HVLC

Collection System.

If the valve designated as "to

O2 system" is open

Hot or Cold

Shutdown:

0.5‐1 hours

1 Continuing routing emissions to the HVLC

Collection System and Control Device

Kraft Pulping: O2 Delig HVLC INC1 185 3 <1.0 hour 1 Unit is only started if the HVLC system is

operating.

Once the O2 MC Feed Pump is

running.

0.75 hr 0.75 Unit is shutdown only when the HVLC system is

operating.

Kraft Pulping: O2 Delig HVLC INC1/SCBR 136 6 NA NA NA NA NA 

Kraft Pulping: O2 Delig HVLC SCBR 137 1 1 1 FOLLOW SSM PLAN Flow to Oxygen Blow Tank >

500 gpm or for two hours andOxygen Reactor Pressure > 20

12 12 FOLLOW SSM PLAN 

psi for 2 hours

Kraft Pulping: O2 Delig HVLC SCBR 140 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

The O2 reactor feed pum is on.

HVLC System is operating

Normally, fan is on and thescrubber has the minimum gp

and the stack temperature is

below the minimum.

HVLC System is operating Normally, fan is on an

the scrubber has the minimum gp and the stactemperature is below the minimum until allemission units are shut down.

Kraft Pulping: Turpentine LVHC

Kraft Pulping: Turpentine LVHC INC 147 1 0.3 0.3 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends when steam is

applied to the digester

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: Turpentine LVHC INC 148 1 NA NA NA NA 

Kraft Pulping: Turpentine LVHC INC 196 1 2.5 2.5 3 3 

Kraft Pulping: Turpentine LVHC INC_BOIL 127 3 0.75 0.75 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Blow tanks in normal operation 0.75 0.75 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Kraft Pulping: Turpentine LVHC INC_BOIL 145 2 0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

when full pulp flow from the

digester is obtained

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_BOIL 152 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

One hour of continuous

discharge to the blow tank

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_BOIL 174 2 Hot Startup:

0.5 Hours

Cold Startup:

2 Hours

0.5 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

Hot

Shutdown:

0.5 Hours

Cold

Shutdown: 4

Hours

4 Continuing routing emissions to the LVHC

Collection System and Control Device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Turpentine LVHC INC_BOIL 182 1 30 30 Operate NCG and foul condensate systems

properly

When pulp is transferred to the

blow tank

30 30 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Turpentine LVHC INC_BOIL 200 1 6 6 At least one combination boiler should be fully

operational before the generation of the

regulated pollutants is initiated

Chip system operating,

circulation pumps online,

digester blowing,and no alarms

6 6 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_BOIL 201 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Completion of 4 hours with

steam flow to digester system

greater than 75,000 lb/hr

1 1 continue routing emissions to LVHC collection

system to primary or backup control system

Kraft Pulping: Turpentine LVHC INC_LK 115 1 instantaneou

s

0 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Turpentine Decanter bottoms

flowing to Stripper Feed

instantaneou

s

0 continue routing emissions to LVHC‐2 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_LK 117 1 4.5 4.5 Operate NCG Collection System during Start‐UP All batch digesters on‐line 6 6 Operate kiln ‐ P36 while generating NCGs 

Kraft Pulping: Turpentine LVHC INC_LK 132 3 <1 hour 1 Emissions collected in a closed system Simultaneous <1 hour 1 Emissions collected in a closed system 

Kraft Pulping: Turpentine LVHC INC_LK 188 1 3 3 LVHC collection system and incineration (Lime

Kilns 1 or 2) are started prior to startup. Foul

condensate collection system is operating priorto startup.

NCG Inlet Pressure (to

condenser)  ‐4 to +3 inches H2O

NCG Inlet Temperature (to

condenser) 175 ‐ 210 ° F

Decanter Inlet Temperature

100 ‐ 165 ° FNCG Scrubber Gas OutletTemperature 60 ‐ 100 ° F

NCG Outlet Pressure  ‐4 to ‐6

inches H2O

4 4 LVHC gases continue to be collected and

incinerated unitl shutdown is complete.

Condensates continue to be collected until

shutdown is complete.

Kraft Pulping: Turpentine LVHC INC_LK 197 1 1.5 1.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Pulp Mill is in operation and

turpentine is being produced

1.5 1.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_LK 202 1 See LVHC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup‐ with venting allowances for HVLC and LVHC

sources

See LVHC System ‐ not further

defined

See LVHC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limitsnot expected to be exceeded during shutdown

with venting allowances for HVLC and LVHCsources

Kraft Pulping: Turpentine LVHC INC_LK/SCBR 121 3 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Chips are being cooked NA continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_LK1 600 2 Hot Startup:

0.5‐1 hours;

Cold Startup:

4‐6 hours

6 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

Hot

Shutdown:

0.5‐1 hours;

Cold

Shutdown: 4‐

8 hours

8 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester in such a way as to prevent overpressurization of system during shutdown

Kraft Pulping: Turpentine LVHC INC_RF 108 2 Hot = 0.5‐1

Cold = 4‐6

6 BEFORE startup of the Turpentine Recovery

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

Hot = 0.5‐1

Cold = 4‐8

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC_RF 119 2 12 12 backup/alternate control When No.21 Rec. Blr. Is firing

black liquor, is stable and safety

interlocks are satisfied. When

kiln front end temperature is1900‐2200 deg.F and kiln is

producing lime

4 4 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_RF 119 3 6 6 backup/alternate control When No.21 Rec. Blr. Is firing

black liquor, is stable and safety

interlocks are satisfied. When

kiln front end temperature is

1900‐2200 deg.F and kiln is

producing lime

4 4 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_RF 180 1 0 0 Underflow to Evaporator, overflow to turpentine

tank; gases collected in LVHC system

None 0 0 Underflow to Evaporator, overflow to turpentin

tank; gases collected in LVHC system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Turpentine LVHC INC_RF 180 1 0.1 0.1 gases collected in LVHC system Cooling water flow normal 0 0 gases collected in LVHC system 

Kraft Pulping: Turpentine LVHC INC_TO 112 1 0.5 0.5 Collection and control systems operating before

start‐up

When turpentine begins

accumulating

10 10 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_TO 146 1 0.3 0.3 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends when steam is

applied to the digester

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: Turpentine LVHC INC_TO 178 1 3 3 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

3 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC_TO 178 1 3 3 BEFORE startup of the Turpentine Recovery

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditions

are met and digesters are

gassing off routinely

3 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC_TO 178 1 6 6 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System/

Standard operating conditions

are met and digesters are

gassing off routinely

3 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC_TO 178 1 6 6 BEFORE startup of the Turpentine Recovery

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

3 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC_TO 178 1 NA BEFORE startup of the Turpentine Recovery

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

NA Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC_TO 178 1 NA Ensure the condensate collection system and

control device are in operation and all system

values are in the appropriate position before

initiating startup on the digesters or turpentine

system

Standard operating conditions

are met and digesters are

gassing off routinely

NA Continuing routing condensates to the

Condensate System and Control Device

Kraft Pulping: Turpentine LVHC INC_TO/SCBR 137 1 6 6 FOLLOW SSM PLAN Digester Steam flow > 50,000 12 12 FOLLOW SSM PLAN 

lb/hr for 2 hours 

Kraft Pulping: Turpentine LVHC INC_TO/SCBR 138 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

A digester is blown. 0.1 0.1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_TO/SCBR 143 1 Hot: 3.0 ‐ 8.0

hours Cold:

8.0 ‐ 12.0

hours

12 (1) Confirm LVHC System and Treatment Units

are operating and route LVHC gases to LVHC

Treatment Unit; (2) Confirm Foul Condensate

Systems are operating and ready to accept foul

condensate; (3) Level out the System andstabilize the vacuum.

Establish system consistency

with a stabilized vacuum, cleancondensates and target solids

level.

Hot and Cold:

0.5 ‐ 2.5

hours

2.5 Maintain LVHC and HVLC Collection and

Treatment Systems until after steam is taken o

the Evaporator Set

Kraft Pulping: Turpentine LVHC INC_TO/SCBR 155 2 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

when steam flow to digesters >

20,000 lbs/hr for 4 hrs

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC_TO/SCBR 243 1 0 0 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Product turpentine to decanter 0.25 0.25 continue routing emissions to NCG collection

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC1 102 1 1 1 Tank levels are adequate to receive foul

condensates. Auto‐fill or continuous fill of loop

seals ensure seals intact and operating correctly.PM routes are performed to ensure equipment is

in proper operating mode and visually checked

for piping or equipment leaks.

Level and conductivity

indication and alarms in theDCS are utilized to verify thecondensates are collected

according to each unit process’

operating guidelines.

1 1 By design, when the collection system is down,

the following measures are taken to minimize

emissions:Condensate re‐used in pulping processes toextent practical

Excess condensates are sent to biological

effluent treatment via sealed or semi‐sealed

systems

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Turpentine LVHC INC1 103 1 0.2 0.2 The LVHC collection suystem is operational with

gases being directed to a control device

The Continuous Digester

system startup is considered

complete when the digester

operations are stable, the No. 6

Digester chip feed is above 4.5

rpm, the No. 7 Digester chip

feed is above 6 rpm, and the

HVLC and LVHC NCGs are beign

incinerated.

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC1 111 1 1.5 1.5 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless thesystem is down or locked and tagged out. LVHC

NCG process source or collection system may bevented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSMplan for collection systems and control devices.

The Continuous Digester

system startup is consideredcomplete when target flow rate

achieved.

3.5 3.5 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condenstates.

Kraft Pulping: Turpentine LVHC INC1 116 1 Hot Startup:

0.5‐1 hr

Cold Startup:

4‐6 hrs

6 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating a

startup on the Kraft Digester Turpentine

Recovery System(s).

Standard operating conditionsare met and digesters are

gassing off routinely

Hot

Shutdown:

0.5‐1 hr

Cold

Shutdown: 4‐

8 hrs

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC1 116 1 Hot Startup:

0.5‐1 hr

Cold Startup:

4‐6 hrs

6 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating a

startup on the Kraft Digester Turpentine

Recovery System(s).

Standard operating conditionsare met and digesters are

gassing off routinely

Hot

Shutdown:

0.5‐1 hr

Cold

Shutdown: 4‐

8 hrs

8 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position until completingshutdown of the Evaporator System(s).

Kraft Pulping: Turpentine LVHC INC1 116 5 Hot Startup:

0.5‐1 hr

Cold Startup:

6 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating a

Standard operating conditionsare met and digesters are

gassing off routinely

Hot

Shutdown:

0.5‐1 hr

8 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position until completing

4‐6 hrs startup on the Kraft Digester Turpentine

Recovery System(s).

Cold

Shutdown: 4‐

8 hrs

shutdown of the Kraft Digester TurpentineRecovery System(s).

Kraft Pulping: Turpentine LVHC INC1 116 1 NA Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating astartup on the Kraft Digester Turpentine

Recovery System(s).

Standard operating conditionsare met and digesters are

gassing off routinely

NA Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC1 139 1 0.1 0.1 LVHC in service. Digester relief/blow valves

open

0.1 0.1 LVHC in service. 

Kraft Pulping: Turpentine LVHC INC1 142 2 1 1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Digester systems are fully

operational, condensate and

vent gas systems are fully

operational, digester is filled

and capped, and cooking has

commenced.

3.5 3.5 Continue routing emissions to G0914 collection

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC1 142 1 1 1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stop feeding condensates to

the tank

1 1 Continue routing emissions to G0914 collection

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC1 142 1 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

NA NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Turpentine LVHC INC1 162 2 1 1 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

1 1 Continuing routing emissions to the LVHC

Collection System and Control Device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Turpentine LVHC INC1 162 1 1 1 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditions

are met and digesters are

gassing off routinely

3 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC1 162 1 1‐2 2 There are no HAP emissions as a result of starting

up the collection system. HAPS are onlygenerated by the emission units and not thecollection system. The collection system andcontrol device must be operational prior to

startup of an emission source

NA‐Not an emission unit 1 1 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system an

control device must be operational while one o

more emission units are running.

Kraft Pulping: Turpentine LVHC INC1 163 2 16 16 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

6 6 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC1 163 2 24 24 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

6 6 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC1 165 3 Hot Startup:

0.5‐1 hours

Cold Startup:

1‐3 hours

3 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditions

are met and digesters are

gassing off routinely

Hot

Shutdown:

0.5‐1 hours

Cold

Shutdown: 1‐

3 hours

3 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC1 166 1 Hot Startup:

0.5‐1 Hours

Cold Startup:

4‐6 Hours

6 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditions

are met and digesters are

gassing off routinely

Hot

Shutdown:

0.5‐1 Hours

Cold

Shutdown: 4‐

8 Hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC1 169 1 Hot ‐ 0.5‐2;

Cold 6‐8

8 BEFORE startup of the Turpentine Recovery

System (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.

When the reclaimed steam isvalved in to the chip bin(s) and

steaming vessel(s), the normalextraction flow(s) has been

established, and the blow

Hot ‐ 0.5‐1;

Cold 4‐8

8 Continuing routing emissions to the LVHC

Collection System and Control Device

valves have been opened.

Kraft Pulping: Turpentine LVHC INC1 169 1 Hot ‐ 0.5‐2;

Cold 6‐8

8 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases: and (2) Ensureequipment is properly valved to the LVHC

Collection System.

When the reclaimed steam is

valved in to the chip bin(s) and

steaming vessel(s), the normalextraction flow(s) has been

established, and the blow

valves have been opened.

Hot ‐ 0.5‐1;

Cold 4‐8

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC1 172 1 Hot Startup:

0.5‐1 hrs

Cold Startup:

4‐6 hrs

6 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System

Standard operating conditions

are met and digesters are

gassing off routinely

Hot

Shutdown:

0.5‐1 hrs

Cold

Shutdown: 4‐

8 hrs

8 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC1 172 1 Hot Startup:

0.5‐1 hrs

Cold Startup:

4‐6 hrs

6 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

Hot

Shutdown:

0.5‐1 hrs

Cold

Shutdown: 4‐

8 hrs

8 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC1 172 1 Hot Startup:

3‐4 hrs

Cold Startup:

3‐4 hrs

4 BEFORE startup of the Digester Equipment

System (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the Digester

Equipment System in such a way as to prevent

over pressurization of system upon startup.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

Hot

Shutdown: 3‐

4 hrs

Cold

Shutdown: 3‐

4 hrs

4 * Continuing routing emissions to the LVHC

Collection System and Control Device

* Operate the Digester Equipment System in

such a way as to prevent over pressurization of

system during shutdown.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Turpentine LVHC INC1 176 1 3 3 Maintain water to condensers Any 9# digester switches are

active

Three hours

from the last

digester blow

3 Shut down the pulp mill before incineration po

shuts down.

Kraft Pulping: Turpentine LVHC INC1 179 1 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

< 0.083 0.083 continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC1 179 1 NA emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digested pulp is blown fromdigester and meets QA/QC

specifications

NA continue routing emissions to LVHC collection

system and primary or backup control system

Kraft Pulping: Turpentine LVHC INC1 184 1 0.5 0.5 Continue routing emissions to LVHC collection

system.

When liquor flow stabilizes. 0.5 0.5 Continue routing emissions to LVHC collection

system.

Kraft Pulping: Turpentine LVHC INC1 186 1 2 2 2 2

Kraft Pulping: Turpentine LVHC INC1 189 1 0 0 NA NA NA NA 

Kraft Pulping: Turpentine LVHC INC1 189 1 0.5 0.5 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. After startup was complete, I insured

that all NCG vent gases and regulated pulping

condensates were being collected. Verified that

Turpentine Recovery System was ready to accept

digester relief gases before diverting the relief

gases. Started up the Turpentine Recovery

System following the standard mill operating

procedures.

Per the SSM Plan, collection of

HVLC/LVHC System. Full

Turpentine rate is obtained.

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System. Shutdown the

Pine Digesters before shutting down or venting

gases and pulping condensates from thecollection systems. The operator should insure

that vent gases and pulping condensates are n

longer being generated before shutting downthe LVHC Gas Collection System or diverting

digester vent gases to atmosphere.

Kraft Pulping: Turpentine LVHC INC1 190 2 1 1 Verify that all NCG gases are collected by the

appropriate collection system and sent to the

appropriate control device.

Beginning of first digester cook. 0.5 0.5 Continue to operate the NCG collection system

Kraft Pulping: Turpentine LVHC INC1 190 1 1 1 Verify that all NCG gases are collected by the

appropriate collection system and sent to the

appropriate control device. Verify that the

digester system is operating in normal operating

temperatures, pressures, and flows.

After completing 4 digesterblows (blow 4 digesterssequentially)

1 1 Continue to operate the NCG collection system

Kraft Pulping: Turpentine LVHC INC1 242 1 0.25 0.25 When flash steam flow starts 0.25 0.25 continue routing emissions to LVHC‐ AA‐026

collection system and primary or backup contro

system

Kraft Pulping: Turpentine LVHC INC1 531 2 Hot Startup:

0.5‐1 hour

Cold Startup:

4‐6 hours

6 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditions

are met and digesters are

gassing off routinely

Hot

Shutdown:

0.5‐1 hours

Cold

Shutdown: 4‐

8 hours

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC INC1 613 1 2 2 Per the SSM Plan, Startup following PSM

procedure. Verify that turpentine system is

ready to accept blow tank tgases before sending

gases from either blow tank to the turpentine

recovery system. Send the digester relief gases

from flow tanks to the turpentine recovery

system. Send the digester relief gases from flow

tanks to the turpentine recovery system. Insure

all NCG vent gases and pulping condensates arecollected by the appropriate collection systems

and sent to the appropriate control device.

Per the SSM Plan:**Required

cooling water pumps arerunning as specified in the mill's

PSM plan; verify that thecondensate pump is running as

specified; NCG vent valve will

divert vent gases to NCG/SOG

Gas collection system and not

to the atmosphere

2 2 Per the SSM Plan:**Shutdown per PSM

procedure. Shutdown the Turpentine Recovery

system before shutting down or diverting the

NCG vent gases and condensates form the

colelction system. By visual obervation, theoperator should insure that vent gases and

Kraft Pulping: Turpentine LVHC INC1 617 1 4 hours 4 start up LVHC‐1 collection system prior to

emission unit start‐up

when accumulator

temperatures and system

pressures meet normal

operating rate, andcondensates are collected

4 hours 4 continue routing emissions to LVHC‐1 collectio

system

Kraft Pulping: Turpentine LVHC INC1/SCBR 136 4 NA NA NA NA NA 

Kraft Pulping: Turpentine LVHC SCBR/INC_BOIL 131 1 10 10 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Kamyr digester system running 10 10 continue routing emissions to LV01 collection

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Turpentine LVHC SCBR/INC_BOIL 131 5 10 10 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

normal operation of batch

digesters

10 10 continue routing emissions to LV01 collection

system and primary or backup control system

Kraft Pulping: Turpentine LVHC SCBR/INC_LK 226 2 0.66 0.66 ensure primary and backup control are available #1 or #2 Kraft digesters are in

operation and turpentinedecanter underflow pump is on

0.25 0.25 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Turpentine LVHC SCBR/INC_LK 226 1 1.2 1.2 ensure primary and backup control are available #1 or #2 Kraft digesters are in

operation and turpentinedecanter underflow pump is on

0.25 0.25 continue routing emissions to collection system

and primary or backup control system

Kraft Pulping: Turpentine LVHC SCBR/INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

TRS Stripper condensate flow is

stable and within 100 gpm ofset point. TRS Stripper

condensate outlet temperature

is at or able 210F. Terpentinecondensate and gas

temperatures are controlling at

set point. Decanter underflow

standpipe level is controlling

within 30% of set point.

Decanter underflowconductivitity is adequate to be

collected to Fiber filter or Foul

Condensate Tank

continue routing emissions to LVHC‐1 collectiosystem and primary or backup control system

Kraft Pulping: Turpentine LVHC SCBR/INC_LK/SCBR 167 5 0.5 ‐ 6

Routine/Ann

ual

6 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.

Standard operating conditionsare met and digesters are

gassing off routinely

0.5 ‐ 8

Routine/Ann

ual

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC SCBR/INC_LK/SCBR 167 1 0.5 ‐ 6

Routine/Ann

ual

6 Ensure the condensate collection system and

control device are in operation and all system

values are in the appropriate position before

initiating startup on the digesters or turpentinesystem

Standard operating conditionsare met and digesters are

gassing off routinely

0.5 ‐ 8

Routine/Ann

ual

8 Continuing routing emissions to the LVHC

Collection System and Control Device

Kraft Pulping: Turpentine LVHC SCBR/INC_TO/SCBR 130 8 3 ‐ 4 4 Emission unit and control device operates in Digester is blowing stock, stock 3‐4 4 

compliance with NSPS and NESHAP parameterlimits during emission unit startup ‐ BEFORE

startup of the Digester Equipment System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment is

properly valved to the LVHC Collection System

is flowing across brown stockwashers, washed pulp is flowing

to high density storage.

1. Continuing routing emissions to the LVHCCollection System and Control Device

2. Operate the Digester Equipment System in

such a way as to prevent over pressurization of

system during shutdown.

Kraft Pulping: Turpentine LVHC SCBR/INC_TO/SCBR 198 1 0.033 0.033 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Turpentine Condenser and Gas

Cooler water supply operating

and water temperature within

normal operating range, no

alarms or rupture disk failures

8 8 continue routing emissions to LVHC‐1 and HVLC

1 collection system and primary or backup

control system

Kraft Pulping: Turpentine LVHC SCBR/INC_TO/SCBR 525 2 0 0 NA NA 0 0 NA 

Kraft Pulping: Washing

Kraft Pulping: Washing COND/INC_BOIL 112 2 6 6 Collection and control systems operating before

start‐up

When liquor and gasses exit

tank

6 6 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing COND/INC_BOIL 112 1 6 6 Collection and control systems operating before

start‐up

When pulp exits deckers 6 6 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing COND/INC_BOIL 112 1 6 6 Collection and control systems operating before

start‐up

When pulp exits press 6 6 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing COND/INC_BOIL 112 1 6 6 Collection and control systems operating before

start‐up

When pulp exits tank 6 6 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing INC 112 1 6 6

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Washing INC 147 2 0.25 0.25 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends 15 minutes after

startup of the knotter feed

pump

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: Washing INC 148 1 1 1 Incineration source is online before startup of

source

When pulp is on washing

system

1 1 Incineration source is still online until source is

shutdown

Kraft Pulping: Washing INC 148 1 1 1 Incineration source is online before startup of

source

When pulp is on washing

system

1 1 Incineration source is still online until source is

shutdown

Kraft Pulping: Washing INC (see note) 182 1 10 10 Verify cooling water system is operational,

operate NCG and foul condensate systems

properly

10 10 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Washing INC (see note) 182 1 30 30 Operate NCG and foul condensate systems

properly

30 30 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Washing INC_BOIL 120 3 1 1 Before start‐up, the HVLC system is available to

accept emissions

The end of startup is marked by

stock to the high density tanks,filtrate tank levels are stable,shower water is stable, washer

drum speeds are stable, vat

levels are stable, all screendifferential pressures are

stable, refiners are stable and

stock flow is stable

1 1 During the planned shutdown, the HVLC

collection system is in operation. The same

measures are used during shutdown as during

normal operation

Kraft Pulping: Washing INC_BOIL 131 9 10 10 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Fiberlizer on and stock pump on

and recirculation valve closed

10 10 continue routing emissions to HV01 collection

system and primary or backup control system

Kraft Pulping: Washing INC_BOIL 131 3 10 10 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Fiberlizers and stock pump on 10 10 continue routing emissions to HV01 collection

system and primary or backup control system

Kraft Pulping: Washing INC_BOIL 143 6 Hot 0.5 ‐ 1.0

hours Cold:

1.0 ‐2.0

hours

2 (1) Confirm HVLC System and Treatment Units

are operating and determine if HVLC gases may

be routed to the NCG TO; (2) Confirm HVLCCollection System fan to the NCG TO isoperational

Steady state operations, target

conductivity, and target stockflow

Hot or Cold:

0.5 ‐ 1.0

hours

1 Maintain HVLC Collection and Treatment Syste

until after the No. 4 Chemiwasher is shut down

Kraft Pulping: Washing INC_BOIL 143 3 Hot or Cold:

0.33 ‐ 1.0

Hours

1 (1) Confirm HVLC System and Treatment Units

are operating and determine if HVLC gases may

be routed to the NCG TO (2) Confirm HVLC

Steady state operations, target

conductivity, and target stockflow

Hot or Cold:

0.33 ‐ 1.0

hours

1 Maintain HVLC Collection and Treatment Syste

until after the No. 4 Chemiwasher is shut down

Collection System fan to the NCG TO isoperational

Kraft Pulping: Washing INC_BOIL 143 1 Hot or Cold:

0.33 ‐ 1.0

Hours

1 (1) Confirm HVLC System and Treatment Units

are operating and determine if HVLC gases may

be routed to the NCG TO; (2) Confirm HVLCCollection System fan to the NCG TO isoperational

Steady state operations, target

conductivity, and target stockflow

Hot or Cold:

0.33 ‐ 1.0

hours

1 Maintain HVLC Collection and Treatment Syste

until after the No. 4 Chemiwasher is shut down

Kraft Pulping: Washing INC_BOIL 145 2 1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Wash flow is started 0.3 0.3 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing INC_BOIL 149 1 0 0 route emissions to HVLC collection system and

primary or backup control system

Pulp flow to brown stock blend

chest

0 0 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Washing INC_BOIL 152 1 3 3 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

digester operates above 8rpm

for 2 hours

1 1 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing INC_BOIL 154 1 0.25 0.25 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow 0.25 0.25 Continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Washing INC_BOIL 154 1 0.33 0.33 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Pulp is discharging from washer 2 2 Continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Washing INC_BOIL 167 2 3 ‐ 16

Routine/Ann

ual

16  ‐ BEFORE startup: 1) Confirm the HVLC System

control device is ready to accept gases and 2)Ensure equipment is properly valved to the HVLC

Collection System

Stock flow has reached anappropriate level

2 ‐ 8

Routine/Ann

ual

8 Continuing routing emissions to the HVLC

Collection System and Control Device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Washing INC_BOIL 167 2 3 ‐ 16

Routine/Ann

ual

16 BEFORE startup of the Digester Equipment

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensureequipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Established blow flow, stock is

going across washers, pulp

going to high density storage.

2 ‐ 8

Routine/Ann

ual

8 (1) Continuing routing emissions to the LVHC

System and Control Device (2) Operate the

Digester System in such a way as to prevent ov

pressurization of system during shutdown.

Kraft Pulping: Washing INC_BOIL 167 4 3 ‐ 16

Routine/Ann

ual

16 BEFORE startup: (1) Confirm the HVLC System

control device is ready to accept gases; and 2)

Ensure equipment is properly valved to the HVLC

Collection System.

Stock flow has reached an

appropriate level

2 ‐ 8

Routine/Ann

ual

8 Continuing routing emissions to the HVLC

Collection System and Control Device

Kraft Pulping: Washing INC_BOIL 173 1 3 ‐ 12 12 BEFORE startup of the Digester Equipment

System:1) Confirm the LVHC System control device is

ready to accept gases and 2) Ensure equipment

is properly valved to the LVHC Collection

System**Operate the Digester Equipment

System in such a way as to prevent over

pressurization of system upon startup.

Established blow flow, stock is

going across washers and

deckers, pulp going to high

density storage.

4 ‐ 12 12

1. Continuing routing emissions to the LVHCCollection System and Control Device

2. Operate the Digester Equipment System in

such a way as to prevent over pressurization of

system during shutdown.

Kraft Pulping: Washing INC_BOIL 173 1 3 ‐ 12 12 BEFORE startup of the Digester Equipment

System: 1) Confirm the LVHC System controldevice is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.**Operate the DigesterEquipment System in such a way as to prevent

over pressurization of system upon startup.

Established blow flow, stock is

going across washers and

deckers, pulp going to high

density storage.

4 ‐ 12 12

1. Continuing routing emissions to the LVHCCollection System and Control Device

2. Operate the Digester Equipment System in

such a way as to prevent over pressurization of

system during shutdown.

Kraft Pulping: Washing INC_BOIL 177 1 1 1 When the oxygen reactor

reaches normal operating rate

and post oxygen washers are

operating at normal stock flow

and normal shower flow.

1 1 continue routing emissions to EU1151 or EU080

Kraft Pulping: Washing INC_BOIL 177 2 1 1 continue routing emissions to EU1151 or EU0804 When Brown Stock Washers

have reached normal operating

rate and targeted shower flows.

1 1 continue routing emissions to EU1151 or EU080

Kraft Pulping: Washing INC_BOIL 205 1 0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Completion of 30 minutes of

stock flow to knotter systemand 30 minutes of operation of

screen feed pump

0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Washing INC_BOIL 207 1 0.33 0.33 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

liquor is coming from the

washers to the filtrate tanks

2 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Washing INC_BOIL 207 1 0.50 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

all valves lined up, pumps

running and stock across No. 3washer

0.33 0.33 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Washing INC_BOIL 525 2 0 0 NA NA 0 0 NA 

Kraft Pulping: Washing INC_BOIL 525 2 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

gases introduced into the boiler 1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Washing INC_BOIL1 600 1 Hot Startup:

0.5‐4 hours;

Cold Startup:

0.5‐4 hours

4 BEFORE startup of the Brown stock washing

system: (1) Confirm the HVLC System control

device is ready to accept gases (2) Ensureequipment is properly valved to the HVLC

Collection System**Operate the Brown stock

washing equipment System in such a way as to

prevent over pressurization of system upon

startup.

Hot

Shutdown:

0.5‐4 hours;

Cold

Shutdown:

0.5‐4 hours

4 (1) Continuing routing emissions to the HVLC

System and Control Device (2) Operate the BS

washing in such a way as to prevent over

pressurization of system during shutdown.

Kraft Pulping: Washing INC_BOIL1 600 2 Hot Startup:

0.5‐4 hours;

Cold Startup:

0.5‐4 hours

4 BEFORE startup of the Brown stock washing

system: (1) Confirm the HVLC System control

device is ready to accept gases (2) Ensureequipment is properly valved to the HVLC

Collection System.**Operate the Brown stockwashing equipment System in such a way as to

prevent over pressurization of system upon

startup.

Hot

Shutdown:

0.5‐4 hours;

Cold

Shutdown:

0.5‐4 hours

4 (1) Continuing routing emissions to the HVLC

System and Control Device (2) Operate the BS

washing in such a way as to prevent over

pressurization of system during shutdown.

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Washing INC_BOIL1 600 14 Hot Startup:

0.5‐4 hours;

Cold Startup:

0.5‐4 hours

4 BEFORE startup of the Brown stock washing

system: (1) Confirm the HVLC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the HVLC

Collection System.**Operate the Brown stock

washing equipment System in such a way to

prevent over pressurization of system upon

startup.

Hot

Shutdown:

0.5‐4 hours;

Cold

Shutdown:

0.5‐4 hours

4 (1) Continuing routing emissions to the HVLC

System and Control Device (2) Operate the BS

washing in such a way as to prevent over

pressurization of system during shutdown.

Kraft Pulping: Washing INC_LK 178 1 NA NA NA NA NA 

Kraft Pulping: Washing INC_LK 197 3 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When a good mat is established

on the washer wire

0.5 0.5 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Kraft Pulping: Washing INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

The F‐Washer lean gases are

being collected.

shut down the HVLC Gas system sources before

venting the lean gases

Kraft Pulping: Washing INC_LK/SCBR 121 1 0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Operating parameters are inline with the values shown in

the SSM plan

0.5 0.5 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing INC_LK/SCBR 121 2 NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

NA NA continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing INC_LK/SCBR 137 1 1 1 FOLLOW SSM PLAN Screen Pump Load > 20% for 2

hours

12 12 FOLLOW SSM PLAN 

Kraft Pulping: Washing INC_RF 115 2 instantaneou

s

0 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Diffuser online and processing

stock

instantaneou

s

0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Washing INC_RF 119 3 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When No.21 Rec. Blr. is firing

black liquor, is stable and safety

interlocks are satisfied.

4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shut down

Kraft Pulping: Washing INC_RF 155 2 1 1 emission unit and control device operates in when stock flow to knotters > 0.25 0.25 NA ‐ applicable emission and parameter limits 

compliance with NSPS and NESHAP parameterlimits during emission unit startup

500 gpm for 1 hr not expected to be exceeded during shutdown 

Kraft Pulping: Washing INC_RF 182 1 10 10 Verify cooling water system is operational,

operate NCG and foul condensate systems

properly

10 10 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Washing INC_RF 182 2 30 30 Operate NCG and foul condensate systems

properly

30 30 Shutdown NCG and foul condensate systems

only after source has been shutdown

Kraft Pulping: Washing INC_RF 198 1 0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

stock flow stable, pumpsrunning, no alarms, no rupture

disk failures

8 8 continue routing emissions to LVHC‐1 and HVLC

1 collection system and primary or backup

control system

Kraft Pulping: Washing INC_RF 202 1 See HVLC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup‐ with venting allowances for HVLC and LVHCsources

See HVLC System ‐ not further

defined

See HVLC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

with venting allowances for HVLC and LVHCsources

Kraft Pulping: Washing INC_RF 243 2 0 0 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Brownstock flow to equipment 0 0 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Washing INC_RF 243 1 0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Brownstock flow to washers 0 0 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Washing INC_RF 615 4 1 1 Unit is only started if the associated collection

system is operating

Stock flow is established

through entire washer line

0.5 0.5 Associated collection system is operated throu

duration of shutdown

Kraft Pulping: Washing INC_RF 208228535 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Completion of 4 hours of stock

flow to knotter system

1 1 continue routing emissions to HVLC‐7 collectio

system and primary control device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Washing INC_RTO/SCBR 610 2 1 1 emission unit and control device operates in

compliance with NESHAP parameter limits during

emission unit startup

When the A knotter screen flow

is greater than 100 gpm for 10

minutes.

1.5 1.5 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing INC_TO 146 4 0.25 0.25 The unit is not allowed to begin operation until

the NCG collection system and combustion

device are in service.

Start‐up ends 15 minutes after

startup of the knotter feedpump

0.1 0.1 NCG system and combustion device remain in

service until system is completely off‐line

Kraft Pulping: Washing INC1 100 6 ~4 hrs 4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating a

startup on the digester system.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing.

~4 hrs 4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position until completing the

shutdown of the digester system.

Kraft Pulping: Washing INC1 102 1 1 1 When NCG‐TO is available and able to maintain

minimum temperature limit for firing HVLC, the

HVLC NCG system is collecting and treating gases

prior to startup of sources.

Pulp flow from PDW 1 1 Whenever possible, HVLC NCG system is

collecting and treating vent gases during

shutdown of sources.

Kraft Pulping: Washing INC1 102 1 See PDW See PDW See PDW See PDW See PDW 

Kraft Pulping: Washing INC1 111 4 0.5 0.5 HVLC NCG system is collecting gases prior to

startup of sources. Source vent and/or collection

valves positions are verified during lock‐out/tag‐

out process.

The Washing and Screeningsystem is considered started up

when target flow rate achieved.

0.5 0.5 HVLC NCG system is collecting gases during

shutdown of sources.

Kraft Pulping: Washing INC1 111 1 1.285974499

1

1.285974499 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless the

system is down or locked and tagged out. LVHC

NCG process source or collection system may bevented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSMplan for collection systems and control devices.

The Continuous Digester

system startup is consideredcomplete target flow rateachieved.

0.366120218

58

0.366120219 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condenstates.

Kraft Pulping: Washing INC1 111 1 1.300318761

4

1.300318761 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless thesystem is down or locked and tagged out. LVHC

NCG process source or collection system may be

vented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSMplan for collection systems and control devices.

The Continuous Digester

system startup is considered

complete whentarget flow rateachieved.

0.298497267

76

0.298497268 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condenstates.

Kraft Pulping: Washing INC1 116 1 Hot Startup:

3‐4 hrs

Cold Startup:

3‐4 hrs

4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating of

the Evaporator System(s).

Blow line flow and extraction

flow standard operating

condition are met.

Hot

Shutdown: 3‐

4 hrs

Cold

Shutdown: 3‐

4 hrs

4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position until completingshutdown of the CSSC Pulp Washing System(s).

Kraft Pulping: Washing INC1 133 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

all stock transfer pumps have

started up and pumps stock

0.5 0.5 continue routing emissions to HVLC collection

and control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Washing INC1 135 1 1 1 Pulp Washing System: The HVLC is operating

prior to startup of the washer. The brownstock

washer doors are closed prior to using recycled

condensate.

Pulp Washing System: The flow

or recycled condensate is

stable. Pulp is flowing steady

from the atmospheric dumptank. Stock flow from thewasher to high density storate

is stable.

1 1 Pulp Washing System: HVLC system continues t

operate. Keep brownstack washer doors closed

and vented to HVLC while using recycled

condensate.

Kraft Pulping: Washing INC1 150 1 0.5 0.5 continue routing emissions to HVLC‐1 collection

system and primary or backup control system

All four washer level controls in"Auto"

0.5 0.5 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing INC1 150 1 2 2 continue routing emissions to HVLC‐1 collection

system and primary or backup control system

Startup complete after 4 blows

and knotter supply pump is

running

1 1 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Kraft Pulping: Washing INC1 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

A negative draft has been

established for the foul

condensate filter and F‐

secondary knotter Lean (HVLC)Gas Vent lines.

shut down the HVLC Gas system sources before

venting the lean gases

Kraft Pulping: Washing INC1 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

The G‐Washer lean gases are

boing collected.

shut down the HVLC Gas system sources before

venting the lean gases

Kraft Pulping: Washing INC1 162 2 1 1 BEFORE startup of the Digester System: (1)

Confirm the LVHC System control device is ready

to accept gases and (2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester System in such a

way as to prevent over pressurization of systemupon startup such as: (1) Do not blow a digester

or cook a digester until all pieces of the blow

heat system are running and within acceptable

control limits, and (2) Ensure critical pumps on

the blow heat system are running prior to

blowing a digester. If blow heat pressure is too

high and the vent has opened, do not attempt to

blow another digester until the problem can be

found and repaired.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

1 1 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way a

to prevent over pressurization of system during

shutdown (3)During emergency shutdowns, alldigesters should be put on hold to suspend the

cooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Kraft Pulping: Washing INC1 163 1 2 2 BEFORE startup of the Washer System: (1)

Confirm the HVLC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the HVLC Collection System.

Digester Cooking and Blowing

has commenced

2 2 Continue routing emissions to the HVLC

Collection System and Control device during

shutdown

Kraft Pulping: Washing INC1 163 20 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Digester Cooking and Blowing

has commenced

2 2 Continue routing emissions to the HVLC

Collection System and Control device during

shutdown

Kraft Pulping: Washing INC1 165 7 Hot Startup:

0.5‐2 hours

Cold Startup:

1‐3 hours

3 BEFORE startup: (1) Confirm the HVLC System

control device is ready to accept gases and (2)Ensure equipment is properly valved to the HVLC

Collection System.

If A‐line washers stock flow has

reached the appropriate level.

Hot

Shutdown:

0.5‐2 hours

Cold

Shutdown: 1‐

3 hours

3 Continuing routing emissions to the HVLC

Collection System and Control Device

Kraft Pulping: Washing INC1 165 7 Hot Startup:

0.5‐2 hours

Cold Startup:

1‐3 hours

3 BEFORE startup: (1) Confirm the HVLC System

control device is ready to accept gases and (2)Ensure equipment is properly valved to the HVLC

Collection System.

If B‐line washers stock flow hasreached the appropriate level.

Hot

Shutdown:

0.5‐2 hours

Cold

Shutdown: 1‐

3 hours

3 Continuing routing emissions to the HVLC

Collection System and Control Device

Kraft Pulping: Washing INC1 169 5 Hot ‐ 1‐4;

Cold 1‐4

4 BEFORE startup of the Washer System: (1)

Confirm the HVLC System control device is ready

to accept gases; and (2) Ensure equipment is

properly valved to the HVLC Collection System.

When a steady pulp blow flow

has been established.

Hot ‐ 2‐4;

Cold 2‐4

4 Continuing routing emissions to the HVLC Syste

and Control Device

Kraft Pulping: Washing INC1 176 1 Will not start up the washers until the HVLV

system is on line

pulp is going to high density

towers

1 1 Utilize HVLC system until non‐emit state is

reached

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Washing INC1 179 2 0.25‐1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Washed stock off of final stage

washer.

0.5‐1 1 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Washing INC1 179 2 1‐2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Washed stock off of final stage

washer.

1‐2 2 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Washing INC1 181 2 0.2 0.2 emissions collected and routed to a control

device during startup (except following cold

outage)

Sheet on 2nd stage and hoods

closed

0.2 0.2 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: Washing INC1 181 1 0.2 0.2 emissions collected and routed to a control

device during startup (except following cold

outage)

Sheet on Decker 0.2 0.2 continue routing emissions to collection system

and control device until unit down

Kraft Pulping: Washing INC1 184 3 0.5 0.5 Continue routing emissions to HVLC collection

system.

When shower flows, vat levelsand drum speeds stabilize.

0.5 0.5 Continue routing emissions to HVLC collection

system.

Kraft Pulping: Washing INC1 185 1 3.5 3.5 Unit is only started if the associated collection

system is operating.

Stock flow has been established

from #57 Tank thru the entireKBS Washers Line and is being

pumped from the DD Washer

discharge chute into #54 or #55

tanks.

3.5 3.5 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

Kraft Pulping: Washing INC1 185 4 Integrated

with KBS

Washer Line

Startup ‐ 3.5

hours

3.5 Unit is only started if the associated collection

system is operating.

Integrated with KBS Washer

Line Startup ‐ See Cell DS33.

Integrated

with KBS

Washer Line

Shutdown ‐ 

3.5 hours

3.5 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

Kraft Pulping: Washing INC1 189 2 0.5 0.5 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting.

Per the SSM Plan, collection of

HVLC/LVHC System

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System

Kraft Pulping: Washing INC1 243 1 0 0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Brownstock flow to washers 0 0 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Washing INC1 340 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When washed pulp is produced 0.5 0.5 continue routing emissions to HVLC collection

system and primary or backup control system

Kraft Pulping: Washing INC1 531 2 0.5‐4 4 BEFORE startup( 1) Confirm the HVLC System

control device is ready to accept gases and (2)Ensure equipment is properly valved to the HVLC

Collection System.

Standard operating conditions

are met

0.5‐4 4 Continuing routing emissions to the HVLC Syste

and Control Device

Kraft Pulping: Washing INC1 617 1 0.5 hours 0.5 start up HVLC‐1 collection system prior to

emission unit start‐up, when possible

when pulp flow is established to

all 3 wash presses, and feed

tank levels are >25%

0.5 hours 0.5 continue routing emissions to HVLC‐1 collectio

system

Kraft Pulping: Washing INC1/SCBR 136 1 NA NA NA NA NA 

Kraft Pulping: Washing SCBR 132 2 <1 hour 1 None Simultaneous <1 hour 1 None 

Kraft Pulping: Washing SCBR 140 1 HVLC System is operating Normally, fan is on and

the scrubber has the minimum gpm and thestack temperature is below the minimum. HVLC

system is not to be shutdown until emission units

are shutdown.

The knotter stock pum is on,

which indicates pulp is going to

the Brownstock washers.

HVLC System is operating Normally, fan is on an

the scrubber has the minimum gp and the stactemperature is below the minimum until allemission units are shut down.

Kraft Pulping: Washing SCBR 157 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

When kamyr and M&D blow

tank stock pumps are running

2 2 continue routing emissions to HVLC collection

system

Kraft Pulping: Washing SCBR 186 1 2 2 2 2

Kraft Pulping: Washing SCBR 240 1 16 16 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

When pulp flow to the bleach

plant is obtained.

4 4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Washing SCBR 240 1 4 4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

When pulp flow to the bleach

plant is obtained.

4 4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Kraft Pulping: Washing SCBR 240 1 6 6 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

When pulp flow to the bleach

plant is obtained.

6 6 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Kraft Pulping: Washing SCBR 615 1 1 1 Unit is only started if the associated collection

system is operating

Stock flow is established

through entire bleach line

0.5 0.5 Associated collection system is operated throu

duration of shutdown

Kraft Pulping: Washing SCBR/INC_BOIL 131 1 10 10 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Fiberlizer on and stock pump on

and recirculation valve closed

10 10 continue routing emissions to HV01 collection

system and primary or backup control system

Kraft Pulping: Washing SCBR1 186 1 0 0 0 0

NSSC Pulping

NSSC Pulping INC1 156 1 2.5 2.5 follow SSM manual procedures Chemi‐washer vent valve and

blow line refiner drain valve is

closed

1.5 1.5 follow SSM manual procedures 

NSSC Pulping INC1 190 2 2 2 Verify that all NCG gases are collected by the

appropriate collection system and sent to the

appropriate control device. Verify that the

digester system is operating in normal operating

temperatures, pressures, and flows.

Stock starts flowing to the NSSC

blow tank

1 1 Continue to operate the NCG collection system

Pulp Storage

Pulp Storage COND 409 1 0.5 0.5 continue routing to control system Startup ends when stock enters

steam tubes

Immediate 0 continue routing to control system 

Pulp Storage INC 175 1 4‐6 hr 6 BEFORE startup of the System: (1) Confirm the

LVHC System control device is ready to accept

gases and (2) Ensure equipment is properly

valved to the LVHC Collection System

Stable liquor sulfidity 0.5 hr 0.5 Continuing routing emissions to the LVHC Syste

and Control Device until all sources systems are

shut down

Pulp Storage INC_BOIL 154 1 0.25 0.25 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow 0.25 0.25 Continue routing emissions to HVLC collection

system and primary or backup control system

Pulp Storage INC_BOIL 154 2 0.5 0.5 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow 0.5 0.5 Continue routing emissions to HVLC collection

system and primary or backup control system

Pulp Storage INC_BOIL 525 1 0 0 NA NA 0 0 NA 

Pulp Storage INC_LK/SCBR 137 1 0.25 0.25 FOLLOW SSM PLAN All HVLC sources are being

burned in a lime kiln

12 12 FOLLOW SSM PLAN 

Pulp Storage INC1 100 1 ~4 hrs 4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

h b f

Blow heat system standard

operating conditions are met

d d l

~4 hrs 4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

h l l h

in the appropriate position before initiating a

startup on the digester system.

and digesters are routinely

blowing.

in the appropriate position until completing the

shutdown of the digester system.

Pulp Storage INC1 111 1 0.5 0.5 HVLC NCG system is collecting gases prior to

startup of sources. Source vent and/or collection

valves positions are verified during lock‐out/tag‐

out process.

The Oxygen Delignificationsystem is considered started up

when target flow rate achieved.

0.5 0.5 HVLC NCG system is collecting gases during

shutdown of sources.

Pulp Storage INC1 150 1 0.5 0.5 continue routing emissions to HVLC‐1 collection

system and primary or backup control system

All four washer level controls in"Auto"

0.5 0.5 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Pulp Storage INC1 181 1 NA

Pulp Storage INC1 185 2 Integrated

with KBS

Washer Line

Startup ‐ 3.5

hours

3.5 Unit is only started if the associated collection

system is operating.

Integrated with KBS WasherLine Startup ‐ See Cell DS33.

Integrated

with KBS

Washer Line

Shutdown ‐ 

3.5 hours

3.5 Unit is shutdown only if the associated collectio

system is operating in accordance with SOP

procedures.

Pulp Storage INC1/SCBR 136 3 NA NA NA NA NA Pulp Storage INC1_BOIL 149 1 0 0 Not empty 0 0 Pulp Storage SCBR 100 3 ~4 hrs 4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating astartup on the digester system.

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing.

~4 hrs 4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position until completing the

shutdown of the digester system.

Pulp Storage SCBR 610 2 1 1 NA 1 1 NA

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Pulp Storage SCBR1 106 3 12 12 Verify collection system is available and gases

are being sent to a control device prior to startup

of the operation.

Brightness and residual at D1

tower for 8 hours (final product

specifications are met).

2 2 Continue routing collected gases to the control

device.

Semichem Pulping

Semichem Pulping COND/SCBR1 244 1 Semichem Pulping COND/SCBR1 244 1 

Semichem Pulping INC_BOIL 128 2 0 0 none needed none 0 0 none 

Semichem Pulping INC_BOIL 187 1 0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

1 to 2 in pressure into control

device

0.25 0.25 Emission sources are shut down before control

device is shut down

Semichem Pulping INC_BOIL 187 4 0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

When pulp flow is obtained

from digester

0.25 0.25 Emission are routed to primary and backup

control devices during startup and shutdown

Semichem Pulping INC_BOIL 187 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

When tank level is steady 0.5 0.5 Emission are routed to primary and backup

control devices during startup and shutdown

Semichem Pulping INC_BOIL 187 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When tank level is steady 0.5 0.5 Emission are routed to primary and backup

control devices during startup and shutdown

Semichem Pulping INC_BOIL 187 2 2 2 When concentrated liquor exits

the evaporator

0.5 0.5 

Semichem Pulping INC_BOIL 187 1 NA When concentrated liquor exits

the evaporator

0.5 0.5 

Semichem Pulping INC_BOIL 245 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Evaporators running producing

46% liquor

4 4 continue routing emissions to HVLC collection

system and primary or backup control system

Semichem Pulping INC_BOIL 245 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

LVHC Operating = Vacuumgreater than ‐15 H2O AND

hotwell Vent closed ANDtemperature on Pressure Relief

OK AND rupture Disk OK and

4 4 continue routing emissions to HVHC collection

system and primary or backup control system

OK AND rupture Disk OK and 

Overflow Loop OK AND 15 min.

rolliing average of steam flow

to ejectors greater than 1000

lbs/hr AND surface condenser

vacuum greater than 22

Semichem Pulping INC_BOIL 245 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC Operating = Vacuum

greater than ‐15 H2O AND

hotwell Vent closed ANDtemperature on Pressure Relief

OK AND rupture Disk OK and

Overflow Loop OK AND 15 min.

rolliing average of steam flow

to ejectors greater than 1000

lbs/hr AND surface condenser

vacuum greater than 22

4 4 continue routing emissions to HVHC collection

system and primary or backup control system

Semichem Pulping INC_BOIL 245 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC Operating = Vacuumgreater than ‐15 H2O AND

hotwell Vent closed ANDtemperature on Pressure Relief

OK AND rupture Disk OK and

Overflow Loop OK AND 15 min.

rolliing average of steam flow

to ejectors greater than 1000

lbs/hr AND surface condenser

vacuum greater than 22

4 4 continue routing emissions to LVHC collection

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Semichem Pulping INC_BOIL 245 1 4.5 4.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Either (HVLC‐M&A Fan is ON

and vacuum > < ‐15") AND(HVLC‐M&A Vent bypass valve

at the No. 1 WFB (13‐ZsC‐

5620)is closed AND the boilerselect is #1WFB OR the No. 2

WFB (13‐ZsC‐5622) is CLOSEDAND the boiler select is #2WFB)AND condenser outlet temp is<150 degrees AND Vacuum <‐

15

1 1 continue routing emissions to HVHC collection

system and primary or backup control system

Semichem Pulping INC_BOIL 245 1 4.5 4.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

Either (HVLC‐M&A Fan is ON

and vacuum > < ‐15") AND(HVLC‐M&A Vent bypass valve

at the No. 1 WFB (13‐ZsC‐

5620)is closed AND the boilerselect is #1WFB OR the No. 2

WFB (13‐ZsC‐5622) is CLOSED

AND the boiler select is #2WFB)AND condenser outlet temp is<150 degrees AND Vacuum <‐

15

1 1 continue routing emissions to HVLC collection

system and primary or backup control system

Semichem Pulping INC_BOIL 245 1 4.5 4.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

LVHC‐M&A Vent bypass valves

(#1 OR #2) at the selected

combustion device (#1=13‐zso‐

5702 and 13‐zso‐5709 OR #2

=13‐zso‐5703 and 13‐zso‐5718)

are CLOSED and vacuum > < ‐

15" H2O AND the S1 Digester

Set OR the S2 Digester Set ORthe Evaporator system OR LHT

is operating

1 1 continue routing emissions to LVHC collection

system and primary or backup control system

Semichem Pulping INC_BOIL 245 2 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Either digester running and

sending weak liquor to the tank

1.5 1.5 continue routing emissions to HVLC collection

system and primary or backup control system

Semichem Pulping INC_BOIL 245 1 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

HVLC system is operating AND

the Chemi‐washer vent valve is

closed AND liquor flow to theimpregnator is greater than 30

gpm for 5 minutes AND the chip

screw feeder 20 rpm for 5

minutes AND blow tank stock

flow is greater than 1000 gpm

for 5 minutes AND KW on 1 of 2

deshive refiners is greater than

100 KW and variation is less

than +/‐400 KW for 15 minutes

2 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Semichem Pulping INC_BOIL 245 1 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC & HVLC control systems

are operating AND #1

DigesterBlow Heat Vent

Impregnator Valve is Closed

AND Digester M&A Vent Valve

is Closed AND NSSC liquor flowto Impregnator is greater than

30 gpm for 5 minutes AND the

chip screw feeder is greater

than 20 rpm for 5 minutes AND

KW on 1 of 3 Unimount refinersis greater htan 100 kw and

variation is less than +/‐ 400 KW

for 15 min.

1.5 1.5 continue routing emissions to HVLC collection

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Semichem Pulping INC_BOIL 245 3 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC & HVLC control systems

are operating AND #1

DigesterBlow Heat Vent

Impregnator Valve is Closed

AND Digester M&A Vent Valve

is Closed AND NSSC liquor flowto Impregnator is greater than

30 gpm for 5 minutes AND the

chip screw feeder is greater

than 20 rpm for 5 minutes AND

KW on 1 of 3 Unimount refinersis greater htan 100 kw and

variation is less than +/‐ 400 KW

for 15 min.

1.5 1.5 continue routing emissions to LVHC collection

system and primary or backup control system

Semichem Pulping INC_BOIL 245 5 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC & HVLC control systems

are operating AND #1

DigesterBlow Heat Vent

Impregnator Valve is Closed

AND Digester M&A Vent Valve

is Closed AND NSSC liquor flowto Impregnator is greater than

30 gpm for 5 minutes AND the

chip screw feeder is greater

than 20 rpm for 5 minutes AND

KW on 1 of 3 Unimount refinersis greater htan 100 kw and

variation is less than +/‐ 400 KW

for 15 min.

2 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Semichem Pulping INC_BOIL 245 1 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

LVHC & HVLC control systems

are operating AND DigesterBlow Heat Vent Impregnator

Valve is Closed AND Digester

M&A Vent Valve is Closed AND

NSSC liquor flow toImpregnator is greater than 30

gpm for 5 minutes AND the chip

screw feeder is greater than 20

1.5 1.5 continue routing emissions to LVHC collection

system and primary or backup control system

rpm for 5 minutes AND KW on 1

of 3 Unimount refiners is

greater htan 100 kw and

variation is less than +/‐ 400 KW

for 15 min.

Semichem Pulping INC_BOIL 245 7 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC & HVLC control systems

are operating AND DigesterBlow Heat Vent Impregnator

Valve is Closed AND Digester

M&A Vent Valve is Closed AND

NSSC liquor flow toImpregnator is greater than 30

gpm for 5 minutes AND the chip

screw feeder is greater than 20

rpm for 5 minutes AND KW on 1

of 3 Unimount refiners is

greater htan 100 kw and

variation is less than +/‐ 400 KW

for 15 min.

2 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Semichem Pulping INC_BOIL 245 2 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

The Blow Tank stock flow is

greater than 1000 gpm for 5

mins. AND power on 1 of 3

unimount refiners is greater

than 100 KW and variation is

less than +/‐  400 kW for 15

mins.

1.5 1.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Semichem Pulping INC_BOIL 247 2 1.5 1.5 Verify NCG Collection System is available and

NCG are being sent to a boiler prior to startup of

the operation.

Amp loads and control loops

are maintained within normal

ranges for 60 minutes.

1.5 1.5 Continue routing emissions to NCG system and

boilers.

Semichem Pulping INC_BOIL 247 2 3 3 Verify NCG Collection System is available and

NCG are being sent to a boiler prior to startup of

the operation.

Black liquor meetsspecifications for 60 minutes.

3 3 Continue routing emissions to NCG system and

boilers.

Semichem Pulping INC_BOIL 247 3 NA NA NA NA NA 

Semichem Pulping INC_LK 188 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Level in Digester, 500‐900 kW

Power on Defibrator

1 1 LVHC gases continue to be collected and

incinerated unitl shutdown is complete.

Semichem Pulping INC_LK 188 1 NA ‐ 

Equipment

Startup and

Shutdown is

dependent

on upstream

and

downstream

operations

emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

NA ‐ Equipment Startup and

Shutdown is dependent on

upstream and downstreamoperations

NA ‐ 

Equipment

Startup and

Shutdown is

dependent

on upstream

and

downstream

operations

NA ‐ Equipment Startup and Shutdown is

dependent on upstream and downstream

operations

Semichem Pulping INC_LK 226 1 0.75 0.75 ensure primary and backup control are available When the unit begins receiving

pulp

0.3 0.3 

Semichem Pulping INC1 116 1 Hot Startup:

3‐4 hrs

Cold Startup:

3‐4 hrs

4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating a

startup on the digester system(s).

Blow line flow and extraction

flow standard operating

condition are met.

Hot

Shutdown: 3‐

4 hrs

Cold

Shutdown: 3‐

4 hrs

4 Maintain a chip level and switch to low pressur

fresh steam for chip bin pre‐steaming prior to

beginning the shutdown sequence.Ensure theHVLC collection and treatment system is in

operation and all system valves are in the

appropriate position until completing shutdow

of the digester system(s).

Semichem Pulping INC1 116 2 Hot Startup:

3‐4 hrs

Cold Startup:

3‐4 hrs

4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating of

the Evaporator System(s).

Blow line flow and extraction

flow standard operating

condition are met.

Hot

Shutdown: 3‐

4 hrs

Cold

Shutdown: 3‐

4 Ensure the HVLC collection and treatment

system is in operation and all system valves are

in the appropriate position until completingshutdown of the CSSC Pulp Washing System(s).

4 hrs

Semichem Pulping INC1 116 2 Hot Startup:

3‐4 hrs

Cold Startup:

3‐4 hrs

4 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position before initiating a

startup on the digester system(s).

Blow line flow and extraction

flow standard operating

condition are met.

Hot

Shutdown: 3‐

4 hrs

Cold

Shutdown: 3‐

4 hrs

4 Maintain a chip level and switch to low pressur

fresh steam for chip bin pre‐steaming prior to

beginning the shutdown sequence.Ensure the LVHC collection and treatmentsystem is in operation and all system valves are

in the appropriate position until completingshutdown of the digester system(s).

Semichem Pulping INC1 116 2 Hot Startup:

6‐12 hrs

Cold Startup:

4‐6 hrs

6 Stop liquor flow and steam flow to the

evaporators prior to intiating shutdown of the

LVHC collection system.

Operation has stabilized andevaporator product is at targetpercent solids

Hot

Shutdown:

0.5‐2 hrs

Cold

Shutdown: 6‐

8 hrs

8 Ensure the LVHC collection and treatment

system is in operation and all system valves are

in the appropriate position until completingshutdown of the Evaporator System(s).

Semichem Pulping INC1 169 8 BEFORE startup of the Washer System: (1)

Confirm the HVLC System control device is ready

to accept gases; and (2) Ensure equipment isproperly valved to the HVLC Collection System.

When a steady pulp blow flow

has been established.

Continuing routing emissions to the HVLC Systeand Control Device

Semichem Pulping INC1 181 1 no longer in

service

Semichem Pulping: NCG System

Semichem Pulping: NCG System INC_BOIL 247 1 0.25 0.25 A boiler is available prior to startup of the

system.

LVHC gases are transported to aboiler, and system vacuum is

verified.

0.25 0.25 Gases routed to a boiler during shutdown. 

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Semichem Pulping: NCG System INC_BOIL 304 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

chip feed 0.25 0.25 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Semichem Pulping: NCG System INC_BOIL 304 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

weak liquor feed 0.25 0.25 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Semichem Pulping: NCG System SCBR/INC_BOIL 122 1 0.75 0.75 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Black liquor feed to evaporator 0.75 0.75 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Semichem Pulping: NCG System SCBR/INC_BOIL 122 1 0.75 0.75 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

pulp feed to washers 0.75 0.75 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Semichem Pulping: NCG System SCBR/INC_BOIL 122 1 0.75 0.75 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

pulp feed to washers,Black

liquor feed to evaporator

0.75 0.75 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Soda Misc

Soda Misc INC_TO 106 1 4 4 Verify collection system is available and gases

are being sent to a control device prior to startup

of the operation.

Begin feeding black liquor tothe black liquor storage tank.

1 1 Continue routing collected gases to the control

device.

Soda Misc INC1_TO 106 2 24 24 Verify collection system is available and gases

are being sent to a control device prior to startup

of the operation.

12 hours after pulp is sent to

the blow tank.

12 12 Continue routing gases to the collection system

and primary or backup control device.

Soda Misc INC1_TO 106 3 24 24 Verify primary or backup control device is

available prior to startup.

Stripper, evaporator, brown

stock washer, and digester

startups are complete.

12 12 Collected gases are routed to a control device

until the stripper, evaporator, brown stockwasher, and digester systems are all shutdown

Soda Misc INC1_TO 106 1 4 4 Verify collection system is available and gases

are being sent to a control device prior to startup

of the operation.

Begin feeding black liquor to

the black liquor storage tank.

1 1 Continue routing collected gases to the control

device.

Soda Misc INC1_TO 106 1 NA NA NA NA NA 

Soda Pulping: Pulping: BL Tanks HVLC

Soda Pulping: BL Tanks HVLC INC1_TO 106 3 NA NA NA NA NA 

Soda Pulping: Digester LVHC

Soda Pulping: Digester LVHC INC1_TO 106 1 24 24 Verify collection system is available and gases

are being sent to a control device prior to startup

of the operation.

12 hours after pulp is sent to

the blow tank.

12 12 Continue routing gases to the collection system

and primary or backup control device.

Soda Pulping: Evaporator LVHC

Soda Pulping: Evaporator LVHC INC1_TO 106 4 4 4 Verify collection system is available and gases

are being sent to a control device prior to startup

of the operation.

Begin feeding black liquor to

the black liquor storage tank.

1 1 Continue routing collected gases to the control

device.

Soda Pulping: Knotter

Soda Pulping: Knotter INC1_TO 106 1 24 24 Verify collection system is available and gases

are being sent to a control device prior to startup

of the operation.

12 hours after pulp is sent to

the blow tank.

12 12 Continue routing gases to the collection system

and primary or backup control device.

Soda Pulping: Washing

Soda Pulping: Washing INC1_TO 106 1 24 24 Verify collection system is available and gases

are being sent to a control device prior to startup

of the operation.

12 hours after pulp is sent to

the blow tank.

12 12 Continue routing gases to the collection system

and primary or backup control device.

Storage Tanks

Storage Tanks BH 137 1 0.25 0.25 NA System operational 1 1 NA 

Storage Tanks INC 145 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Storage Tanks INC_BOIL 167 6 3 ‐ 16

Routine/Ann

ual

16  ‐ BEFORE startup: 1) Confirm the HVLC System

control device is ready to accept gases and 2)Ensure equipment is properly valved to the HVLC

Collection System

Stock flow has reached anappropriate level

2 ‐ 8

Routine/Ann

ual

8 Continuing routing emissions to the HVLC

Collection System and Control Device

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Storage Tanks INC_BOIL 245 2 4.5 4.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Either (HVLC‐M&A Fan is ON

and vacuum > < ‐15") AND(HVLC‐M&A Vent bypass valve

at the No. 1 WFB (13‐ZsC‐

5620)is closed AND the boilerselect is #1WFB OR the No. 2

WFB (13‐ZsC‐5622) is CLOSEDAND the boiler select is #2WFB)AND condenser outlet temp is<150 degrees AND Vacuum <‐

15

1 1 continue routing emissions to HVHC collection

system and primary or backup control system

Storage Tanks ‐ Methanol

Storage Tanks ‐ Methanol INC_RF 180 1 0.1 0.1 Ensure seal pot has water level in it Methanol feeding into tank 1 1 Ensure seal pot has water level in it 

Storage Tanks ‐ Methanol INC_RF 180 1 1 1 No rupture discs blown Methanol flow to storage tank 1 1 No rupture discs blown 

Storage Tanks ‐ Methanol INC_TO 242 1 0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Steam flow to the stripper 0.1 0.1 stop routing process condensates to stripper

before beginning shutdown

Storage Tanks ‐ Methanol INC_TO/SCBR/ESP 243 1 0 0 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Methanol flow to tank. 0 0 continue routing emissions to NCG collection

system and primary or backup control system

Storage Tanks ‐ Methanol INC_TO/SCBR/ESP 243 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Production of rectifiedmethanol

0.5 0.5 continue routing emissions to NCG collection

system and primary or backup control system

Storage Tanks ‐ Methanol INC1 189 1 0 0 NA NA NA NA 

Storage Tanks ‐ Methanol INC1 613 1 2 2 Per the SSM Plan:

Methanol System is accepted into the NCG

System prior to startup; Cooling water is flow isintroduced to methanol system condenser

Per the SSM Plan:

Temperature from condenser:<130F, storage tank

temperature, <130F, Methanol

density between 56 and 60,

NCG system available

2 2 Per the SSM Plan:

Stripping Column is shut down prior to shutting

down of Methanol System

Storage Tanks ‐ Methanol OTH 115 1 instantaneou

s

0 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Methanol in tank NA NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Wood Handling: Digester chip bin

Wood Handling: Digester chip bin COND/TO 112 1 0.5 0.5 Collection and control systems operating before

start‐up

When chips fed from bin todigester

10 10 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

Wood Handling: Digester chip bin INC_BOIL 177 1 6‐20 hours

(range which

includes

startup of

digester

system

equipment).

20 continue routing emissions to EU1151 or EU0804 When digester reaches target

production rates and normal

cooking cooking conditions are

established.

6‐20 hours

(range which

includes shut

down ofdigester

system

equipment).

20 continue routing emissions to EU1151 or EU080

Wood Handling: Digester chip bin INC_RF 119 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameterlimits during emission unit startup

When No.21 Rec. Blr. is firing

black liquor, is stable and safety

interlocks are satisfied.

4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shut down

Wood Handling: Digester chip bin INC_RF 182 1 30 30 Operate NCG and foul condensate systems

properly

When pulp is transferred to theblow tank

30 30 Shutdown NCG and foul condensate systems

only after source has been shutdown

Wood Handling: Digester chip bin INC_TO 112 1 Collection and control systems operating before

start‐up

When NCG generating systemsstabilize

continue routing emissions to LVHC collection

system and primary or backup control system

Wood Handling: Digester chip bin INC_TO 112 1 0.5 0.5 Collection and control systems operating before

start‐up

When gasses exit condenser 10 10 continue routing emissions to LVHC‐1 collectio

system and primary or backup control system

C2_NCG_Equip_detail 
Appendix C2

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_h

rs_num

SD_EmissRednMeas 

Wood Handling: Digester chip bin INC_TO 178 1 6 6 BEFORE startup of the Digester System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment is

properly valved to the LVHC Collection

System.**Operate the Digester System in such a

way as to prevent over pressurizatio

Blow heat system standard

operating conditions are met

and digesters are routinelyblowing

3 3 (1) Continuing routing emissions to the LVHC

Collection System and Control Device (2) Opera

the Digester Equipment System in such a way ato prevent over pressurization of system during

shutdown (3)During emergency shutdowns, all

digesters should be put on hold to suspend the

cooking process and blowing should be held un

the Blow Heat System is back under normal

operating conditions.

Wood Handling: Digester chip bin INC1 102 1 See DIG See DIG See DIG See DIG See DIG 

Wood Handling: Digester chip bin INC1 150 1 2.5 2.5 continue routing emissions to HVLC‐1 collection

system and primary or backup control system

Pressure Diffuser Operating,

Sustained flow on diffuser

0.75 0.75 continue routing emissions to HVLC‐1 collectio

system and primary or backup control system

Wood Handling: Digester chip bin INC1 [NOTE: INC1 m 111 1 1.5 1.5 Check for proper water seal levels and flows and

verify all pressure and vacuum seals. HVLC NCG

system is in a collect mode when all the safety

permissives have been satisfied unless the

system is down or locked and tagged out. LVHC

NCG process source or collection system may bevented during startup until it is safe to collect the

gas. Pulping condensates are sent to the

appropriate collection systems. Follow the

proper startup sequence and procedures

outlined in the appropriate sections of the SSMplan for collection systems and control devices.

The Continuous Digester

system startup is consideredcomplete target flow rate

achieved.

3.5 3.5 Shutdown the continuous digester system,

including associate tanks and other equipment

before shutting down the respective collection

systems, e.g. HVLC vent gases, LVHC vent gases

and pulping condenstates.

C2_NCG_Equip_detail 
Appendix C3

Query of Part I Survey Data Base (PI Equip detail tab) for Equipment that Burns NCGs 

(Boilers, Incineration Control Devices, Lime Kilns, and DCE or NDCE Recovery Furnaces) 
Appendix C3

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

DCE or NDCE ESP 115 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Boiler in the Steam Header and

Smelt Flow

0.5 0.5 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

DCE or NDCE ESP 117 1 12 12 Operate ESP during Start‐UP Liquor flow to the boiler is

established

12 12 emission unit and control device operates du

emission unit shutdown (but not necessarily i

compliance with all NSPS/NESHAP parameter

limits)

DCE or NDCE ESP 146 1 Information

to be

provided

with Part III

of survey

Information to be provided with Part III of survey Information to be provided with

Part III of survey

Information

to be

provided

with Part III

of survey

Information to be provided with Part III of sur

DCE or NDCE ESP 148 2 6 6 emission unit and control device operates in

compliance parameter limits during emission unit

startup

When emission unit is firing

black liquor

4 4 emission unit and control device operates in

compliance parameter limits during emission 

shutdown

DCE or NDCE ESP 177 1 8‐12 hours 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Normal operation begins whennormal black liquour firing rates

are reached and the furnace

operation is stable.

8‐12 hours 12 Control device (EU0804ESP) continues to ope

normally during the furnace shutdown proces

DCE or NDCE ESP 195 1 8 8 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Boiler at Pressure (850 psi) 18 18 All Control Equipment remain on‐line until so

is shut down.

DCE or NDCE INC_RF 112 1 14.5 14.5 When recovery boiler stabilizes 13 13 continue routing emissions to control system 

DCE or NDCE INC_RF 140 1 Black Liquor purge credit is

established and Precipitator

Fields 1‐4 on the east or west

side of the precipitator must be

energized.

Ensure that the electrostatic precipitator field

4 on the east or the west side of the precipita

is energized until the boiler is off liquor.

DCE or NDCE INC_RF 146 1 Information

to be

provided

with Part III

of survey

Information to be provided with Part III of survey Information to be provided with

Part III of survey

Information

to be

provided

with Part III

of survey

Information to be provided with Part III of sur

DCE or NDCE INC_RF 147 2 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Steam Temp and Pressure Limit

Met

9 9 emission unit and control device operates du

emission unit shutdown

ICI Boiler/PH BH 370 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Combustion temperature is

reached

2 2 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH BH/SCR 261 1 12 12 Precoat baghouse bags with sodium bicarbonate,

warm SCR using steam coil heaters.

Start of ammonia injection to

system

1 1 Use burners to ensure all fuel is burned. 

ICI Boiler/PH CYC/BH 339 1 3 3 Steam pressure of 100 psig or

greater achieved

1.5 1.5 

ICI Boiler/PH CYC/ESP 118 2 6 6 centrifugal collectors and ESP steam flow 15 15 centrifugal collectors and ESP 

ICI Boiler/PH CYC/SCBR 606 1 8 8 Follow applicable module PBOMP, activate the

boiler and bark dryer venturi scrubbers.

Steam pressure of 600 psi or

greater has been achieved

2 2 Follow applicable module PBOMP for shutdow

of the boiler and ancillary equipment, operate 

boiler and bark dryer venturi scrubbers until t

boiler is down.

ICI Boiler/PH CYC/SCBR 606 1 8 8 Follow applicable module PBOMP, activate the

boiler venturi scrubber and use the TRS non‐

condensable gas backup scrubber until the

furnace temperature reaches a minimum of 1,200

F.

Steam pressure of 600 psi or

greater has been achieved

2 2 Follow applicable module PBOMP for shutdow

of the boiler and ancillary equipment, operate 

boiler venturi scrubber and use the TRS non‐

condensable gas backup scrubber prior to the

shutdown sequence.

DCE or NDCE

ICI Boiler/PH

C3_RF_INC_LK_BOI_Equip_detail 
Appendix C3

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

ICI Boiler/PH ESP 115 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Boiler into the Steam Header for

the Plant

1 1 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH ESP 199 4 1 1 emission unit and control device operates during

emission unit startup in compliance with air

permit limits

Coal feed system is started and

coal is fed to boiler

0.5 0.5 emission unit and control device operates du

emission unit shutdown in compliance with apermit limits

ICI Boiler/PH ESP 208228535 1 12 12 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

Commencement of hog fuelfiring in boiler

0.2 0.2 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH ESP/MC 420 1 8 8 1250 psi and steam flow to

header

4.5 4.5 

ICI Boiler/PH ESP/SCBR 159 1 6‐8 8 control device used during startup ~600 lb pressure 1 1 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH FGR 118 2 steam flow 0.01 0.01 

ICI Boiler/PH FGR 258 1 6 6 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

Operating steam pressure is

achieved

0 0 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH FGR 311 1 4 4 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

Flue gas temperature at desired

level. Steam system pressure atset point

0.5 0.5 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH LNB 139 1 6 6 Startup in low fire mode. Steam production at pressure 1 1 Purge burner tip with steam 

ICI Boiler/PH MC 230 2 6 6 Trim fuel/air ratio, trim steam/oil ratio Steam pressure of 920 psig or

greater achieved and steam

flowing to header

1 1 Trim fuel/air ratio, trim steam/oil ratio 

ICI Boiler/PH MC 258 1 6 6 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

Operating steam pressure is

achieved

0 0 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH MC/ESP 149 1 12‐16 16 Operate all APCDs during startup Normal steam rate and no

longer burning auxiallary fuel

4‐6 6 Operate all APCDs during shutdown 

ICI Boiler/PH MC/ESP 245 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

WFB2 Fuel Burner Valve=open

OR any WFB2 stoker feeders

operating OR ID Fan operating

at greater than 1000rpm AND

steam production greater than

50000 lbs/hr

1 1 emission unit and control device operates du

emission unit shutdown (but not necessarily i

compliance with all NSPS/NESHAP parameter

limits)

ICI Boiler/PH MC/ESP 451 2 5 5 emission unit and control device operates during

emission unit startup

Producing steam on‐line and

opacity <20%

12 12 emission unit and control device operates du

emission unit shutdown

ICI Boiler/PH MC/SCBR 103 1 12 12 The control device should be fully operational

prior to introduction of pollutants. Minimum

steaming rate (> 120 Klbs/hr and Steam Pressure

> 1200 PSIG) must be achieved before NCG’s are

incinerated.

The No. 1 Hog Fuel Boiler is

operating normally, as defined

by the mill's operating manualsand standard operating

procedures and verified by DCS

data. For the HVLC gases, the

No. 1 Hog Fuel Boiler isoperating at a stable rate,

incineration interlocks are metand the switch (No. HS812) is in

the select boiler position.

8 8 DCS also display provides information of HVLC

NCG switch over from No. 2 Hog Fuel Boiler to

No. 1 Hog Fuel Boiler before shutdown of boi

occurs. Operators also receive an alarm if the

main header HVLC NCG vent valve opens.

C3_RF_INC_LK_BOI_Equip_detail 
Appendix C3

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

ICI Boiler/PH MC/SCBR 103 1 12 12 The control device should be fully operational

prior to introduction of pollutants. Minimum

steaming rate (> 120 Klbs/hr and Steam Pressure

> 1200 PSIG) must be achieved before NCG’s are

incinerated.

The No. 2 Hog Fuel Boilers is

operating normally, as defined

by the mill's operating manuals

and standard operating

procedures and verified by DCS

data. For the LVHC and SOG

gases, the No. 2 Hog Fuel Boiler

is operating at a stable rate,

incineration interlocks are metand the manual LVHC NCG and

SOG switches are in the

"Accept" mode. For the HVLC

gases, the No. 2 Hog Fuel Boiler

is operating at a stable rate,

incineration interlocks are metand the switch (No. HS812) is in

the select boiler position.

8 8 DCS display provides information of LVHC NC

and SOG switch over from No. 2 Hog Fuel Boi

to Lime Kiln before shutdown of boiler occurs

Operators also receive an alarm if the main

header LVHC NCG or SOG vent valve opens. D

also display provides infomation of HVLC NCG

switch over from No. 2 Hog Fuel Boiler to No. 

Hog Fuel Boiler before shutdown of boiler occ

Operators also receive an alarm if the main

header HVLC NCG vent valve opens.

ICI Boiler/PH MC/SCBR 124 2 6 6 Scrubber system turned prior to initiating firing in

boiler. Fuel to air ratios monitored and adjusted,

as necessary.

Start producing steam 3 3 Scrubber system kept on until firing is halted 

boiler. Fuel to air ratios monitored and adjusas necessary.

ICI Boiler/PH MC/SCBR 147 2 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Steam Temp and Pressure Limit

Met

5 5 emission unit and control device operates du

emission unit shutdown

ICI Boiler/PH MC/SCBR 149 1 12‐16 16 Operate all APCDs during startup Normal steam rate and no

longer burning auxiallary fuel

4‐6 6 Operate all APCDs during shutdown 

ICI Boiler/PH MC/SCBR 167 1 3 ‐ 12

Routine/Ann

ual

12 NA‐ not an emissions unit Power Boiler ‐ Steam flow being

produced above minimum

necessary to incinerate NCGs.

2 ‐ 8

Routine/Ann

ual

8 NA‐ not an emissions unit 

ICI Boiler/PH MC/SCBR/WESP 245 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

WFB1 Fuel Burner Valve=open

OR any WFB1 stoker feed

screws operating AND steam

production greater than 50000

lbs/hr

1 1 emission unit and control device operates du

emission unit shutdown (but not necessarily i

compliance with all NSPS/NESHAP parameter

limits)

ICI Boiler/PH NOT PROVIDED (SEE

BOILER ICR DATA)

156 1 4.5 4.5 follow SSM manual procedures 4.5 4.5

ICI Boiler/PH NOT PROVIDED (SEE

BOILER ICR DATA)

156 2 4.5 4.5 follow SSM manual procedures Weak NCG Vent is closed to

atmosphere

4.5 4.5 follow SSM manual procedures 

ICI Boiler/PH NOT PROVIDED (SEE

BOILER ICR DATA)

156 1 4.5 4.5 Good operating practices 4.5 4.5 Good operating practices

ICI Boiler/PH SCBR 180 1 5 5 Scrubbers on‐line above minimum flow of

1,657gpm with dp above 7.0 psi

Main 850 psi header pressure

obtained at temperature of 825

degrees F

0.2 0.2 Scrubbers on‐line above minimum flow of

1,657gpm with dp above 7.0 psi

ICI Boiler/PH SCBR 180 2 5 5 Scrubbers on‐line above minimum flow of 433

gpm with dp above 4.3 psi

Main 850 psi header pressure

obtained at temperature of 825

degrees F

0.1 0.1 Scrubbers on‐line above minimum flow of 433

gpm with dp above 4.3 psi

ICI Boiler/PH SCBR 195 1 6 6 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Boiler at Pressure (850 psi) 1 1 All Control Equipment remain on‐line until so

is shut down.

ICI Boiler/PH SCBR 197 1 0.5 0.5 I.D. fan running and the boiler is

producing steam

0.5 0.5 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH SCBR 500 1 0.08 0.08 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

System vacuum is approximately7 inches Hg

0.02 0.02 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH SCBR 606 1 7 7 Follow applicable module PBOMP (Principle

Based Operation & Maintenance Procedure) for

pre‐start‐up and startup of the boiler and

ancillary equipment.

Steam pressure of 600 psi or

greater has been achieved

1 1 Follow applicable module PBOMP for shutdow

of the boiler and ancillary equipment.

ICI Boiler/PH SCBR 208228535 1 12 12 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

Commencement of hog fuelfiring in boiler

0.2 0.2 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

C3_RF_INC_LK_BOI_Equip_detail 
Appendix C3

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

ICI Boiler/PH SCBR/MC 229 2 6 6 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

When steaming hits 30% of

capacity

11 11 

ICI Boiler/PH SCBR/WESP 245 2 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Flame is proven for 15 minutes

and 15 minute rolling average of

steam production is greater

than 25000#/hr

1 1 emission unit and control device operates du

emission unit shutdown (but not necessarily i

compliance with all NSPS/NESHAP parameter

limits)

ICI Boiler/PH WESP 203 1 5 5 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

wood feed on, unit has alreadybeen preheated by natural gas

0.5 0.5 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

ICI Boiler/PH WESP 226 1 6 6 ensure WESP is operational When steam enters the steam

header

0.5 0.5 Continue operation of WESP 

Incineration Control Device INC_BOIL 600 1 Hot/Cold

Startup: 0.5‐2

hours

2 There are no HAP emissions as a result of starting

up the collection system. HAPS are only

generated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit Hot/Cold

Shutdown:

0.5 hours

0.5 There are no HAP emissions as a result of shu

down the collection system. HAPS are only

generated by the emission units and not the

collection system. The collection system and

control device must be operational while one 

more emission units are running.

Incineration Control Device INC_TO/SCBR 130 1 Hot Startup:

1 Hr; Cold

Startup: 16

Hrs

16 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup. LVHC

NCGs are only valved to Thermal Oxidizer when

unit has achieved minimum operating

temperature and SO2 Scrubber is operational.

Thermal Oxidizer has achieved

minimum operating

temperature and SO2 Scrubber

is operational.

1 1 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

Incineration Control Device INC_TO/SCBR 137 1 14 14 BACKUP CONTROL Steam flow to the LVHC ejectors

and NCG Incinerator

temperature > 1324 deg.F

1 1 BACKUP CONTROL 

Incineration Control Device INC_TO/SCBR 138 1 0.2 0.2 Route LVHC‐1 to the Lime Kiln for incineration

Incineration Control Device INC_TO/SCBR 162 1 1‐2 2 1 1

Incineration Control Device SCBR 102 1 APCD is a

Thermal

Oxidizer; see

PI Controls

tab

APCD is a Thermal Oxidizer; see PI Controls tab APCD is a Thermal Oxidizer; see

PI Controls tab

APCD is a

Thermal

Oxidizer; see

PI Controls

tab

APCD is a Thermal Oxidizer; see PI Controls ta

Incineration Control Device SCBR 104 1 Startup Hot ‐ 

0.25, Startup

Cold ‐ 2

2 There are no HAP emissions as a result of starting

up the collection system. HAPS are only

generated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source

NA‐Not an emission unit Shutdown

Hot ‐ 0.25,

Shutdown

Cold ‐ 0.25

0.25 There are no HAP emissions as a result of shu

down the collection system. HAPS are only

generated by the emission units and not the

collection system. The collection system and

control device must be operational while one 

more emission units are are running.

Incineration Control Device SCBR 109 2 8 8 The scrubber must be operational before process

unit is started up

Emission unit is not started up if APCD is not

operational, venting can occur if both primary

and backup incinerator points are down (but 

isn't the only time).

Incineration Control Device SCBR 112 1 12 12 Collection and control systems operating before

start‐up

When NCG generating systems

and Incinerator stabilize

8 8 continue routing emissions to control system

Incineration Control Device SCBR 127 1 0.333 0.333 Use Power Boiler 3 as control device Estalishing desired temperature 0.0167 0.0167 Use Power Boiler 3 as control device 

Incineration Control Device SCBR 136 1 24 24 Burn NCGs in power boilers EU 002 and EU 004 Combustion chamber

temperature >=1600 oF

0 0 Burn NCGs in power boilers EU 002 and EU 00

Incineration Control Device SCBR 143 1 NA NA NA NA NA 

Incineration Control Device SCBR 146 1 12 12 NCG Gases are not introduced until the

temperature reaches 1400 F and the scrubber

system is in operation

0.1 0.1 None 

Incineration Control Device SCBR 148 1 10 10 NCGs are not introduced until source has reached

proper temperature

When reach 1600 deg F 10 10 emission unit and control device operates in

compliance parameter limits during emission 

shutdown

Incineration Control Device SCBR 149 1 10 10 Operate all APCDs during startup Warm up curve complete to

1250 °F

0 0 Operate all APCDs during shutdown 

Incineration Control Device

C3_RF_INC_LK_BOI_Equip_detail 
Appendix C3

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Incineration Control Device SCBR 169 1 0.5 0.5 There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., HVLC systems).There are no emissions during startup since the

control device is started up and meets required

operating parameter limits before the emission

unit is started up.

When an operational

temperature is achieved in the

HVLC incinerator.

0.166666666

666667

0.166666667 SHUTDOWN (Does not include unplanned

shutdown events associated with equipmentmalfunctions). During a normal shutdown, thcontrol device is not shutdown until all gases

from emission units are shut down or re‐rout

During an emergency shutdown, all gases froemission units are routed to a backup device.

Incineration Control Device SCBR 178 1 13 13 There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).There are no emissions during startup since the

control device is started up and meets required

operating parameter limits before the emission

unit is started up.

Startup ends when the

combustion temperature limit is

achieved

10 10 SHUTDOWN (Does not include unplanned

shutdown events associated with equipmentmalfunctions). During a normal shutdown, thcontrol device is not shutdown until all gases

from emission units are shut down or re‐rout

During an emergency shutdown, all gases fro

emission units are routed to a backup device.

Incineration Control Device SCBR 189 1 16 16 Per the SSM Plan, at 1400 F. Startup Note: The

operator will insure that certain operating

conditions are reached before the Incinerator is

ready to accept vent gases. The operator will also

insure that the LVHC and HVLC gases are

introduced to the Incinerator is ready to accept

vent gases. The operator will also insure that the

LVHC and HVLC gases are introduced to the

Incinerator following the startup procedures for

each process and the LVHC and HVLC Gas

Collection Systems.

Per the SSM Plan, collection of

HVLC/LVHC System. Verify the

Incinerator temperature has

reached 1400°F. Ignite theIncinerator per mill standard

operating procedures. Insurethe Incinerator has reached the

minimum temperature for

ignition as defined in the mills

standard operating procedures.

Verify all valve positions are set

as defined in the mills standard

operating procedures.

0.25 0.25 Per the SSM Plan, Shutdown Note: The

Incinerator must remain online until all proce

systems have been completely shutdown and

vent gases are no longer being sent to the

Incinerator or the vent gases are being divert

the 9A Boiler or Lime Kiln.

Incineration Control Device SCBR 195 1 0.5 0.5 Temperature set point met 0.2 0.2

Incineration Control Device SCBR 226 1 12 12 Thermal Oxidizer temperature

>1400 + any burn valve open

0.5 0.5 continue routing emissions to collection syste

and primary or backup control system

Incineration Control Device SCBR 242 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

NCG gases introduced to unit 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP paramete

limits during emission unit shutdown

Incineration Control Device SCBR 243 2 36 36 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Incinerator up to requiredtemperature and scrubber is

operational

0.25 0.25 Shutdown all sources of NCGs before shutting

down incinerator

Incineration Control Device SCBR 525 1 0 0 NA NA 0 0 NA 

Incineration Control Device SCBR 610 1 5 5 RTO up to combustion

temperature 1500 F

0.08 0.08 

Incineration Control Device WESP 186 1 0.05 0.05 WESP 0.05 0.05

Lime Kiln CYC/ESP 147 1 20 20 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Full load introduced 24 24 emission unit and control device operates du

emission unit shutdown

Lime Kiln ESP 102 1 0.1 0.1 Switching of HC from Incinerator to Lime kiln is

designed for vent‐less transfer.

Minimum steam flow established on the NCG

lance to prevent burn‐back

Natural gas flame and sufficient combustion air

flow to provide complete combustion

DCS and operating logs indicate

when HC gases are routed to

the lime kiln.

0.1 0.1 Switching of HC from Lime kiln to Incinerator 

designed for vent‐less transfer.

Lime Kiln ESP 112 1 30 30 Collection and control systems operating before

start‐up

When NCG generating systems

and kiln stabilize

6 6 continue routing emissions to control system

Lime Kiln ESP 115 1 24 24 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Lime flow out of the Kiln 4 4 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

Lime Kiln

C3_RF_INC_LK_BOI_Equip_detail 
Appendix C3

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Lime Kiln ESP 126 1 4 4 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

3 hours after lime mud

processing begins and when

firing sufficiently stable to

thermally oxidize NCG from

LVHC.

4 4 continue routing emissions to LVHC collection

system and primary or backup control system

Lime Kiln ESP 146 1 12 12 alternate control device for NCG combustion

(LVHC1, SOG1, HVLC1)

Introduction of NCGs to the kiln 0.1 0.1 Emissions are normally routed to the incinera

(REC065)

Lime Kiln ESP 148 1 14 14 emission unit and control device operates in

compliance parameter limits during emission unit

startup

When proper operating

temperature has been achieved

0.5 0.5 emission unit and control device operates in

compliance parameter limits during emission 

shutdown

Lime Kiln ESP 240 1 Greater 20

hours

20 Start‐up kiln.**After kiln is brought to operating

temperature follow procedure 09‐"Switching the

NCGs to the Kiln".**Follow procedure "Stripper

Off Gas ‐ Ventless Mode Transfer from the

Incinerator to Kiln".**Note that startup

procedures for the lime kil

Startup has ended and normal

operation has begun after the

kiln is brought up to operating

temperature and NCGs have

been successfully diverted from

the incinerator to the lime kiln.

Greater 20

hours

20 (1) Follow procedure "Stripper Off Gas ‐ Trans

from Kiln to Incinerator in Ventless Mode". (2

Follow procedure 11‐"Switching the NCG's to 

Incinerator".(3) Shutdown kiln. Note that

shutdown procedures for the lime kiln have b

automated. The mea

Lime Kiln ESP/BH 132 1 36 36 ESP energized and NCGs routed to backup

incinerator

Steady mud flow 36 36 ESP energized, NCGs routed to backup

incinerator, No. 6 Fuel oil feed turned off.

Lime Kiln ESP/SCBR 137 2 36 36 FOLLOW SSM PLAN Natural gas flow > 150 scfm on a

sustained basis and precipitator

temperature > 350 deg.F and

Stack O2 is < 16% on a sustainedbasis and precoat belt mud flow

into kiln operating in a forward

position and mud flow to lime

kiln > 50 gpm on a sustained

basi

24 24 FOLLOW SSM PLAN 

Lime Kiln ESP/SCBR 154 1 30 30 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Start feed to kiln 2 2 Continue routing emissions to ESP/Scrubber 

Lime Kiln ESP/SCBR 242 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When lime mud flow to the kiln

starts

0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP paramete

limits during emission unit shutdown

Lime Kiln SCBR 117 1 36 36 Operate Scrubber during Start‐UP Full and Steady Combustion

temperature reached and lime

mud feed on

18 18 emission unit and control device operates du

emission unit shutdown (but not necessarily i

compliance with all NSPS/NESHAP parameter

limits)

Lime Kiln SCBR 130 2 Hot Startup:

1 Hr; Cold

Startup: 24

Hrs

24 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

Established lime production

through the kiln

6‐8 8 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

Lime Kiln SCBR 139 1 4 4 LK Scrubber is operating prior to startup Mud feed to LM Washer is on. 0.1 0.1 LK Scrubber is operating during shutdown 

Lime Kiln SCBR 140 1 Venturi Scrubber flow is greater than 500 gpm

and the delta P across the scrubber is greater

than 20 inches of water.

Lime Mud filter pump is on,

Venturi Scrubber flow is greater

than 500 gpm and the delta P

across the scrubber is greater

than 20 inches of water.

The flow to the Venturi scrubber must be gre

than 500 gpm and the delta P across the scru

must be greater than 20 inches of water.

Lime Kiln SCBR 146 1 12 12 alternate control device for NCG combustion

(LVHC1, SOG1)

Introduction of NCGs to the kiln 0.1 0.1 Emissions are normally routed to the incinera

(REC065)

Lime Kiln SCBR 147 1 20 20 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Full load introduced 24 24 emission unit and control device operates du

emission unit shutdown

Lime Kiln SCBR 148 1 14 14 emission unit and control device operates in

compliance parameter limits during emission unit

startup

When proper operatingtemperature has been achieved

0.5 0.5 emission unit and control device operates in

compliance parameter limits during emission 

shutdown

Lime Kiln SCBR 152 1 8 8 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup,

backup/alternate controls are available

Combustion temperature

reaches 1200F

8 8 If emission units are operating, switch to

alternate control device

C3_RF_INC_LK_BOI_Equip_detail 
Appendix C3

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Lime Kiln SCBR 156 1 42 42 follow SSM manual procedures Open Weak NCG supply valve to

No. 3 Lime Kiln Primary Air Fan

inlet Stack

24 24 follow SSM manual procedures 

Lime Kiln SCBR 156 1 42 42 follow SSM manual procedures Open Weak NCG supply valve to

No. 4 Lime Kiln Primary Air Fan

inlet Stack

24 24 follow SSM manual procedures 

Lime Kiln SCBR 157 1 27 27 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When product lime is made 3 3 NA ‐ applicable emission and parameter limits 

expected to be exceeded during shutdown

Lime Kiln SCBR 186 1 36 36 Precipitator and Scrubber Startup is complete when mud

and fire are fed into the kiln

24 24 Precipitator and scrubber 

Lime Kiln SCBR 188 2 24 24 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Lime mud is introduced to wet

end of kiln

24 24 Operate Peabody Scrubber during Shutdown 

Lime Kiln SCBR 188 1 48 48 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Lime mud is introduced to wet

end of kiln

24 24 Operate Peabody Scrubber during Shutdown 

Lime Kiln SCBR 190 2 3 3 Control device is started up and required

scrubber flow and differential pressure operating

parameter limits are met before emission unit is

started up load is put on Lime Kiln. Ensureminimum Kiln front end temperature is met

before routing NCG to the Kiln.

Startup is complete once lime

mud begins going to the lime

kiln.

8 8 Control device continues to operate and mee

required operating limits while emission unit shut down.

Lime Kiln SCBR 195 1 1 1 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Introduction of mud 1 1 All Control Equipment remain on‐line until so

is shut down.

Lime Kiln SCBR 610 1 1 1 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NESHAP parameter limits)

mud flow and oil on 0.08 0.08 emission unit and control device operates du

emission unit shutdown (but not necessarily i

compliance with all NESHAP parameter limits

Lime Kiln SCBR 610 1 1 1 emission unit and control device operates in

compliance with NESHAP parameter limits during

emission unit startup

mud flow and oil on 0.08 0.08 emission unit and control device operates in

compliance with NESHAP parameter limits du

emission unit shutdown

Lime Kiln SCBR 613 1 2 2 Per the SSM Plan, Starup and ensure the

minimum scrubber flow rate and differential

pressure have been established in the Venturi

Scrubber before introducing mud into the Lime

kiln. Follow established operating procedures.

After proper startup, ensure that he scrubber

flow rate and differential pressure are meeting

the minimum requirements.

Per the SSM Plan, Veifty that

lime kiln fuel burner is in

operation and is stable. Verify

that the lime kiln's flame safety

system is engaged. Verify the

SO2 system is operating within

normal ranges, as is the

temperature.

2 2 Per the SSM Plan: Full Operation of the Ventu

Scrubber should continue after fuel firing cea

until the flow of lime mud has stopped and th

generation of lime has also ceased (approxim

3 hours); Verify that gases are no longer bein

accepted

Lime Kiln SCBR 615 1 36 36 LVHC sources are not started until the kiln (or

recovery furnace) is operating

Product is generated from kiln 3 3 LVHC sources are down (or in Recovery Furna

prior to kiln shutdown starting

RF BOI INC LK

Startup time

Min 6 0.08 0 0.1

Max 14.5 16 36 48

Avg 10.1 7.0 8.9 19.6

Median 12 6 9 20

Shutdown time

Min 0.5 0 0 0.08

Max 18 15 10 36

Avg 9.8 2.9 1.5 10.2

Median 12 1 0.225 4

C3_RF_INC_LK_BOI_Equip_detail 
Appendix C4

Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the 

ICR
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

109 Kraft 109‐‐LK1 Lime Kiln INC128 Secondary, SemiChem 128‐‐B006 Semichem Pulping: NCG System INC

145 Kraft 145‐‐Other ‐ (SOG002‐01C) condensate stripper INC

145 Kraft 145‐‐Other ‐ (NCG001‐01C)

Condensate Stripper; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC; Kraft

Pulping: HVLC; Kraft Pulping: NCG System;

Kraft Pulping: Turpentine LVHC; Kraft

Pulping: Washing INC

164 Kraft

164‐‐LVHC NCG Incineration in

either Lime Kiln (primary) or No.

11 Boiler (backup)

Kraft Pulping: Digester LVHC; Kraft Pulping:

Evaporator LVHC; Kraft Pulping: Turpentine

LVHC INC NA NA

196 Kraft 196‐‐LVHC

Kraft Pulping: Evaporator LVHC; Kraft

Pulping: Digester LVHC; Kraft Pulping:Turpentine LVHC INC

Monitor combustion

temperature

196 Kraft 196‐‐SOG Condensate Stripper INC

Monitor combustion

temperature

198 Kraft, Mechanical, Secondary 198‐‐014, 014_S

Condensate Stripper; Kraft Pulping:

Evaporator LVHC; Kraft Pulping: Turpentine

LVHC INC Combustion temperature

203 Kraft, Sulfite‐Na 203‐‐Lkiln Kraft Pulping: LVHC INC

203 Kraft, Sulfite‐Na 203‐‐HogBlr Kraft Pulping: LVHC INC

114 Kraft 114‐‐U400

Condensate Stripper; Kraft Pulping:Turpentine LVHC; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC INC_BOIL

115 Kraft 115‐‐SS01 Condensate Stripper INC_BOIL115 Kraft 115‐‐WS01‐4 Condensate Stripper INC_BOIL

115 Kraft 115‐‐WS01‐5 Condensate Stripper INC_BOIL

115 Kraft 115‐‐Stripper Pre‐heater Condensate Stripper; Kraft Pulping: LVHC INC_BOIL

115 Kraft 115‐‐Stripper Condenser Condensate Stripper; Kraft Pulping: LVHC INC_BOIL124 Kraft 124‐‐016 Kraft Pulping: LVHC INC_BOIL

140 Kraft 140‐‐Other ‐ #1 Power Boiler ICI Boiler/PH INC_BOIL

Boiler, Recovery Furnace or

lime kiln into the primary fuel

or into the flame zone.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

145 Kraft 145‐‐Boiler (PR005) ICI Boiler/PH INC_BOIL

145 Kraft 145‐‐Boiler (PR004) ICI Boiler/PH INC_BOIL

152 Kraft 152‐‐09

Kraft Pulping: Digester LVHC; Kraft Pulping:

Turpentine LVHC; Kraft Pulping: Evaporator

LVHC; Kraft Pulping: LVHC; Kraft Pulping:

HVLC; Kraft Pulping: Washing INC_BOIL steam flow

154 Kraft 154‐‐B21 ICI Boiler/PH INC_BOIL combustion temperature None

154 Kraft 154‐‐B20 ICI Boiler/PH INC_BOIL combustion temperature None

173 Kraft 173‐‐PB1

Kraft Pulping: Evaporator LVHC; Kraft

Pulping: Knotter; Kraft Pulping: BL Tanks

HVLC; Kraft Pulping: BL Tanks HVLC; Kraft

Pulping: Digester LVHC; Wood Handling:

Digester chip bin; Kraft Pulping: Washing;

Kraft Pulping: LVHC; Kraft Pulping: HVLC;

Salt Cake INC_BOIL

185 Kraft 185‐‐09 Kraft Pulping: LVHC INC_BOIL

187 Secondary, SemiChem 187‐‐1 Semichem Pulping INC_BOIL

187 Secondary, SemiChem 187‐‐2 Semichem Pulping INC_BOIL

201 Kraft, Mechanical, Secondary 201‐‐SR0030 ICI Boiler/PH INC_BOIL

LVHC bypass vent valveposition, SOG bypass ventvalve position NA

201 Kraft, Mechanical, Secondary 201‐‐SR0002

Condensate Stripper; Kraft Pulping:Evaporator LVHC; Kraft Pulping: Turpentine

LVHC; Kraft Pulping: LVHC INC_BOIL

LVHC bypass vent valveposition, SOG bypass ventvalve position NA

205 Kraft, Secondary 205‐‐011

Wastewater (Kraft): Biogas collection; Kraft

Pulping: Knotter/Screen; Kraft Pulping:Washing; Kraft Pulping: HVLC; Kraft Pulping:

Decker INC_BOIL other (bypass valve position)

Boiler steam production >

75,000 lbs/hr

245 Secondary, SemiChem 245‐‐WFB2 ICI Boiler/PH INC_BOIL

Prism system monitors variousdifferent points in HVLC & LVHC

system

245 Secondary, SemiChem 245‐‐WFB1 ICI Boiler/PH INC_BOIL

Prism system monitors variousdifferent points in HVLC & LVHC

system

245 Secondary, SemiChem 245‐‐WFB2 ICI Boiler/PH INC_BOIL

Prism system monitors various

different points in HVLC & LVHC

system

245 Secondary, SemiChem 245‐‐WFB1 ICI Boiler/PH INC_BOIL

Prism system monitors variousdifferent points in HVLC & LVHCsystem

340 Kraft, Secondary 340‐‐SN‐02 ICI Boiler/PH INC_BOIL

340 Kraft, Secondary 340‐‐SN‐04 Kraft Pulping: HVLC INC_BOIL

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

606 Kraft 606‐‐LVHC Kraft Pulping: LVHC INC_BOIL617 Kraft 617‐‐B20 ICI Boiler/PH INC_BOIL

617 Kraft 617‐‐B21 ICI Boiler/PH INC_BOIL617 Kraft 617‐‐B24 Kraft Pulping: LVHC; Condensate Stripper INC_BOIL103 Kraft 103‐‐WLS, G‐165

Kraft Pulping: LVHC; Kraft Pulping: Digester

LVHC; Kraft Pulping: Turpentine LVHC; Kraft

Pulping: Evaporator LVHC; CondensateStripper INC_LK

Flue gas exit temp., liquid flow

rate, Hot end temp gauge, O2

gauge

107 Kraft 107‐‐11‐P14 Lime Kiln INC_LK TRS monitoring

115 Kraft 115‐‐KD02 Kraft Pulping: Digester LVHC INC_LK

115 Kraft 115‐‐KD06 Kraft Pulping: Turpentine LVHC INC_LK

115 Kraft 115‐‐KD06 Kraft Pulping: Turpentine LVHC INC_LK

115 Kraft 115‐‐KD02 Kraft Pulping: Digester LVHC INC_LK115 Kraft 115‐‐EV03 Kraft Pulping: Evaporator LVHC INC_LK115 Kraft 115‐‐CO03 Kraft Pulping: Evaporator LVHC INC_LK117 Kraft 117‐‐P36

Kraft Pulping: Digester LVHC; Kraft Pulping:

Turpentine LVHC; Kraft Pulping: Evaporator

LVHC; Kraft Pulping: BL Tanks HVLC; Kraft

Pulping: Knotter; Kraft Pulping: HVLC INC_LK NCG Venting to Atmosphere

Combustion Temperature (>

1200 F)

124 Kraft 124‐‐004 Kraft Pulping: LVHC INC_LK pH, gas & liquid flow rate, d/p

140 Kraft 140‐‐Other ‐Lime Kiln Lime Kiln INC_LK

Boiler, Recovery Furnace or

lime kiln into the primary fuel

or into the flame zone.

142 Kraft, Secondary 142‐‐P6025 Kraft Pulping: LVHC INC_LK

other (introduce gas stream

with the primary fuel into the

flame zone of the kiln)

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

142 Kraft, Secondary 142‐‐P6009 Kraft Pulping: LVHC INC_LK

other (introduce gas stream

with the primary fuel into the

flame zone of the kiln)

149 Kraft 149‐‐P001

Kraft Pulping: Evaporator LVHC; Kraft

Pulping: Digester LVHC; Kraft Pulping: LVHC;

Condensate Stripper INC_LK NA

Hot end temperature, cold end

temperature, gas flow, kiln draft

151 Kraft 151‐‐CD‐CP002

Causticizing: Misc; Condensate Stripper;

Kraft Pulping: BL Tanks HVLC; Kraft Pulping:

Digester LVHC; Kraft Pulping: Evaporator

LVHC; Kraft Pulping: HVLC; Kraft Pulping:LVHC; Kraft Pulping: Turpentine LVHC; Kraft

Pulping: Washing; Wastewater (Kraft) INC_LK

151 Kraft 151‐‐CD‐CP001

Causticizing: Misc; Condensate Stripper;

Kraft Pulping: BL Tanks HVLC; Kraft Pulping:

Digester LVHC; Kraft Pulping: Evaporator

LVHC; Kraft Pulping: HVLC; Kraft Pulping:

LVHC; Kraft Pulping: Turpentine LVHC; Kraft

Pulping: Washing; Wastewater (Kraft) INC_LK

152 Kraft 152‐‐08 Lime Kiln INC_LK

combustion chamber

temperature

154 Kraft 154‐‐P30 Lime Kiln INC_LK None None

155 Kraft, Mechanical 155‐‐LIME KILN Lime Kiln INC_LK

180 Kraft, Secondary 180‐‐L002

Condensate Stripper; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC; KraftPulping: Turpentine LVHC; Storage Tanks ‐ 

Methanol INC_LK

180 Kraft, Secondary 180‐‐L001

Condensate Stripper; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC; Kraft

Pulping: Turpentine LVHC; Storage Tanks ‐ 

Methanol INC_LK

183 Kraft 183‐‐Incin1

Kraft Pulping: HVLC; Kraft Pulping: LVHC;

Kraft Pulping: Digester LVHC; Kraft Pulping:

Evaporator LVHC; Kraft Pulping: Washing;

Kraft Pulping: Knotter INC_LK

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

185 Kraft 185‐‐07 Lime Kiln INC_LK188 Kraft, Secondary, SemiChem 188‐‐LK1

Semichem Pulping; Kraft Pulping: Evaporator

LVHC; Kraft Pulping: Digester LVHC; Kraft

Pulping: Turpentine LVHC; Fugitive

Emissions ‐ Misc INC_LK

188 Kraft, Secondary, SemiChem 188‐‐LK2

Kraft Pulping: Digester LVHC; Kraft Pulping:

Evaporator LVHC; Kraft Pulping: Turpentine

LVHC; Semichem Pulping INC_LK

199 Kraft 199‐‐010

Kraft Pulping: HVLC; Kraft Pulping: LVHC;

Kraft Pulping: Digester LVHC; Kraft Pulping:

Evaporator LVHC; Kraft Pulping:

Knotter/Screen; Condensate Stripper INC_LK

CNCG and DNCG Bypass Vent

Valve Positions

Hot End Combustion

Temperature (>1250 deg F)

205 Kraft, Secondary 205‐‐008

Kraft Pulping: Evaporator LVHC; Kraft

Pulping: LVHC; Kraft Pulping: Digester LVHC INC_LK other (bypass valve position)

Kiln hot end temperature >

1600 degrees F

226 Kraft, Secondary, SemiChem 226‐‐07

Condensate Stripper; Condenser; Kraft

Pulping: Digester LVHC; Kraft Pulping:

Evaporator LVHC; Kraft Pulping: HVLC; Kraft

Pulping: LVHC; Kraft Pulping: Turpentine

LVHC; Semichem Pulping INC_LK

combustion chamber

temperature

226 Kraft, Secondary, SemiChem 226‐‐06

Semichem Pulping; Condensate Stripper;Condenser; Kraft Pulping: Digester LVHC;

Kraft Pulping: HVLC; Kraft Pulping: LVHC INC_LK

combustion chamber

temperature

240 Kraft 240‐‐NCC1, CA81

Condensate Stripper; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC; Kraft

Pulping: NCG System; Kraft Pulping:

Turpentine LVHC INC_LK other (flame scanner)

242 Kraft 242‐‐RC‐6 Condensate Stripper INC_LK temperature (hot end)

340 Kraft, Secondary 340‐‐SN‐08 Kraft Pulping: LVHC INC_LK

610 Kraft, Mechanical 610‐‐7 Lime Kiln INC_LK

combustion temperaturewhen in no load

610 Kraft, Mechanical 610‐‐8 Lime Kiln INC_LK

combustion temperaturewhen in no load

613 Kraft, Secondary 613‐‐009 Kraft Pulping: LVHC; Kraft Pulping: HVLC INC_LK

615 Kraft 615‐‐EU ID 21

Kraft Pulping: LVHC; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC INC_LK lvhc gas flow, lime mud

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

208228535 Kraft(1) 208228535‐‐X003

Kraft Pulping: Digester LVHC; Kraft Pulping:

LVHC; Kraft Pulping: Evaporator LVHC INC_LK

LVHC system bypass control

valve position

Kiln hot end combustion

temperature (1600 deg F)

208228535 Kraft(1) 208228535‐‐X014

Kraft Pulping: Evaporator LVHC; Kraft

Pulping: LVHC INC_LK

LVHC system bypass control

valve position

Kiln hot end combustion

temperature (1800 deg F)

107 Kraft 107‐‐08‐P1

Kraft Pulping: Washing; Kraft Pulping: O2Delig HVLC; Kraft Pulping: Digester LVHC;

Kraft Pulping: HVLC INC_RF TRS monitoring

155 Kraft, Mechanical

155‐‐RECOVERY FURNACE/RFESP Kraft Pulping: HVLC INC_RF

180 Kraft, Secondary 180‐‐D001

Storage Tanks ‐ Methanol; Kraft Pulping:

Digester LVHC; Kraft Pulping: Turpentine

LVHC; Kraft Pulping: Evaporator LVHC;Condensate Stripper INC_RF

199 Kraft 199‐‐001

Condensate Stripper; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC; KraftPulping: HVLC; Kraft Pulping:Knotter/Screen; Kraft Pulping: LVHC INC_RF

CNCG and DNCG Bypass Vent

Valve Positions NA

615 Kraft 615‐‐EU ID 24

Kraft Pulping: LVHC; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC INC_RF lvhc gas flow, steam flow

615 Kraft 615‐‐EU ID 24

Kraft Pulping: HVLC; Kraft Pulping: BL Tanks

HVLC; Kraft Pulping: Decker; Kraft Pulping:Digester LVHC; Kraft Pulping: Knotter; Kraft

Pulping: Washing INC_RF hvlc gas flow, steam flow

617 Kraft 617‐‐B14 Kraft Pulping: HVLC INC_RF

208228535 Kraft(1) 208228535‐‐X001 Kraft Pulping: Washing INC_RF

HVLC system bypass control

valve position

208228535 Kraft(1) 208228535‐‐X012 Kraft Pulping: O2 Delig HVLC INC_RF

HVLC system bypass control

valve position

185 Kraft 185‐‐02 Kraft Pulping: HVLC; Salt Cake Tank OTH_RF

118 Mechanical 118‐‐CE012

Mechanical Pulping; Incineration Control

Device RTO

118 Mechanical 118‐‐CE012

Mechanical Pulping; Incineration Control

Device RTO

166 Kraft 166‐‐BLOX Scrub, BLOX WESP

BLO; Kraft Pulping: HVLC; Kraft Pulping:LVHC; Condensate Stripper RTO Temperature

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

206 Kraft 206‐‐S‐71 BLO RTO temperature

229 Mechanical 229‐‐CE 027, CE 024 Mechanical Pulping RTO

229 Mechanical 229‐‐CE 027, CE 024 Mechanical Pulping RTO Temperature

610 Kraft, Mechanical 610‐‐17

Kraft Pulping: BL Tanks HVLC; Kraft Pulping:

Washing; Kraft Pulping: O2 Delig HVLC; Kraft

Pulping: Digester LVHC; Kraft Pulping:

Knotter/Screen; Kraft Pulping: HVLC RTO combustion temperature

368611 Mechanical, Secondary 368611‐‐CE001‐RTO Incineration Control Device RTO

combustion chamber

temperature, suction

pressure, inlet temperature,

outlet temperature, inlet

airflow

100 Kraft 100‐‐NCG1 Kraft Pulping: LVHC; Kraft Pulping: HVLC TO Combustion Temperature NA102 Kraft 102‐‐NCG‐TO Kraft Pulping: HVLC TO

combustion chamber

temperature

104 Kraft, SemiChem 104‐‐EUG F4a/F4b Incineration Control Device TO

combustion chamber

temperature

106 Soda 106‐‐TO Incineration Control Device TO temperature NA

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

109 Kraft 109‐‐B‐900

Kraft Pulping: BL Tanks HVLC; Kraft Pulping:

Evaporator LVHC; Kraft Misc TO

109 Kraft 109‐‐INCR01

Kraft Pulping: NCG System; Kraft Pulping:

Washing; Kraft Pulping: Evaporator LVHC;

Condensate Stripper; Kraft Pulping: BL Tanks

HVLC; Kraft Misc; Incineration Control

Device TO

temperature (firebox outlettemperature)

116 Kraft, Secondary, SemiChem 116‐‐NCG1 Incineration Control Device TO Combustion Temperature NA

127 Kraft, Secondary 127‐‐E200A

SEE RTI NOTE ‐ Condensate Stripper;Incineration Control Device; Kraft Pulping:

Digester LVHC; Kraft Pulping: Evaporator

LVHC; Kraft Pulping: LVHC; Kraft Pulping:

Turpentine LVHC TO Combustion temperature

130 Kraft 130‐‐39TO Kraft Pulping: Turpentine LVHC TO

temperature (combustionchamber) NA

136 Kraft 136‐‐CE 022, CE 023

Condensate Stripper;Kraft Pulping:Evaporator LVHC;Kraft Pulping:Washing;Kraft Pulping: BL Tanks HVLC;Kraft

Pulping: Digester LVHC;Kraft Pulping:Evaporator LVHC;Kraft Pulping:Knotter/Screen;Kraft Pulping: O2 Delig

HVLC;Pulp Storage;Salt Cake Tank;Soap TO Temperature NA

137 Kraft 137‐‐PC(106) & PC(106)S Incineration Control Device TO temperature

138 Kraft 138‐‐NCGTO1

Incineration Control Device; Kraft Pulping:

Digester LVHC; Kraft Pulping: Evaporator

LVHC; Kraft Pulping: Turpentine LVHC; Kraft

Pulping: LVHC TO

combustion chamber

temperature

146 Kraft 146‐‐LVHC1

Kraft Pulping: Digester LVHC; Kraft Pulping:

Evaporator LVHC; Kraft Pulping: Turpentine

LVHC; Causticizing: Misc TO temperature NA

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

146 Kraft 146‐‐SOG1 Condensate Stripper TO temperature NA

146 Kraft 146‐‐HVLC1

Kraft Pulping: O2 Delig HVLC; Kraft Pulping:

Washing TO temperature NA

147 Kraft 147‐‐C‐INC Incineration Control Device TO NA NA

147 Kraft 147‐‐C‐016 Incineration Control Device TO NA NA

148 Kraft, Secondary 148‐‐044 Incineration Control Device TO Combustion temperature NA

149 Kraft 149‐‐NC‐101

Kraft Pulping: Evaporator LVHC; Kraft

Pulping: Digester LVHC TO temperature (firebox)

Stack O2 (2‐3%),

pressures/flows of NCG streams

to the incinerator (SOG 2.0 psi,

blow heat 600‐1000 acfm,

continuous 500‐700 acfm),furnace pressure (<0.5 in)

155 Kraft, Mechanical

155‐‐THERMAL OXIDIZER/TO

SCRUBBER

Kraft Pulping: Digester LVHC; Kraft Pulping:

Evaporator LVHC; Kraft Pulping: LVHC;

Condensate Stripper; Kraft Pulping:Turpentine LVHC; Incineration Control

Device TO

combustion chamber

temperature

162 Kraft 162‐‐331A

Incineration Control Device; Kraft Pulping:

NCG System TO Incinerator Temperature NA

165 Kraft 165‐‐000037, NCG Kraft Pulping: LVHC TO

Combustion chambertemperature, excess O2 in

exhaust

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

169 Kraft, SemiChem 169‐‐09 Incineration Control Device TO

combustion chamber

temperature

169 Kraft, SemiChem 169‐‐J0 Kraft Pulping: HVLC TO

combustion chamber

temperature

171 Kraft 171‐‐043 Incineration Control Device TO

limit operaiton to no more than

200 hrs, incinerate NCG gases at

1,200 def F for at least 0.5

seconds

172 Kraft, Secondary 172‐‐LV01 IN01

Kraft Pulping: Digester LVHC; Kraft Pulping:

Evaporator LVHC; Kraft Pulping: Turpentine

LVHC TO

combustion chamber

temperature NA

178 Kraft 178‐‐23C006

Kraft Pulping: Evaporator LVHC; Kraft

Pulping: Digester LVHC; Kraft Pulping:Turpentine LVHC; Kraft Pulping: NCG

System; Wood Handling: Digester chip bin;

Condensate Stripper; Kraft Pulping: O2 DeligHVLC TO Temperature in firebox NA

189 Kraft 189‐‐SN83, SO2Scr, CANDLE

Condensate Stripper; Incineration Control

Device; Kraft Pulping: Decker; Kraft Pulping:

Digester LVHC; Kraft Pulping: Evaporator

LVHC; Kraft Pulping: Knotter/Screen; KraftPulping: Turpentine LVHC; Kraft Pulping:Washing; Storage Tanks ‐ Methanol TO

temperature (specify if inlet,

outlet, bed, or other

temperature)

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

190 Kraft, Secondary, SemiChem 190‐‐R425a Condensate Stripper TO temperature (back end)

207 Kraft 207‐‐001 Incineration Control Device TO

temperature where gases

injected

Natural gas flow 80‐300 scfm,

natural gas pressure 30‐35 psi,

O2 5%, exit temperature 600

deg F

226 Kraft, Secondary, SemiChem 226‐‐10 Incineration Control Device TO

combustion chamber

temperature

240 Kraft 240‐‐NCC1, CA81

Condensate Stripper; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC; KraftPulping: NCG System; Kraft Pulping:Turpentine LVHC TO

combustion chamber

temperature

242 Kraft 242‐‐RC‐22

Kraft Pulping: NCG System; Condensate

Stripper; Storage Tanks ‐ Methanol TO

combustion chamber

temperature, Scrubber pH

243 Kraft 243‐‐R480 Incineration Control Device TO temperature (incineration)

243 Kraft 243‐‐R488

Kraft Pulping: Turpentine LVHC; Kraft

Pulping: NCG System; Kraft Pulping: Digester

LVHC; Storage Tanks ‐ Methanol; Kraft

Pulping: Evaporator LVHC; CondensateStripper TO temperature (incineration)

340 Kraft, Secondary 340‐‐SN‐22 Incineration Control Device TO

525 Kraft

525‐‐NCGSCB, EU37, SO2SCB,

CME

Condensate Stripper; Incineration Control

Device; Kraft Pulping: Digester LVHC; Kraft

Pulping: Evaporator LVHC; Kraft Pulping:LVHC; Kraft Pulping: NCG System; KraftPulping: Turpentine LVHC; Tall Oil TO temperature (firebox) oxygen, flame status

208228535 Kraft(1) 208228535‐‐015 Incineration Control Device TO Combustion zone temperature

107 Kraft 107‐‐16‐P4

Kraft Pulping: Evaporator LVHC; Kraft

Pulping: BL Tanks HVLC; Kraft Pulping:

Digester LVHC; Kraft Pulping: HVLC; Kraft

Pulping: Turpentine LVHC; Kraft Pulping:LVHC; Soap; Condensate Stripper; Salt Cake

Tank; Incineration Control Device TO/SCBR

Scrubbing liquid recirculationflow rate (>= 100 gpm),

scrubbing liquid pH (>= 9)

112 Kraft 112‐‐NCG Incinerator

Condensate Stripper; Incineration Control

Device; Kraft Pulping: Digester LVHC; Kraft

Pulping: Evaporator LVHC; Kraft Pulping:

Turpentine LVHC; Lime Kiln; Wood Handling:

Digester chip bin TO/SCBR

combustion chamber

temperature scrubber liquid flow, pH

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI Code Pulp Type RTI_APCDID RTI_EmissionUnitType RTI_APCDType Parameter_Continuous Parameter_Other

613 Kraft, Secondary 613‐‐058 Incineration Control Device TO/SCBR

Bed Temperatures, CausticFlow

Natural Gas Flow approximately

60 SCFM

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

109‐‐LK1128‐‐B006145‐‐Other ‐ (SOG002‐01C)

145‐‐Other ‐ (NCG001‐01C)

164‐‐LVHC NCG Incineration in

either Lime Kiln (primary) or No.

11 Boiler (backup)

196‐‐LVHC196‐‐SOG198‐‐014, 014_S

203‐‐Lkiln203‐‐HogBlr114‐‐U400115‐‐SS01115‐‐WS01‐4

115‐‐WS01‐5

115‐‐Stripper Pre‐heater

115‐‐Stripper Condenser124‐‐016140‐‐Other ‐ #1 Power Boiler

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

24 24

Control device is started up and meets required

operating parameter limits before emission unit is

started up. Unit is not started until control is steady state

When mfger's warmup requirements are

complete and the unit is steady state

N/A

Boiler is only source of steam for plant operation.

Since steam is required to produce HVLC, there is

nothing to control until boiler becomes fully

operational. No CEMS None when steam flow is at 175,000

1 1

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

1 1

Control device cannot be started prior to

emission unit starting up due to safety issue or

risk of property damage. {Explain}

Collection system must vent to purge O2 to avoid

explosive gas mixture.

NA NA NA NA NA6 6

NCG's switched to No. 2 Lime Kiln while No. 2

Power Boiler shutdown

Bring No. 2 Power Boiler to 1200F before routing

NCG or SOG to boiler. Combustion temperature reaches 1200F

6 6

SOG's switched to No. 2 Lime Kiln while No. 2

Power Boiler shutdown

Bring No. 2 Power Boiler to 1200F before routing

NCG or SOG to boiler. Combustion temperature reaches 1200F

11 11

Control device is started up and meets required

operating parameter limits before emission unit is

started up. combustion temperature

Control device i(or backup device) is operational

before process startup

combustion temperature within normal operati

range, scrubber operating normally, no alarms,

no rupture disk failures

12 12

NCG emission units will not be started up until

incineration points (hog or kiln) are running and

can burn NCG gas.

The applicable emission and parameter limits are

expected to be met during startup

flame pyrometer‐ detected flame temperature

has to be > 1600 degrees to accept NCG’s

5 5

NCG emission units will not be started up until

incineration points (hog or kiln) are running and

can burn NCG gas.

The applicable emission and parameter limits are

expected to be met during startup

flame pyrometer‐ detected flame temperature

has to be > 1600 degrees to accept NCG’s

NA

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

control device is operating prior to emission unit

start up.

Boiler operating at 60,000 lbs/hr and differentia

across the NCG nozzle is greater than 2 inches

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

145‐‐Boiler (PR005)

145‐‐Boiler (PR004)

152‐‐09154‐‐B21154‐‐B20173‐‐PB1185‐‐09187‐‐1187‐‐2201‐‐SR0030201‐‐SR0002205‐‐011245‐‐WFB2245‐‐WFB1245‐‐WFB2245‐‐WFB1340‐‐SN‐02340‐‐SN‐04

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

8 8

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup verify HVLC vent and/or flare is closed

Boiler producing steam using primary fuel and

interlocks have been satisfied

8 8

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup verify HVLC vent and/or flare is closed

Boiler producing steam using primary fuel and

interlocks have been satisfied

0.5 0.5

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

equipment vented to the HVLC and LVHC systems

may not start‐up if the gasses are not routed to

either the primary or backup control device. Steam flow reaches 90,000 lb/hr

7 7

Control device is started up and meets required

operating parameter limits before emission unit is

started up. NA Process is not started until scrubber is running

Boiler achieves 120,000 klbs steaming rate or

boiler temperature of 1700 deg F is achieved

7 7

Control device is started up and meets required

operating parameter limits before emission unit is

started up. NA Process is not started until scrubber is running

Boiler achieves 120,000 klbs steaming rate or

boiler temperature of 1700 deg F is achieved

2 2

Control device is started up and meets required

operating parameter limits before emission unit is

started up. NA

Control device meets LVHC and SOG burn

permissives before emission sources are started

up

Bark transfer to boiler commences and steam

production rate > 50,000 lb/hr

2 2

Control device is started up and meets required

operating parameter limits before emission unit is

started up. NA

Control device meets LVHC and SOG burn

permissives before emission sources are started

up

Bark transfer to boiler commences and steam

production rate > 50,000 lb/hr

2 2

Control device is started up and meets required

operating parameter limits before emission unit is

started up. Steam production rate reaches 75,000 lbs/hr

4 4

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

Route LVHC & HVLC gases to primary control

device (WFB2) steam flow rate greater than 25000 lbs/hr

4 4

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

Route LVHC & HVLC gases to backup control

device (WFB1) steam flow rate greater than 25000 lbs/hr

4 4

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

Route LVHC & HVLC gases to primary control

device (WFB2) steam flow rate greater than 25000 lbs/hr

4 4

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

Route LVHC & HVLC gases to backup control

device (WFB1) steam flow rate greater than 25000 lbs/hr

2 2

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

4 4

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

606‐‐LVHC617‐‐B20617‐‐B21617‐‐B24103‐‐WLS, G‐165

107‐‐11‐P14

115‐‐KD02115‐‐KD06115‐‐KD06115‐‐KD02115‐‐EV03115‐‐CO03117‐‐P36124‐‐004140‐‐Other ‐Lime Kiln

142‐‐P6025

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

1 1

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

15 15

Lime kiln is operating prior to start up of the

systems that produce LVHC and SOG.

The applicable emission and parameter limits are

expected to be met during startup

Kiln is stable and all safety interlocks are met

before LVHC NCG’s and SOG’s are incinerated

For a cold startup, the kiln is operating at a stab

rate not < 300 gpm of lime mud, incineration

interlocks are met and the manual switch is in th

"Accept" mode. The 300 gpm mud flow could be

less and depends upon the number of LVHC

sources being colle

26 2636 36

Control device needs to warm to a minimum

temperature before collection system NCGs can

be burned. Combustion and treatment of LVHC & HVLC

Bring P36 temperature to at least 1200F before

routing NCGs to P36 ‐ begin warming process

before emission unit is started.

Start‐Up ends when NCGs are able to be

introduced into P36 to be burned.

n/astartedprior toemissionunit startup

Control device must be in operation before and

after EU startup/shutdown

need production levels of gas flow to attain target

d/p None ‐ control device started before EU attainment of operating limits

NA

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

control device is operating prior to emission unit

start up.

permissive for temperature (1400 F) met and ai

flow rate in the kiln is greater than 102,000 scfh

and the fan is running.

24 24

Control device is started up and meets required

operating parameter limits before emission unit is

started up. NA

NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

Adequate vacuum is maintained at essential

inlets and outlets of the LVHC system for 60

minutes.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

142‐‐P6009149‐‐P001151‐‐CD‐CP002151‐‐CD‐CP001152‐‐08154‐‐P30155‐‐LIME KILN

180‐‐L002180‐‐L001183‐‐Incin1

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

24 24

Control device is started up and meets required

operating parameter limits before emission unit is

started up. NA

NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

Adequate vacuum is maintained at essential

inlets and outlets of the LVHC system for 60

minutes.

24 24

Primary control device (NC‐101) used during Lime

Kiln startup or shutdown

The applicable emission and parameter limits are

expected to be met during startup

Primary control device (NC‐101) used during Lime

Kiln startup or shutdown

Total Mud Flow to Kiln > 400 lb/min for 2 hrs an

Gas Flow to Kiln > 51 MMscfh

15 15

Kiln firing end temperature is above 1200F and

NCGs are being collected

0.3 0.3

Kiln firing end temperature is above 1200F and

NCGs are being collected

8 8

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

equipment vented to the HVLC and LVHC systems

may not start‐up if the gasses are not routed to

either the primary or backup control device. Combustion temperature reaches 1200F

30 30

Control device is started up and meets required

operating parameter limits before emission unit is

started up. NA Process is not started until scrubber is running

The lime kiln would only be used if neither boile

was available.

12 12

from cold startup, the combustion chamber

temperature needs to be reamped up slowly as

not to damage the refractory

The applicable emission and parameter limits are

expected to be met during startup

LVHC systems not fed to combustion chanber

until temperature setpoint can be met Combustion temperature reaches 1200F

8 8

Lime Kiln is operating normally when LVHC gases

are introduced

No continuous parameter monitoring required for

Lime Kiln operation Usage of lime kiln wet scrubber and TRS scrubber

Infeed temperature 1300 degrees and mud on

kiln; introduction of LVHC gases

8 8

Lime Kiln is operating normally when LVHC gases

are introduced

No continuous parameter monitoring required for

Lime Kiln operation Usage of lime kiln wet scrubber and TRS scrubber

Infeed temperature 1300 degrees and mud on

kiln; introduction of LVHC gases

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

185‐‐07188‐‐LK1188‐‐LK2199‐‐010205‐‐008226‐‐07226‐‐06240‐‐NCC1, CA81242‐‐RC‐6340‐‐SN‐08610‐‐7610‐‐8613‐‐009615‐‐EU ID 21

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

24 24

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup Lime mud is introduced to wet end of kiln

24 24

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup Lime mud is introduced to wet end of kiln

18 18

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup NA

Kiln reaches proper hot end temperature and

lime mud has been fed to kiln for at least 2 hour

18 18

Control device is started up and meets required

operating parameter limits before emission unit is

started up. Combustion temperature reaches 1200 degrees 

12 12

Control device is started up and meets required

operating parameter limits before gases are sent

to device. tempurature set point

bring kiln to temperature before routing NCG or

SOG to the kiln Combustion temperature reaches 1350F

12 12

Control device is started up and meets required

operating parameter limits before gases are sent

to device. tempurature set point

bring kiln to temperature before routing NCG or

SOG to the kiln Combustion temperature reaches 1450F

> 20 hours

if cold

startupfromplanned

outage 20

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Lime Kiln meets minimum back end temperatur

requirements

temperature set point

interlocks prevent routing NCG or SOG to the kiln

before it is at operating temperature. Lime mud to the kiln

2 2

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

8.33333333 0.08333333

Control device is started up and meets required

operating parameter limits before emission unit is

started up. Combustion temperature reaches 1600F

8.33333333 0.08333333

Control device is started up and meets required

operating parameter limits before emission unit is

started up. Combustion temperature reaches 1600F

2 2

When we start up the mill after a cold shutdown,

the oxidizer is started up prior to any other mill

process. That way, we always have an

incineration source ready when we start up our

emission sources. Once the kiln is started up and

is stable, we switc Mud Flow to Kiln

36 ‐ 42 42 Normal operations prior to LVHC introduction

cannot introduce lvhc gas until normal operating

load No lvhc gas sources are allowed to start up Normal operations with lime mud feed

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

208228535‐‐X003208228535‐‐X014107‐‐08‐P1

155‐‐RECOVERY FURNACE/RF

ESP180‐‐D001199‐‐001615‐‐EU ID 24

615‐‐EU ID 24

617‐‐B14208228535‐‐X001208228535‐‐X012185‐‐02118‐‐CE012118‐‐CE012166‐‐BLOX Scrub, BLOX WESP

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

23 23

Control device is started up and meets required

operating parameter limits before combustion of

LVHC gases commences. If sources are started

prior to control device, then LVHC gases are

burned in the backup control device (emission

unit 015).

The applicable emission and parameter limits are

expected to be met during startup

LVHC gases are burned in backup incinerator

(emission unit 015) during kiln startup Continuous lime mud feed to kiln for 3 hours

23 23

Control device is started up and meets required

operating parameter limits before combustion of

LVHC gases commences. If sources are started

prior to control device, then LVHC gases are

burned in the backup control device (emission

unit 015).

The applicable emission and parameter limits are

expected to be met during startup

LVHC gases are burned in backup incinerator

(emission unit 015) during kiln startup Continuous lime mud feed to kiln for 3 hours

10 104 4

secondary air fan running and furnace

permissives satisfied prior to feeding HVLC stream

and brownstock washer operation

The applicable emission and parameter limits are

expected to be met during startup

7 7

Recovery Boiler is operating normally when LVHC

gases are introduced

No continuous parameter monitoring required for

Recovery Boiler operation Usage of recovery boiler ESP and CEMS

main 850psi header pressure obtained at

temperature of 825 deg F, superheaters cleared

4 4

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup NA

Recovery furnace completes three hours of

successful combustion of black liquor followingstartup on fuel oil

8 8 stable steam load before LVHC introduction cannot introduce lvhc gas until stable steam load No lvhc gas sources are allowed to start up stable steam load

7 7 stable steam load prior to HVLC introduction cannot introduce hvlc gas until stable steam load No hvlc gas sources are allowed to start up stable steam load

12 12

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup 4 black liquor guns are in service

12 12

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup 4 black liquor guns are in service

2‐5

The control device is started up and meets

required operating parameter limits before

emission unit is started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).

There are no emissions during startup since the

control device

Startup ends when the parameter limits are

achieved

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

206‐‐S‐71

229‐‐CE 027, CE 024

229‐‐CE 027, CE 024

610‐‐17368611‐‐CE001‐RTO100‐‐NCG1102‐‐NCG‐TO104‐‐EUG F4a/F4b106‐‐TO

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

4 4

Control device is operating at firebox

temperature above 1450 prior to introducing

HVLC gases minimum firebox temperature

bring RTO temperature above minimum

operating range prior to introducing gases

When the RTO has reached a stable operating

temperature above the minimum established

operating range.

12 12 Combustion temperature reaches 1587F

6 6 Combustion temperature reaches 1400F

6 6

Control device must be up to 1500 before HVLC

gases are sent to the RTO. Combustion temperature reaches 1500F

0.75 0.75

Control device is started up and meets required

operating parameter limits before emission unit is

started up. combustion chamber temperature set point

Combustion chamber temperature reaches 146

and damper directs process air to RTO

~ 12 hrs 12

The control device is started up and meets

required operating parameter limits before

emission unit is started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).

There are no emissions during startup since the

control device

Startup ends when the combustion temperature

limit is achieved

3 3

Control device is started up and meets required

operating parameter limits before emission unit is

started up. However, the device may not be able

to maintain operating temperature limits when

resuming control of HVLC vent gas during first 12‐

48 hours af temperature set point LVHC‐S to the Lime Kiln

Combustion temperature reaches 1500F and is

able to maintain setpoint temperature while

firing HVLC gases.

4 4

The control device is started up and meets

required operating parameter limits before

emission unit is started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).

There are no emissions during startup since the

control device

Startup ends when the combustion temperature

limit is achieved

0.05 0.05

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Temperature fluctuates during startup of the

control device and during startup of the NCG

system as gases are introduced into the control

device.

NCG are not introduced into the control device

until a minimum temperature is met. Combustion temperature reaches 1350F

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

109‐‐B‐900

109‐‐INCR01116‐‐NCG1127‐‐E200A130‐‐39TO136‐‐CE 022, CE 023

137‐‐PC(106) & PC(106)S

138‐‐NCGTO1146‐‐LVHC1

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

7 7

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Emission Unit is not started until control is steady

state

When mfger's warmup requirements are

complete and the unit is steady state (>1200oF)

12 12

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Temperature is at least 1450 befoe routine NCG

or SOG to incinerator

When mfger's warmup requirements are

complete and the unit is steady state

~16 16

The control device is started up and meets

required operating parameter limits before

emission unit is started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).

There are no emissions during startup since the

control device

Startup ends when the combustion temperature

limit is achieved

0.333 0.333

Control device is started up and meets required

operating parameter limits before emission unit is

started up. temperature set point

bring thermal oxidizer temperature to 1500F

before routing NCG or SOG to the thermal

oxidizer Combustion temperature reaches 1500F

HotStartup: 1

Hr; ColdStartup:16 Hrs

LVHC NCGs are only valved to Thermal Oxidizer

when unit has achieved minimum operating

temperature and SO2 Scrubber is operational. Combustion temperature of 1600°F

The sources feeding into the LVHC system are not

started up until the thermal oxidizer is at its

target combustion temperature of 1600 °F

Startup ends when the operating parameter

limits are achieved

24 24 Independent temperature Combust NCGs in power boilers Achieving firebox temperature >= 1500 oF

20 20

Control device is started up and meets required

operating parameter limits before emission unit is

started up. temperature set point delay startup

Steam flow to the LVHC ejectors and NCG

Incinerator temperature > 1324 deg.F

24 24

Control device is started up and meets required

operating parameter limits before emission unit is

started up. If the NCG Thermal Oxidizer is

unavailable during startup of the evaporators or

digesters, the NCGs are routed to the Lime Kiln

for incineratio temperature set point

NCGs routed to Lime Kiln during startup process if

NCG sources are operated prior to completion of

startup of NCG Thermal Oxidizer.

Startup ends when the combustion temperture

reaches 1250F.

0.3 0.3

The process units exhausting to LVHC system are

not allowed to begin operation until the NCG

collection system and combustion device are in

service.

Temperature set point must be met prior to

startup

The process units exhausting to LVHC system are

not allowed to begin operation until the NCG

collection system and combustion device are in

service.

NCG system and combustion device remain in

service until system is completely off‐line

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

146‐‐SOG1146‐‐HVLC1147‐‐C‐INC

147‐‐C‐016

148‐‐044149‐‐NC‐101

155‐‐THERMAL OXIDIZER/TO

SCRUBBER162‐‐331A165‐‐000037, NCG

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

0.25 0.25

The unit is not allowed to begin operation until

the NCG collection system and combustion device

are in service.

Temperature set point must be met prior to

startup

The unit is not allowed to begin operation until

the NCG collection system and combustion device

are in service.

NCG system and combustion device remain in

service until system is completely off‐line

0.25 0.25

The unit is not allowed to begin operation until

the NCG collection system and combustion device

are in service.

Negative pressure at all hood openings cannot be

maintained

The unit is not allowed to begin operation until

the NCG collection system and combustion device

are in service.

Start‐up ends 15 minutes after startup of the

knotter feed pump

NA NA NA NA NANA NA NA NA NA10 10

Must meet Title V parameters before adding any

fuel to emission unit to go through the control

device

Control device parameters are met before

emission unit is brought up

Control device parameters are met before

emission unit is brought up

Control device parameters are met before

emission unit is brought up

10 10

Backup control device (P001) used during

Thermal Oxidizer startup or shutdown

The applicable emission and parameter limits are

expected to be met during startup

Backup control device (P001) used during

Thermal Oxidizer startup or shutdown Warm up curve complete

12 12

from cold startup, the combustion chamber

temperature needs to be reamped up slowly as

not to damage the refractory

The applicable emission and parameter limits are

expected to be met during startup

LVHC systems not fed to combustion chanber

until temperature setpoint can be met Combustion temperature reaches 1350F

1 to 2 hours

The control device is started up and meets

required operating parameter limits before

emission unit is started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).

There are no emissions during startup since the

control device

Startup ends when the parameter limits are

achieved

12 12

The control device is started up and meets

required operating parameter limits before

emission unit is started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).

There are no emissions during startup since the

control device

Startup ends when the combustion temperature

limit is achieved

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

169‐‐09169‐‐J0171‐‐043172‐‐LV01 IN01

178‐‐23C006189‐‐SN83, SO2Scr, CANDLE

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

0.75 0.75

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).

There are no emissions during startup since the

control device

When operating temperature is achieved in the

incinerator.

0.5 0.5

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., HVLC systems).

There are no emissions during startup since the

control device

When an operational temperature is achieved in

the HVLC incinerator.

0.1 0.1

Control device cannot be started prior to

emission unit starting up due to safety issue or

risk of property damage. Startup commenes

upon detection of primiary treatment device

trouble.

LVHC gases are vented during change over from

primary to secondary treatment device.

Quick startup; secondary treatment device on line

prior to any "planned" treatment device down

time.

Startup ends when the accept/vent station bloc

valves on the flare are turned to accept LVHC

gases.

Approximately 2 hrs 2

The control device is started up and meets

required operating parameter limits before

emission unit is started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).

There are no emissions during startup since the

control device

Startup ends when the combustion temperature

limit is achieved

13 hr 13

The control device is started up and meets

required operating parameter limits before

emission unit is started up.

Temperature is transient in nature (i.e., changes

as startup progresses)

There are no HAP emissions as a result of starting

up a control device. Control devices do not

generate HAPS. HAPS are only generated by the

emission units or sources (i.e., LVHC systems).

There are no emissions during startup since the

control device

Startup ends when the combustion temperature

limit is achieved

0.15 0.15

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup

Per the SSM Plan, at 1400 F. Startup Note: The

operator will insure that certain operating

conditions are reached before the Incinerator is

ready to accept vent gases. The operator will also

insure that the LVHC and HVLC gases are

introduced to the Incin

Per the SSM Plan, collection of HVLC/LVHC

System. Verify the Incinerator temperature has

reached 1400°F. Ignite the Incinerator per mill

standard operating procedures. Insure theIncinerator has reached the minimum

temperature for ignition as defined i

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

190‐‐R425a207‐‐001226‐‐10240‐‐NCC1, CA81242‐‐RC‐22243‐‐R480243‐‐R488340‐‐SN‐22525‐‐NCGSCB, EU37, SO2SCB,

CME208228535‐‐015107‐‐16‐P4

112‐‐NCG Incinerator

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

2 2

Pollution abatement equipment must be

operational prior to firing NCGs or SOGs. NCGs or

SOGs are not admitted to the unit until minimum

temperature is reached.

The applicable emission and parameter limits are

expected to be met during startup

NCGs or SOGs are not sent to the unit during

startup and startup is on natural gas. Meet minimum firing temperature.

0.25 0.25

Control device cannot be started prior to

emission unit starting up due to safety issue or

risk of property damage. {Explain}

The applicable emission and parameter limits are

expected to be met during startup NA

Temp >1200 def F and process gasses routed to

device

12 12

Control device is started up and meets required

operating parameter limits before gases are sent

to device. tempurature set point

bring TO temperature to 1400F before routing

NCG or SOG to the TO Any thermal oxidizer burn valve is open

UK

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

Startup ends when minimum scrubber flow

established

8 8 temperature set point

interlocks prevent routing NCG or SOG to the TO

before it is at operating temperature. Combustion temperature reaches 1450F

36 36

Refractory needs to come up to proper operating

temperature before unit can operate as designed. temperature set point

Bring unit to proper operating temperature

before routing NCGs to unit

Unit reaches desired combustion temperatureand all safety interlocks (purging, etc.) have bee

met

36 36

Refractory needs to come up to proper operating

temperature before unit can operate as designed. temperature set point

Bring unit to proper operating temperature

before routing NCGs to unit

Unit reaches desired combustion temperatureand all safety interlocks (purging, etc.) have bee

met

0.3 0.3

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

24 24

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

The applicable emission and parameter limits are

expected to be met during startup all complinace parameters in range

1 1

Control device is started up and meets required

operating parameter limits before combustion of

LVHC gases commences. If sources are started

prior to control device, then LVHC gases are

burned in the backup control device (emission

unit 015).

The applicable emission and parameter limits are

expected to be met during startup

Combustion temperature meets minimum

parameter value

13 13

Control device is started up and meets required

operating parameter limits before emission unit is

started up. None Combustion temperature reaches >1200F

8 8

Control device is started up and meets required

operating parameter limits before emission unit is

started up.

bring TO temperature to 1375 F before routing

NCG or SOG to the TO Combustion temperature reaches 1375F

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

613‐‐058

APCD_SU_

Duration_

hrs

APCD_SU_D

uration_hrs_

num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

2 2

When we start up the mill after a cold shutdown,

the oxidizer is started up prior to any other mill

process. That way, we always have an

incineration source ready when we start up our

emission sources. Once the kiln is started up and

is stable, we switc

40‐100 gpm quench water flow. 50‐200 KSCFH

natural gas consumption. "OXIDIZER READY"

indication from provox. 1600 F operating

temperature upper zone.

max 42 all

min 0.05avg 10.0median 8max 42 INC‐LK

min 0.083avg 16.7median 18max 8 INC‐BOI

min 4avg 4.0median 4max 36 TO/RTO/INC

min 0.05avg 8.5median 6max 12 INC‐RF

min 4avg 8median 7.5

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

109‐‐LK1128‐‐B006145‐‐Other ‐ (SOG002‐01C)

145‐‐Other ‐ (NCG001‐01C)

164‐‐LVHC NCG Incineration in

either Lime Kiln (primary) or No.

11 Boiler (backup)

196‐‐LVHC196‐‐SOG198‐‐014, 014_S

203‐‐Lkiln203‐‐HogBlr114‐‐U400115‐‐SS01115‐‐WS01‐4

115‐‐WS01‐5

115‐‐Stripper Pre‐heater

115‐‐Stripper Condenser124‐‐016140‐‐Other ‐ #1 Power Boiler

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

Control is shutdown after the emission unit is

shutdown

Control is shutdown after the emission unit is

shutdown

The unit has cooled to the mfger's

recommendation

annualoutage is

typically168 hours;unit 100%upotherwise

Boiler is only source of steam for plant operation.

Since steam is required to produce HVLC, there is

nothing to control until boiler becomes fully

operational. None NoneControl device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup unit offline

1 1

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

Collection system must vent to purge O2 to avoid

explosive gas mixture. unit offline

NA NA NA NA NA 0.1 0.1 If down, NCG and SOG are routed to Lime Kiln

The applicable emission and parameter limits are

expected to be met during startup

NCG and SOG are routed to backup source (No. 2

Lime Kiln)

NCG and SOG are routed to backup source (No. 2

Lime Kiln)

0.25 0.25 If down, NCG and SOG are routed to Lime Kiln

The applicable emission and parameter limits are

expected to be met during startup

NCG and SOG are routed to backup source (No. 2

Lime Kiln)

NCG and SOG are routed to backup source (No. 2

Lime Kiln)

1 1

Control device continues to operate and meets

required operating limits while emission unit is

shut down. combustion temperature

control device continues to operate as long as

possible while process shuts down

combustion temperautre drops below noral

operating range or burner extinguished

0 0

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

lime kiln will not accept NCG until temperature

point is reached

the first thing would be to divert NCG gas flow to

hog boiler. If hog boiler is shut down, it would be

reducing natural gas flow and flame temp.

0.5 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

Natural gas used to maintain temperature while

priamary fuel is cut off. primary fuel is cut off

NA NA NA Route NCGs to alternate control

Shutdown conditions are the steaming rate is les

than 60,000 lb/hr and the differential pressure

across the NCG nozzle is less than 2 inches of

water.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

145‐‐Boiler (PR005)

145‐‐Boiler (PR004)

152‐‐09154‐‐B21154‐‐B20173‐‐PB1185‐‐09187‐‐1187‐‐2201‐‐SR0030201‐‐SR0002205‐‐011245‐‐WFB2245‐‐WFB1245‐‐WFB2245‐‐WFB1340‐‐SN‐02340‐‐SN‐04

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

confirmation that NCG's are being combusted in

PR004

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup steam pressure <50,000 psig

0.5 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

shutdown associated emission units prior to

control device shutdown

Fuel is pulled from the unit and the steam flow

falls below 90,000 lb/hr

0.25 0.25

Control device continues to operate and meets

required operating limits while emission unit is

shut down. NA

Control device is not shutdown until process is

down

Boiler Steaming rate drops below 120klbs/hr or

temp drops below 1700 deg F

0.25 0.25

Control device continues to operate and meets

required operating limits while emission unit is

shut down. NA

Control device is not shutdown until process is

down

Boiler Steaming rate drops below 120klbs/hr or

temp drops below 1700 deg F

0.5 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down. NA

LVHC/SOG gases are transferred to primary

control device (SR0002) Bark transfer to boiler is ceased

0.5 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down. NA

LVHC/SOG gases are transferred to backup

control device (SR0030) Bark transfer to boiler is ceased

0.5 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

HVLC gases are transferred to backup control

device (Lime Kiln) Bark transfer to boiler is ceased

1 1

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

Route LVHC & HVLC gases to primary controldevice (WFB2) Burners off and no bark flow

1 1

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

Route LVHC & HVLC gases to backup control

device (WFB1) Burners off and no bark flow

1 1

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

Route LVHC & HVLC gases to primary controldevice (WFB2) Burners off and no bark flow

1 1

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

Route LVHC & HVLC gases to backup controldevice (WFB1) Burners off and no bark flow

4 4

Control device continues to operate and meets

required operating limits while emission unit is

shut down. When brownstock washers are shut down

4 4

Control device continues to operate and meets

required operating limits while emission unit is

shut down. When brownstock washers are shut down

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

606‐‐LVHC617‐‐B20617‐‐B21617‐‐B24103‐‐WLS, G‐165

107‐‐11‐P14

115‐‐KD02115‐‐KD06115‐‐KD06115‐‐KD02115‐‐EV03115‐‐CO03117‐‐P36124‐‐004140‐‐Other ‐Lime Kiln

142‐‐P6025

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

Process is completely shutdown prior to control

device shutdown

24 24

Lime Kiln operates until the LVHC and SOG

systems have completed shut down or the gases

are routed to back‐up control.

When Lime Kiln or No. 2 Hog Fuel Boiler are ready

to incinerate NCG’s, operator must place unit in

the "Accept" mode. DCS display provides

information of LVHC NCG and SOG switch over

from Lime Kiln to the No. 2 Hog Fuel Boiler, if the

No. 2 Hog Fuel Boil LVHC and SOG systems complete shutdown.

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

18 18

Need to allow feed to be shut off to P36, and

then time to burn out and cool before motor is

shut off.

Will not be able to burn LVHC and HVLCs during

cooling process. Shutdown LVHC & HVLC systems before P36. Mud feed to P36 is stopped.

0 0 need gas flow to attain d/p n/a no parameters needed with EU down. n/a no measures needed with EU down stop lime mud feed‐EU shutdown

NA NA NA Route NCGs to alternate control

Shutdown conditions are the lime kiln hood

temperature is less than 1400 F, the primary air

flow is less than 102,000 standard cubic feet per

hour. And the kiln NCG fan is not running.

20 20

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

Valves are positioned for shutdown and steam

flow is discontinued.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

142‐‐P6009149‐‐P001151‐‐CD‐CP002151‐‐CD‐CP001152‐‐08154‐‐P30155‐‐LIME KILN

180‐‐L002180‐‐L001183‐‐Incin1

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

20 20

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

Valves are positioned for shutdown and steam

flow is discontinued.

2 2

Primary control device (NC‐101) used during Lime

Kiln startup or shutdown

The applicable emission and parameter limits are

expected to be met during startup

Primary control device (NC‐101) used during Lime

Kiln startup or shutdown

Total Mud Flow to Kiln < 100 lb/min for 30 mins

and Gas Flow to Kiln < 25 MMscfh

12 12 Route NCG and/or SOG back to backup control NCG/SOG re‐routed to backupcontrol device

24 24 Route NCG and/or SOG back to primary control NCG/SOG re‐routed to primary control device

8 8

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

shutdown associated emission units prior to

control device shutdown

Fuel is pulled from the unit and the combustion

temperature falls below 1200F

0.5 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down. NA

Control device is not shutdown until process is

down

The lime kiln would only be used if neither boile

was available.

4 4

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

LVHC system feeds will be routed to the primary

control device. If the primary control device isunavailable, the LVHC system feeds will beremoved and LVHC contributing processses shut

down.

Mud flow to lime kiln less than 10 gpm for 30

min. or temperature of 1200F cannot be met.

2 2

Kiln continues to operate while LVHC gases are

removed

No continuous parameter monitoring required for

Lime Kiln operation Usage of lime kiln wet scrubber and TRS scrubber

LVHC re‐routed to recovery boiler or other kiln;

ceasing of mud flow to kiln

2 2

Kiln continues to operate while LVHC gases are

removed

No continuous parameter monitoring required for

Lime Kiln operation Usage of lime kiln wet scrubber and TRS scrubber

LVHC re‐routed to recovery boiler or other kiln;

ceasing of mud flow to kiln

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

185‐‐07188‐‐LK1188‐‐LK2199‐‐010205‐‐008226‐‐07226‐‐06240‐‐NCC1, CA81242‐‐RC‐6340‐‐SN‐08610‐‐7610‐‐8613‐‐009615‐‐EU ID 21

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

24 24

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup switch to other lime kiln

24 24

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup switch to other lime kiln

0.5 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

CNCGs and DNCGs are transferred to alternate

control device upon shutdown Lime mud feed to kiln is discontinued

0.5 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

LVHC gases are transferred to backup control

device (Combination Boiler) Lime mud transfer to kiln is ceased

0.5 0.5

Control device continues to operate and meets

required operating limits until emission unit is

shut down. tempurature set point

Route NCGs and/or SOGs through primary or

backup control device

Mud flow to kiln is off and temperature is below

required minimum

0.5 0.5

Control device continues to operate and meets

required operating limits until emission unit is

shut down. tempurature set point

Route NCG and/or SOG through backup control

device

Mud flow to kiln is off and temperature is below

required minimum

UK

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

Control device continues to operate and meets

required operating limits while emission unit is

shut down. UK

Control device shutdown begins after emissions

unit shutdown is complete 

12 12

Control device continues to operate and meets

required operating limits while emission unit is

shut down. Route NCG and/or SOG back to primary control lime mud out of the kiln

4 4

Control device continues to operate and meets

required operating limits while emission unit is

shut down. When evaporators and digesters are shut down

8.33333333333333E‐02 0.0833333

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

LVHC gases out of the kiln and in the other kiln

for control

8.33333333333333E‐02 0.0833333

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

LVHC gases out of the kiln and in the other kiln

for control

2 2

For the lime kiln to be shut down, the thermal

oxidizer must be fully operational; we always

have one incineration source available to burn

NCGs

Stopping mud flow to the lime kiln with the

intention of shutting down the operation

3 3

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

208228535‐‐X003208228535‐‐X014107‐‐08‐P1

155‐‐RECOVERY FURNACE/RF

ESP180‐‐D001199‐‐001615‐‐EU ID 24

615‐‐EU ID 24

617‐‐B14208228535‐‐X001208228535‐‐X012185‐‐02118‐‐CE012118‐‐CE012166‐‐BLOX Scrub, BLOX WESP

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

0.1 0.1

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

LVHC gases are transferred to backup control

device when primary control device no longer

meets permissives to burn. Lime mud feed to kiln ceases

0.1 0.1

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

LVHC gases are transferred to backup control

device when primary control device no longer

meets permissives to burn. Lime mud feed to kiln ceases

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

4 4

control device continues to operate after HVLCsystem contributing operations have beenshutdown

The applicable emission and parameter limits are

expected to be met during startup

If recovery furnace not available within one hour

then shutdown processes contributing to LVHC

system.

Black liquor flow rate less than 40 gpm for 15

min. or secondary air fan is not running.

2 2

Recovery Boiler continues to operate while LVHC

gases are removed

No continuous parameter monitoring required for

Recovery Boiler operation Usage of recovery boiler ESP and CEMS

LVHC re‐routed to lime kiln(s); ceasing of liquor

flow or auxiliary fuels

12 12

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

CNCGs and DNCGs are transferred to alternate

control device upon shutdown Black liquor feed to boiler is discontinued

5 5

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

5 5

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

6 6

Source emission units for HVLC gases are shut

down when control device shutdown commences

The applicable emission and parameter limits are

expected to be met during shutdown Less than 2 black liquor guns are in service

6 6

Source emission units for HVLC gases are shut

down when control device shutdown commences

The applicable emission and parameter limits are

expected to be met during shutdown Less than 2 black liquor guns are in service

0.15 ‐ 24

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

Stop burning gases in the RTO. LVHC and HVLC

emission sources are either shut down before th

RTO is shut down or the LVHC gases are swapped

to another control device.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

206‐‐S‐71

229‐‐CE 027, CE 024

229‐‐CE 027, CE 024

610‐‐17368611‐‐CE001‐RTO100‐‐NCG1102‐‐NCG‐TO104‐‐EUG F4a/F4b106‐‐TO

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

4 4

Control device remains in operation until HVLC

gases have been redirected out of the collection

system. None

Firebox temperature is ramped down for the

purposes of shutting down the unit.

12 12

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed. temperature set point When no longer need to control emissions

11 11

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed. temperature set point When no longer need to control emissions

8.33333333333333E‐02 0.0833333

Control device can continue to operate and

meets required operating limits while emission

unit is shut down. Routine maintenance is

conducted on the RTO while HVLC sources are in

operation (HVLC gases are vented during this

period). Minimum NCG combustion temperature

Valve out HVLC gases and shutoff propane flow t

the RTO

0.02 0.02

Control device continues to operate and meets

required operating limits while emission unit is

shut down. temperature set point Burner shuts off, fresh air damper opens

~ < 1 hr

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

Stop burning gases in the thermal oxidizer. LVHC

emission sources are either shut down before th

thermal oxidizer is shut down or the LVHC gases

are swapped to another control device.

0 0

The control device remains in operation during

short‐duration emission unit shutdowns. For long‐

duration emission unit shutdown (eg, annual

maintenance outage), NCG‐TO remains on line

and up to temperature until HVLC‐S and HVLC‐S

processes are shut down. temperature set point Route LVHC to Lime Kiln Shutdown begins when burner is shut off.

0.1 0.1

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

Stop burning gases in the thermal oxidizer. LVHC

emission sources are either shut down before th

thermal oxidizer is shut down or the LVHC gases

are swapped to another control device.

UK

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

Temperature fluctuates during startup of the

control device and during startup of the NCG

system as gases are introduced into the control

device.

Shutdown does not begin until NCG/SOG are re‐

routed to backup control device or the NCG

System has been shut down.

NCG/SOG re‐routed to backup control device, or

NCG System is shut down.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

109‐‐B‐900

109‐‐INCR01116‐‐NCG1127‐‐E200A130‐‐39TO136‐‐CE 022, CE 023

137‐‐PC(106) & PC(106)S

138‐‐NCGTO1146‐‐LVHC1

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

Control is shutdown after the emission unit is

shutdown

Control is shutdown after the emission unit is

shutdown

The unit has cooled to the mfger's

recommendation

4 4

This unit is not shutdown until backup units are

operating

This unit is not shutdown until backup units are

operating

The unit has cooled to the mfger's

recommendation (<200)

~15 15

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

Stop burning gases in the thermal oxidizer. LVHC

emission sources are either shut down before th

thermal oxidizer is shut down or the LVHC gases

are swapped to another control device.

0.0167 0.0167

Control device continues to operate and meets

required operating limits while emission unit is

shut down. temperature set point Route NCG/SOG gases to Power Boiler 3 Stop natural gas flow

< 1 Hr

Control device continues to operate and meets

required operating limits while emission unit is

shut down. Combustion temperature of 1600°F

The thermal oxidizer continues to meet its target

combustion temperature of 1600 °F until the

sources feeding into the LVHC collection system

are shutdown

When the thermal oxidizer can no longer meet it

operating parameter limits, the control device is

considered to have begun its shutdown 

0 0 Independent NA Combust NCGs in power boilers temperature <= 1500 oF 

1 1

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed. temperature set point Route NCG back to lime kiln for control

Steam flow to the LVHC ejectors and NCG

Incinerator temperature > 1324 deg.F

0.1 0.1

Control device operation is independent of

emission unit operation temperature set point

NCGs routed to Lime Kiln prior shutdown process

if NCG sources are in operation duirng the

shutdown of the NCG Thermal Oxidizer. NCGs routed to the Lime Kiln

0.1 0.1

NCG system and combustion device remain in

service until system is completely off‐line NA

NCG system and combustion device remain in

service until system is completely off‐line

Shutdown begins when digester blows or steam

addition is stopped to evaporators 

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

146‐‐SOG1146‐‐HVLC1147‐‐C‐INC

147‐‐C‐016

148‐‐044149‐‐NC‐101

155‐‐THERMAL OXIDIZER/TO

SCRUBBER162‐‐331A165‐‐000037, NCG

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

0.1 0.1

NCG system and combustion device remain in

service until system is completely off‐line NA

NCG system and combustion device remain in

service until system is completely off‐line Shutdown steam addition is stopped 

0.1 0.1

NCG system and combustion device remain in

service until system is completely off‐line NA

NCG system and combustion device remain in

service until system is completely off‐line

Shutdown begins when the knotter feed pump is

shutdown 

NA NA NA NA NA NA NA NA NA NA 10 10

Control device is not shutdown until the emission

unit is shutdown

Control device parameters are met before

emission unit is brought up

Control device parameters are met before

emission unit is brought up When NCGs have been diverted to back up sourc

0 0

Backup control device (P001) used during

Thermal Oxidizer startup or shutdown

MACT minimum operating temperature is not be

met until after LVHC gas flow to incinerator has

been established. However, the 3‐hour average

temperature can meet the minimum temperature

requirement.

Backup control device (P001) used during

Thermal Oxidizer startup or shutdown

EU routed to backup control device and natural

gas flow stops

0.5 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

Continue to maintain temperature setpoint of

1350F until LVHC system feeds have beenremoved and contributing process shutdown or

route LVHC system feeds to alternate control.

Unable to maintain minimum temperature

setopint of 1350F over a 1‐hour average or

maintain a temperature of 1200F for 5‐min.

1 1

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

Stop burning gases in the thermal oxidizer. LVHC

emission sources are either shut down before th

thermal oxidizer is shut down or the LVHC gases

are swapped to another control device.

0.1 0.1

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

Stop burning gases in the thermal oxidizer. LVHC

emission sources are either shut down before th

thermal oxidizer is shut down or the LVHC gases

are swapped to another control device.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

169‐‐09169‐‐J0171‐‐043172‐‐LV01 IN01

178‐‐23C006189‐‐SN83, SO2Scr, CANDLE

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

0.166666666666667 0.1666667

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

When LVHC/NCGs are removed from the

incinerator

0.166666666666667 0.1666667

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

When flow of HVLC gases or auxiliary fuel is

reduced in anticipation of shutting down.

0.1 0.1

This is the secondary treatment device. The unit

is limited in hours of operation.

The applicable emission and parameter limits are

expected to be met during startup

The flare will not be shutdown if still needed for

control of LVHC gases.

Shutdown begins when NCGs are removed from

the flare.

Approximately 0.5 hrs 0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

Stop burning gases in the thermal oxidizer. LVHC

emission sources are either shut down before th

thermal oxidizer is shut down or the LVHC gases

are swapped to another control device.

7 hr

Control device continues to operate and meets

required operating limits while emission unit is

shut down or re‐routed.

Temperature is transient in nature (i.e., changes

as shutdown progresses)

SHUTDOWN (Does not include unplanned

shutdown events associated with equipment

malfunctions). During a normal shutdown, the

control device is not shutdown until all gases

from emission units are shut down or re‐routed.

During an emergency shutdown, all

Stop burning gases in the thermal oxidizer. LVHC

emission sources are either shut down before th

thermal oxidizer is shut down or the LVHC gases

are swapped to another control device.

0.25 0.25

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup

Per the SSM Plan, Shutdown Note: The

Incinerator must remain online until all process

systems have been completely shutdown and

vent gases are no longer being sent to the

Incinerator or the vent gases are being diverted

to the 9A Boiler or Lime Kiln.

Per the SSM Plan, below 1400 F. Verify that the

Incinerator is shut down, following the mills

standard operating procedures. Verify that the

Incinerator is shut down, following the mills

standard operating procedures.

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

190‐‐R425a207‐‐001226‐‐10240‐‐NCC1, CA81242‐‐RC‐22243‐‐R480243‐‐R488340‐‐SN‐22525‐‐NCGSCB, EU37, SO2SCB,

CME208228535‐‐015107‐‐16‐P4

112‐‐NCG Incinerator

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

3 3 NCGs or SOGs are not admitted during shutdown.

The applicable emission and parameter limits are

expected to be met during shutdown.

NCGs or SOGs are not sent to the unit during

shutdown and shutdown is on natural gas.

Removal of NCGs and SOGs from incinerator. Fir

out.

1 1

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup NA Process gasses stopped

0.5 0.5

Control device continues to operate and meets

required operating limits until emission unit is

shut down. tempurature set point

Route NCGs and/or SOGs through primary or

backup control device

NCGs/SOGs are re‐routed to primary control

device and burn valves are closed

UK

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

Control device continues to operate and meets

required operating limits while emission unit is

shut down. UK

Control device shutdown begins after emissions

unit shutdown is complete 

8 8

Control device continues to operate and meets

required operating limits while emission unit is

shut down. Route NCG and/or SOG back to back‐up control NCG/SOG re‐routed to back‐up control device

0.25 0.25

Incinerator can trip at any time due to safety

interlocks an is not dependent upon emission

sources to operate. temperature set point

Continue to operate incinerator until all emission

sources are down.

When NCG gases and/or methanol is no longer

being burned in incinerator and temperature no

longer meets permitted allowables

0.25 0.25

Incinerator can trip at any time due to safety

interlocks an is not dependent upon emission

sources to operate. temperature set point

Continue to operate incinerator until all emission

sources are down.

When NCG gases and/or methanol is no longer

being burned in incinerator and temperature no

longer meets permitted allowables

0.3 0.3

Control device continues to operate and meets

required operating limits while emission unit is

shut down. When evaporators and digesters are shut down

0 0

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during startup loss of flame

0.1 0.1

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

LVHC gases are transferred to primary control

device (lime kiln)

8 8

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

8 8

Control device continues to operate and meets

required operating limits while emission unit is

shut down. NCGs to Lime Kiln or NCG processes down NCGs removed from Incinerator

AppC4_Inc_controls Table is 4 pages wide. 
Appendix C4. Startup and Shutdown Responses for Incineration Controls in the PI Controls tab of the ICR

RTI_APCDID

613‐‐058

APCD_SD_

Duration_h

rs

APCD_SD_

Duration_h

rs_num APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin 

0.5 0.5

For the thermal oxidizer to be shut down, the

lime kiln must be fully operational; we always

have one incineration source available to burn

NCGs; the oxidizer is totally independent of the

emission units

When gases are no longer being accepted by

Thermal Oxidizer and natural gas flow is below 3

SCFM

max 24 all

min 0avg 3.9median 1max 24 INC‐LK

min 0avg 7.7median 2max 4 INC‐BOImin 0.75avg 1.2median 0.75max 15 TO/RTO/INC

min 0avg 2.4median 0.275max 12 INC‐RF

min 2avg 5.7median 5

AppC4_Inc_controls Table is 4 pages wide. 
Appendix D

ICR Data Relevant for the 

Sulfite Pulping Vent Gas Standards

Appendix D1 - Query of Part I Survey Data Base (PI Equip detail tab) for Sulfite 

Emission Units and Collection Systems

Appendix D2 - Information from PI Controls tab for Sulfite Pulping Vent Gas Scrubbers
Appendix D1

Query of Part I Survey Data Base (PI Equip detail tab) for Sulfite Emission Units and 

Collection Systems
Appendix D1

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration_hrs_

num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration_

hrs_num

SD_EmissRednMeas 

Sulfite Pulping INC_LK 203 1 0 0 emission unit and control device operates in

compliance with NSPS and NESHAP

parameter limits during emission unit startup

0 0 NA ‐ applicable emission and parameter

limits not expected to be exceeded during

shutdown

Sulfite Pulping (Ca) SCBR 192 1 0.1 0.1 1 1 shut down in an orderly sequence and keep

pollution control equipment running

Sulfite Pulping (Ca) SCBR 365 1 1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

stock to bleach plant 1 1 NA ‐ applicable emission and parameter

limits not expected to be exceeded during

shutdown

Sulfite Pulping (Ca) SCBR 365 1 4 4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

acid to process 4 4 NA ‐ applicable emission and parameter

limits not expected to be exceeded during

shutdown

Sulfite Pulping (Ca) SCBR 365 1 4 4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

steaming of digester 4 4 NA ‐ applicable emission and parameter

limits not expected to be exceeded during

shutdown

Sulfite Pulping (NH3) SCBR/COND1 241 5 30 30 Control device meets operational targets

prior to emission unit startup.

After first digester blow. 24 24 Control device meets operational targets

until emission unit shutdown is complete.

Sulfite Pulping (NH3) SCBR1 158 1 1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Pulp exiting washer train within

specification

0.5 0.5 NA ‐ applicable emission and parameter

limits not expected to be exceeded during

shutdown

Sulfite Pulping (NH3) SCBR1 158 1 12 12 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Absorption Tower in circulation

with adequate reagent strength

12 12 NA ‐ applicable emission and parameter

limits not expected to be exceeded during

shutdown

Sulfite Pulping (NH3) SCBR1 158 1 2 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Acid fill complete and

temperature/pressure specachieved

2 2 NA ‐ applicable emission and parameter

limits not expected to be exceeded during

shutdown

Sulfite Pulping (NH3) SCBR1 158 1 2 2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Liquor solids content meets

spec.

2 2 NA ‐ applicable emission and parameter

limits not expected to be exceeded during

shutdown

Sulfite Pulping (NH3) SCBR1 241 2 12 12 Control device meets operational targets

prior to emission unit startup.

Producing liquor at target solidsand flow.

6 6 Control device meets operational targets

until emission unit shutdown is complete.

Sulfite Pulping (NH3) SCBR1 241 2 6 6 Control device meets operational targets

prior to emission unit startup.

Producing liquor at target solidsand flow.

4 4 Control device meets operational targets

until emission unit shutdown is complete.

Sulfite Pulping

Sulfite Pulping (Ca)

Sulfite Pulping (NH3)

D1_Sulfite_Equip_detail 
Appendix D2

Information from PI Controls tab for Sulfite Pulping Vent Gas Scrubbers
Appendix D2. Information from PI Controls tab for Sulfite Pulping Vent Gas Scrubbers

RTI

Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType

RTI_SubpartS_Pr

ocessType APCDType

APCD_Pre

ssDrop_in

H2O Scrub_AlkaliType

S

158 Sulfite‐NH3 NEI42385 158‐‐DYNAWA, BRINKS Sulfite Pulping (NH3) Sulfite Pulping Mist eliminator 6

158 Sulfite‐NH3 NEI42385 158‐‐DYNAWA, BRINKS Sulfite Pulping (NH3) Sulfite Pulping Scrubber >3.5 Caustic 2

192 Sulfite‐Ca NEI42730 192‐‐c09 Sulfite Pulping (Ca) Sulfite Pulping Scrubber

6"vacuum caustic 5

193 Sulfite‐NH3 NEI39968 193‐‐00403 Sulfite Pulping (NH3) Sulfite Pulping Mist eliminator

193 Sulfite‐NH3 NEI39968 193‐‐00311 Sulfite Recovery Sulfite Recovery Mist eliminator 20

203 Kraft, Sulfite‐Na NEI42410 203‐‐LKScr

SEE RTI NOTE ‐ Causticizing: Slaker; Kraft Pulping:

BL Tanks HVLC; Kraft Pulping: Digester LVHC; Kraft

Pulping: Evaporator LVHC; Kraft Pulping: LVHC;

Sulfite Pulping; Wastewater (Kraft) NCG, Causticizing:

Scrubber ‐ venturi 30

Weak Wash(Sodium Sulfide / Sodium

Hydroxide) 4

241 Sulfite‐NH3 NEI26382 241‐‐MEHCON Sulfite Pulping (NH3) Sulfite Pulping Condenser UK

241 Sulfite‐NH3 NEI26382 241‐‐VGSCON Sulfite Pulping (NH3) Sulfite Pulping Condenser UK

241 Sulfite‐NH3 NEI26382 241‐‐VGSSCR Sulfite Pulping (NH3) Sulfite Pulping

Scrubber ‐ packed bed UK Caustic 4

365 Sulfite‐Ca NEI54400 365‐‐CO5 Sulfite Pulping (Ca) Sulfite Pulping Scrubber 3 NaOH/Caustic 3

D2_sulfite_controls Table is 5 pages wide
Appendix D2. Information from PI Controls tab for Sulfite Pulping Vent Gas Scrubbers

RTI_APCDID

158‐‐DYNAWA, BRINKS

158‐‐DYNAWA, BRINKS

192‐‐c09193‐‐00403193‐‐00311203‐‐LKScr241‐‐MEHCON241‐‐VGSCON241‐‐VGSSCR365‐‐CO5

Scrub_LiquidMake

up_gpm

Pack_Mat

erialType Water_Source

Water_Re

circulated

Water_Re

circ_gpm

Water_Bl

owdown_

Pct

Water_BlowdownUseDisp

ose Parameter_Continuous Parameter_

fresh water (for periodic

internal washes) No NA NA

Treated in onsite

wastewater treatment

plant

minimum 4 out of 6 demister

tanks must be continuously on‐

line (damper position sensors)

UK fresh water Yes >2400 UK

Treated in onsite

wastewater treatment

plant liquid flow, pressure drop pH for SO2 cont

85 river water Yes 250

0.242424

242424242 used for acid making flow, pH, eductor on/off status

scrubber level (

water tempertu

degrees F)

fresh water No

Treated in onsite

wastewater treatment

plant pressure drop

2.6 process water {Weak Wash} Yes 1316 UK

Recycled to process:

{weak wash tank}

liquid flow rate,

Pressure Drop

partially treated wastewater

{clarifier} No NA 1

Treated in onsite

wastewater treatment

plant gas temperature, liquid flow rate

fresh water No NA 1

Treated in onsite

wastewater treatment

plant liquid flow rate, gas temperature

150

plasticpacking fresh water No NA 1

Treated in onsite

wastewater treatment

plant other (SO2 CEMS, pH)

120

polypropylene Filter Water/Well Water No NA NA

Treated in onsite

wastewater treatment

plant

ph, liquid flow rate, water

temperature

D2_sulfite_controls Table is 5 pages wide
Appendix D2. Information from PI Controls tab for Sulfite Pulping Vent Gas Scrubbers

RTI_APCDID

158‐‐DYNAWA, BRINKS

158‐‐DYNAWA, BRINKS

192‐‐c09193‐‐00403193‐‐00311203‐‐LKScr241‐‐MEHCON241‐‐VGSCON241‐‐VGSSCR365‐‐CO5

APCD_SU_Du

ration_hrs APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas APCD_SU_MarkEnd

0.5

Control device is started up and meets required

operating parameter limits before emission unit

is started up. None None

Not applicable, the demisters are

static and there are no special

startup procedures beyond

opening dampers.

0.5

Control device is started up and meets required

operating parameter limits before emission unit

is started up. None

Ensure scrubberant is

circulating and pH is at target

level throughout startup.

Startup ends when the pressure

drop and scrubberant

recirculation parameter limit

ranges are achieved

3.3333333333

Pulpmill processes are not started until scrubber

is running

everything is off‐line until

scrubber is running

Make sure scrubber flow is at 60

gpm and caustic valves are

controlling

0

Control device is started up and meets required

operating parameter limits before emission unit

is started up.

The applicable emission and

parameter limits are expected

to be met during startup

Scrubber operating parameters

established

1

Control device is started up and meets required

operating parameter limits before emission unit

is started up.

The applicable emission and

parameter limits are expected

to be met during startup

Control device operational

parameters met

0.5

Control device is started up and meets required

operating parameter limits before emission unit

is started up.

The applicable emission and

parameter limits are expected

to be met during startup

Control device operational

parameters met

0.5

Control device is started up and meets required

operating parameter limits before emission unit

is started up.

The applicable emission and

parameter limits are expected

to be met during startup

Control device operational

parameters met

1

Control device is started up and meets required

operating parameter limits before emission unit

is started up.

The applicable emission and

parameter limits are expected

to be met during startup

Control device is started up

and meets required operating

parameter limits before

emission unit is started up.

water flow and temp and ph

parameters achieved

D2_sulfite_controls Table is 5 pages wide
Appendix D2. Information from PI Controls tab for Sulfite Pulping Vent Gas Scrubbers

RTI_APCDID

158‐‐DYNAWA, BRINKS

158‐‐DYNAWA, BRINKS

192‐‐c09193‐‐00403193‐‐00311203‐‐LKScr241‐‐MEHCON241‐‐VGSCON241‐‐VGSSCR365‐‐CO5

APCD_SD_Du

ration_hrs APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_Mark

0

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter

limits are expected to be met during

startup

Shutdown affected process unit prior to

shutting down the control device. shut damper to demiste

0.25

APCD_SD_Integration: Control device continues

to operate and meets required operating limits

while emission unit is shut down. When

switching the Recovery Boiler to natural gas‐only

mode there may be a short period where there

is inadequate flue gas flow to maintain the

pressure drop parameter. This is a subpart MM

consideration (not subpart S or NSPS BB

concern).

When switching the Recovery Boiler

from natural gas‐only mode to

combustion of spent liquor there may

be a short period where there is

inadequate flue gas flow to maintain

the pressure drop parameter. This is a

subpart MM consideration (not

subpart S or NSPS BB concern).

Shutdown affected process unit prior to

shutting down the control device. shut off liquid flow

1.66666666666667E‐02

the rest of the process is shut down and valved

closed before scrubber is taken off‐line Nothing on‐line

when all of the valves to 

digester are closed and 

acid making going on

0.16

Control device continues to operate and meets

required operating limits while emission unit isshut down.

The applicable emission and parameter

limits are expected to be met during

startup

lime kiln shut down before scrubber shut

down lime kiln is shut down

0.5

Control device continues to operate and meets

required operating limits while emission unit is

shut down.

The applicable emission and parameter

limits are expected to be met during

startup

Failure to meet operatioparameters due to shut

0.5

Control device continues to operate and meets

required operating limits while emission unit isshut down.

The applicable emission and parameter

limits are expected to be met during

startup

Failure to meet operatio

parameters due to shut

0.5

Control device continues to operate and meets

required operating limits while emission unit isshut down.

The applicable emission and parameter

limits are expected to be met during

startup

Failure to meet operatioparameters due to shut

1

Control device continues to operate and meets

required operating limits while emission unit isshut down.

The applicable emission and parameter

limits are expected to be met during

startup

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

Control device continue

and meets required ope

limits while emission un

down.

D2_sulfite_controls Table is 5 pages wide
Appendix D2. Information from PI Controls tab for Sulfite Pulping Vent Gas Scrubbers

RTI_APCDID

158‐‐DYNAWA, BRINKS

158‐‐DYNAWA, BRINKS

192‐‐c09193‐‐00403193‐‐00311203‐‐LKScr241‐‐MEHCON241‐‐VGSCON241‐‐VGSSCR365‐‐CO5

APCDComment RTI_Notes

Six cells in parallel. Delta P is total

unit.Scrubbing liquid is continuously bledoff and replenished, unknown flow.

The PIII DB was used to comfirm the LVHC

system was introducted to the lime kiln

and then the scubber on the LK

EmissionUnit_Coll_ID: multiple vents

combined,P50,P53,P54

D2_sulfite_controls Table is 5 pages wide
Appendix E

ICR Data Relevant for the 

Bleaching Vent Gas Standards

Appendix E1 - Query of Part I Survey Data Base (PI Equip detail tab) for Bleaching 

Emission Units and Collection Systems

Appendix E2 - Information from PI Controls tab for Bleach Plant Scrubbers
Appendix E1

Query of Part I Survey Data Base (PI Equip detail tab) for Bleaching Emission Units and 

Collection Systems
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching

Bleaching SCBR 100 12 ~3 hrs 3 The bleach plant collection system and scrubber

will be in a normal operation condition before

bleaching chemical is introduced to the pulp and

the stock to storage pump is operating.

Startup is considered complete

when the following quality

based parameters (pulp

brightness and CLO2 residual)

for the bleach plant are met:

~3hrs 3 The bleach plant collection system and scrubber

will remain in normal operation as defined above

until the addition of bleaching chemical ceases

and the stock to high density storage pump is

shutdown.

Bleaching SCBR 102 1 12 12 The bleach plant is considered to be starting up

when brown stock begins to be fed to the bleach

plant and chemical is applied. Bleach plant

emissions are minimized by startup SOP’s that

assure all vent gases from process equipment

that uses chlorinated compounds are collected

and sent to the Bleach Plant scrubber.

Product flow 1 1 The Bleach Plant Vent Gas System is operated

until the Bleach Plant is shut down. The bleach

plant and bleach plant vent gas system are

interlocked such that the ClO2 feed pumps

cannot run if the scrubber is down.

Bleaching SCBR 103 2 8 8 To minimize emissions from the bleaching

operations, the bleach plant scrubber(s) are in

operation before beginning startup of a bleach

line.

The bleach plant is considered

to have completed startup

when brownstock begins to

feed to the bleach line and

chemical is fed.

8 8 To minimize emissions during shutdown, the

Bleach Plant Vent Gas Collection System and

scrubber(s) is operated until the Bleach Plant has

completed shutdown.

Bleaching SCBR 106 14 12 12 Verify collection system is available and gases

are being sent to a control device prior to startup

of the operation.

Brightness and residual at D1

tower for 8 hours (final product

specifications are met).

2 2 Continue routing collected gases to the control

device.

Bleaching SCBR 109 1 The scrubber must be operational before process

unit is started up

Bleaching SCBR 109 1 0 0 The scrubber must be operational before process

unit is started up

Bleaching SCBR 112 1 6 6 Collection and control systems operating before

start‐up

When filtrate exits tanks 6 6 continue routing emissions to collection system

and control system

Bleaching SCBR 112 1 6 6 Collection and control systems operating before

start‐up

When gasses exit scrubber 6 6 continue routing emissions to collection system

and control system

Bleaching SCBR 112 3 6 6 Collection and control systems operating before

start‐up

When stock enters tower 6 6 continue routing emissions to collection system

and control system

Bleaching SCBR 115 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Unit is operating and all CMS

parameters within limits

0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Bleaching SCBR 124 1 6 6 Start scrubber prior to starting bleach plant bleached stock going to high

density

6 6 Keep scrubber going until all ClO2 addition has

ended

Bleaching SCBR 124 1 6 6 Start scrubber prior to starting bleach plant bleached stock going to high

density

6 6 Keep scrubber operating until all ClO2 addtion is

ended

Bleaching SCBR 130 2 2 ‐ 6 6 1. Exercise caution to prevent excess chlorinated

HAPs from being emitted. 2. Ensure Bleach Plant

scrubber is running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits. 3. Ensure Bleach washer hood

doors and tube sample doors are closed. 4.

Apply chemicals at a lesser rate until operations

stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels. All five bleachedwashers running and meeting

quality specifications.

1‐4 4 1. Exercise caution to prevent excess chlorinated

HAPs from being emitted.

2. Ensure Bleach Plant scrubber is running and

operating parameters (ex, scrubber flow, ORP,

fan amps) are within allowable limits.

3. Ensure Bleach washer hood doors and tube

sample doors are closed.

4. Reduce chemical application rates.

5.Shut off chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

Bleaching SCBR 130 6 2 ‐ 6 6 1. Exercise caution to prevent excess chlorinated

HAPs from being emitted. 2. Ensure Bleach Plant

scrubber is running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits. 3. Ensure Bleach washer hood

doors and tube sample doors are closed. 4.

Apply chemicals at a lesser rate until operations

stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels. All five bleachedwashers running and meeting

quality specifications.

1‐4 4 1. Exercise caution to prevent excess chlorinated

HAPs from being emitted.

2. Ensure Bleach Plant scrubber is running and

operating parameters (ex, scrubber flow, ORP,

fan amps) are within allowable limits.

3. Ensure Bleach washer hood doors and tube

sample doors are closed.

4. Reduce chemical application rates.

5.Shut off chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

E1_Bleaching_Equip_detail 
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching SCBR 130 1 2 ‐ 6 6 1. Exercise caution to prevent excess chlorinated

HAPs from being emitted. 2. Ensure Bleach Plant

scrubber is running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits. 3. Ensure Bleach washer hood

doors and tube sample doors are closed. 4.

Apply chemicals at a lesser rate until operations

stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels. All five bleachedwashers running and meeting

quality specifications.

1‐4 4 1. Exercise caution to prevent excess chlorinated

HAPs from being emitted.

2. Ensure Bleach Plant scrubber is running and

operating parameters (ex, scrubber flow, ORP,

fan amps) are within allowable limits.

3. Ensure Bleach washer hood doors and tube

sample doors are closed.

4. Reduce chemical application rates.

5.Shut off chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

Bleaching SCBR 131 7 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stock pumps running 2 2 Continue routing emissions to BP‐CS collection

system and BP‐CD control system

Bleaching SCBR 133 1 8 8 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

the bleach plant vent fan is

running, scrubber circulation is

established, and scrubber

chemical is verified

8 8 continue routing emissions to bleach plant

scrubber, keep scrubber operating until process

shutdown is completed

Bleaching SCBR 135 1 0.5 0.5 BPCS: The bleach plant scrubber is operating and

ready to accept BPCS gases for control.

BPCS: The BPCS gases are being

controlled by the scrubber

within compliance range.

0.5 0.5 BPCS: The bleach plant scrubber continues to

operate while the collection system is shut down

Bleaching SCBR 135 1 7 7 Bleaching System: The BPCS and bleach plant

scrubber is operating prior to startup of

bleachine line.

Bleaching System: All stages of

washing and reaction towers

are operating. The scrubber

parameters are in the

compliance range. The pulp has

an ISO brightness of 85 flowing

to high density storage.

11 11 Bleaching System: The BPCS and bleach plant

scrubber continue to operate while the bleaching

system is in shutdown mode.

Bleaching SCBR 136 12 NA NA NA NA NA Bleaching SCBR 137 1 1 1 FOLLOW SSM PLAN Flow to No.1 PO Washer > 500

gpm or for 2 hours

12 12 FOLLOW SSM PLAN 

Bleaching SCBR 137 1 1 1 NA Flow to washer at normal rates

or for 2 hours

12 12 NA 

Bleaching SCBR 138 4 5 5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stock flow is obtained through

the washers.

0.5 0.5 continue routing emissions to BLCH‐1 collection

system to bleach plant scrubber (SCRB BL1)

Bleaching SCBR 140 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

ClO2 is going to the bleachplant, the bleach scrubber fan is

on, the ph of the scrubber

media is greater than 11, and

the flow to the scrubber is

greater than the minimum.

The bleach scrubber fan is on, the ph of the

scrubber media is greater than 11, and the flow

to the scrubber is greater than the minimum

until bleach plant is shut down.

Bleaching SCBR 145 8 0.75 0.75 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

All dampers and hoods in

operating positions.

1.5 1.5 Scubber continues to operate 

Bleaching SCBR 146 3 0.25 0.25 Chlorine dioxide addition is not allowed until the

scrubber flowrate meets the required level

Start‐up begins with the

addition of chlorine dioxide

0.1 0.1 The scrubber operation continues until after all

pulp is processed through the bleach line

Bleaching SCBR 147 4 0.25 0.25 Chlorine dioxide addition is not allowed until the

scrubber flowrate meets the required level

Start‐up begins with the

addition of chlorine dioxide

0.1 0.1 The scrubber operation continues until after all

pulp is processed through the bleach line

Bleaching SCBR 149 1 8 8 Operate all APCDs during startup Pulp flow to white stock storage 1 1 Operate all APCDs during shutdown 

Bleaching SCBR 150 2 0.2 0.2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Scrubber ID Fan On, Recirc

Flows at set point, ORP at set

point

0.2 0.2 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Bleaching SCBR 150 6 0.75 0.75 continue routing emissions to BL‐A collection

system and primary or backup control system

All 3 bleaching stages running

with chemical flows

0.75 0.75 continue routing emissions to BL‐A collection

system and primary or backup control system

E1_Bleaching_Equip_detail 
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching SCBR 150 6 0.75 0.75 continue routing emissions to BL‐B collection

system and primary or backup control system

All 3 bleaching stages running

with chemical flows

0.75 0.75 continue routing emissions to BL‐B collection

system and primary or backup control system

Bleaching SCBR 152 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

fan is started and recirculation

pumps started

4 4 emission unit and control device operates in

compliance with NESHAP parameter limits

during emission unit shutdown

Bleaching SCBR 152 7 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

chlorine dioxide flow is initiated 4 4 emission unit and control device operates in

compliance with NESHAP parameter limits

during emission unit shutdown

Bleaching SCBR 154 2 0.25 0.25 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous discharge fromcleaner decker

0.25 0.25 Continue routing emissions to the scrubber

system

Bleaching SCBR 154 2 0.5 0.5 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow to

associated washer

1 1 Continue routing emissions to the scrubber

system

Bleaching SCBR 154 2 1 1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow to

associated washer

1 1 Continue routing emissions to the scrubber

system

Bleaching SCBR 154 1 2 2 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow to

associated washer

2 2 Continue routing emissions to the scrubber

system

Bleaching SCBR 154 1 3 3 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow to

associated washer

3 3 Continue routing emissions to the scrubber

system

Bleaching SCBR 154 1 4 4 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Continuous stock flow to

associated washer

4 4 Continue routing emissions to the scrubber

system

Bleaching SCBR 154 1 Instant 0 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

NA Instant 0 Continue routing emissions to the scrubber

system

Bleaching SCBR 155 4 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

when Do stock flow > 500 gpm

& D2 stock pump > 50 amps for

4 hrs

0.25 0.25 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Bleaching SCBR 157 1 16 16 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When stage 4 chlorine residual

is normal

10 10 continue routing emissions to HVLC collection

system

Bleaching SCBR 158 1 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Bleached pulp meets

specification.

6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Bleaching SCBR 162 2 2‐12 12 There are no HAP emissions as a result of starting

up the collection system. HAPS are only

generated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source.

NA‐Not an emission unit 6 6 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system and

control device must be operational while one or

more emission units are running.

Bleaching SCBR 165 2 Hot Startup:

1‐2 hours

Cold Startup:

1‐4 hours

4 Exercise caution to prevent excess chlorinated

HAPs from being emitted.**Ensure Bleach Plant

scrubbers are running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits.**Ensure Bleach washer hooddoors and tube sample

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels

Hot

Shutdown: 1‐

2 hours

Cold

Shutdown: 1‐

3 houts

3  ‐ Exercise caution to prevent excess chlorinated

HAPs from being emitted.

 ‐ Ensure Bleach Plant scrubbers are running and

operating parameters (ex, scrubber flow, ORP,

fan amps) are within allowable limits.

 ‐ Ensure Bleach washer hood doors and tube

sample doors are closed.

 ‐ Reduce chemical application rates.

 ‐ Shut off chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

E1_Bleaching_Equip_detail 
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching SCBR 166 2 Hot Startup:

2‐4 Hours

Cold Startup:

4‐6 Hours

6 (1) Exercise caution to prevent excess chlor HAPs

from being emitted; (2) Ensure BP scrubbers are

running and operating parameters are within

allowable limits; (3) Bleach washer hood doors

and tube sample doors are closed; (4) Apply

chemicals at a lesser rate until operations

stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels

Hot

Shutdown: 1

Hour

Cold

Shutdown: 4

Hour

4 (1)Exercise caution to prevent excess chlorinated

HAPs from being emitted. (2)Ensure Bleach Plant

scrubbers are running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits. (3) Ensure Bleach washer hood

doors and tube sample doors are

closed.(4)Reduce chemical application

rates.(5)Shut off chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

Bleaching SCBR 172 6 Hot Startup:

2‐4 hrs

Cold Startup:

4‐6 hrs

6 (1) Exercise caution to prevent excess chlor HAPs

from being emitted; (2) Ensure BP scrubbers are

running and operating parameters are within

allowable limits; (3) Bleach washer hood doors

and tube sample doors are closed; (4) Apply

chemicals at a lesser rate until operations

stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels

Hot

Shutdown:

approx. 1 hr

Cold

Shutdown:

approx. 4 hrs

4 (1)Exercise caution to prevent excess chlorinated

HAPs from being emitted. (2)Ensure Bleach Plant

scrubbers are running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits. (3) Ensure Bleach washer hood

doors and tube sample doors are

closed.(4)Reduce chemical application

rates.(5)Shut off chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

Bleaching SCBR 173 8 2 ‐ 20 20

1. Ensure Bleach Plant scrubber is running and

operating parameters are within allowable

limits.2. Ensure Bleach washer hood doors are closed.

All five bleach‐side washers are

running and meeting quality

specifications.

2 ‐ 24 24

1. Ensure Bleach Plant scrubber is running and

operating parameters are within allowable

limits.2. Ensure Bleach washer hood doors are closed.

Bleaching SCBR 174 1 Hot Startup:

0.5 Hours

Cold Startup:

4 Hours

0.5 (1) Exercise caution to prevent excess chlor HAPs

from being emitted; (2) Ensure BP scrubbers are

running and operating parameters are within

allowable limits; (3) Bleach washer hood doors

and tube sample doors are closed; (4) Apply

chemicals at a lesser rate until operations

stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels

Hot

Shutdown:

0.5 Hours

Cold

Shutdown: 4

Hours

4 (1)Exercise caution to prevent excess chlorinated

HAPs from being emitted. (2)Ensure Bleach Plant

scrubbers are running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits. (3) Ensure Bleach washer hood

doors and tube sample doors are

closed.(4)Reduce chemical application

rates.(5)Shut off chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

Bleaching SCBR 175 2 Hot Startup:

2‐4 Hours

Cold Startup:

4‐6 Hours

6 (1) Exercise caution to prevent excess chlorinated

HAPs from being emitted; (2) Ensure Bleach Plant

scrubbers are running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits; (3) Apply chemicals at a lesser

rate until operations stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels

Hot

Shutdown: 1

Hour

Cold

Shutdown: 4

Hours

4 (1)Exercise caution to prevent excess chlorinated

HAPs from being emitted.(2)Ensure Bleach Plantscrubbers are running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits. (3)Reduce chemical application

rates.(4) Shut of chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

Bleaching SCBR 177 1 2.0‐10 (range

includes

startup of

bleach plant

process

equipment)

10 continue routing emissions to EU0501 When all towers, residuals and

brightnesses are at speicfied set

points and all washer vats are

at normal levels.

2.0‐10 (range

includes

startup of

bleach plant

process

equipment)

10 continue routing emissions to EU0501 

Bleaching SCBR 177 2 2.0‐10 (range

includes

startup of

bleach plant

process

equipment)

10 continue routing emissions to EU0502 When all towers, residuals and

brightnesses are at speicfied set

points and all washer vats are

at normal levels.

2.0‐10 (range

includes

startup of

bleach plant

process

equipment)

10 continue routing emissions to EU0502 

E1_Bleaching_Equip_detail 
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching SCBR 178 1 1 1 There are no HAP emissions as a result of starting

up the collection system. HAPS are only

generated by the emission units and not thecollection system. The collection system and

control device must be operational prior to

startup of an emission source.

NA 1 1 There are no HAP emissions as a result of

shutting down the collection system. HAPS are

only generated by the emission units and not

the collection system. The collection system and

control device must be operational while one or

more emission units are running.

Bleaching SCBR 178 7 6 6 Exercise caution to prevent excess chlorinated

HAPs from being emitted.

Ensure Bleach Plant scrubbers are running and

operating parameters (ex, scrubber flow, ORP,

fan amps) are within allowable limits.

Ensure Bleach washer hood doors and tube

sample doors are closed.

Apply chemicals at a lesser rate until operations

stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels

4 4 Exercise caution to prevent excess chlorinated

HAPs from being emitted.

Ensure Bleach Plant scrubbers are running and

operating parameters (ex, scrubber flow, ORP,

fan amps) are within allowable limits.

Ensure Bleach washer hood doors and tube

sample dooors are closed.

Reduce chemical application rates.

Shut off chlorine dioxide flow at least 5 minutes

before stock flow is cut off to allow ClO2 to be

fully reacted.

Bleaching SCBR 179 1 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow greater than 10

gpm

0.25‐1 1 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than

10 gpm

0.25‐1 1 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than 3

gpm

0.25‐1 1 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than 5

gpm

0.25‐1 1 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 <0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than 8

gpm

0.25‐1 1 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow greater than 10

gpm

< 0.083 0.083 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than 5

gpm

<0.083 0.083 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 0.083‐0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than 3

gpm

<0.083 1/0/1900 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 0.5‐1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than

10 gpm

0.5‐1 1 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 0.5‐1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than 8

gpm

0.5‐1 1 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 10‐12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

1.) DO chemical flow is greater

than 10 gpm 2.) D1 chemical

flow is greater than 5 gpm. 3)

D2 chemical flow is greater

than 3 gpm

10‐12 12 continue routing emissions to the bleach plant

scrubber during equipment shutdown

Bleaching SCBR 179 1 10‐12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

1.) DO chemical flow is greater

than 10 gpm and 2.) D1

chemical flow is greater than 8

gpm.

10‐12 12 continue routing emissions to the bleach plant

scrubber during equipment shutdown

E1_Bleaching_Equip_detail 
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching SCBR 179 1 2‐3 3 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow greater than 10

gpm

2‐3 3 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 2‐3 3 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than

10 gpm

3‐4 4 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 3‐4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than 3

gpm

2‐3 3 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 5‐7 7 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than 5

gpm

4‐6 6 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 179 1 6‐7 7 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical flow is greater than 8

gpm

4‐6 6 continue routing emissions to Bleach Plant

Scrubber collection system

Bleaching SCBR 182 19 7 7 Ensure scrubber is operating properly When pulp is flowing into pulp

storage

7 7 Shutdown scrubber only after source has been

shutdown

Bleaching SCBR 184 2 0.5 0.5 Continue routing emissions to scrubber

collection system.

When stock and chemical flows

are stabilize.

0.5 0.5 Continue routing emissions to scrubber

collection system.

Bleaching SCBR 184 1 1 1 Continue routing emissions to scrubber

collection system.

When stock and chemical flows

are stabilize.

0.75 0.75 Continue routing emissions to scrubber

collection system.

Bleaching SCBR 185 2 <1.0 hour 1 In accordance with the IOM/SOP, whenever the

bleack plant or ClO2 generator are operating, the

associated scrubber must also be in operation

with all continuous monitoring parameters

within their specified limits.

When adding ClO2 to the D2

chute.

<1.0 hour 1 In accordance with the IOM/SOP, the control

device will continue to operate while the

emission unit is shutdown.

Bleaching SCBR 186 1 1 1 When bleaching agent is

introduced.

1 1 Scrubber 

Bleaching SCBR 186 2 1 1 Scrubber Each of the bleaching stages are

applying the bleaching agent,

stock feed pump to D0 stage is

running and the thick stock

pump to high density tower is

running.

1 1 Scrubber 

Bleaching SCBR 189 1 0.25 0.25 Per the SSM Plan, fan amp and flows in spec.

Startup Note: Verify that the Bleach Plant

Scrubber is collecting vent gases from process

equipment that uses chlorinated compounds. By

visual observation, check for emissions from

hoods, and enclosures, etc.

Per the SSM Plan, collection of

HVLC/LVHC System. Verify that

the Caustic and Additive Pumps

are running at greater than the

acceptable minimum flow rate,

as defined in mills standard

operating procedures. Verify

that one of the RecirculationPumps (32‐0708, 32‐0709) is

running at greater than the

acceptable minimum flow rate,

as defined in mills standard

operating procedures. Verify

that one of the Airpol Scrubber

Fans (32‐0335, 32‐0336) is

running. Verify that the ORP isin the proper operational range,

as defined in mills standard

operating procedures. Verify

that the Bleach Plant ScrubberSystem equipment is operating

normally, as defined by the

mills standard operating

procedures. Verify that the

Bleach Plant Scrubberoperation is stable before

chlorinated compounds are

d d h bl h

0.25 0.25 Per the SSM Plan, continue routing to Bleach

Plant Scrubber. Following a System Outage: Shut

down the Bleach Plant Scrubber following

standard operating procedures. Following a Line

Outage: The Crossett Mill will continue to

operate the Bleach Plant Gas System and Bleach

Plant Scrubber at all times during a line outage.

Following a Line Outage: At anytime the Bleach

Plant Scrubber is not operating the mill will

insure that excess emissions of chlorinated

compounds have been reduced to the maximum

extent practicable. Following a Line Outage:

Verify that the Vent Gas System is operating

normally. Following a System Outage: Shut

down the Bleach Plant Scrubber following

standard operating procedures. Following a Line

Outage: The Crossett Mill will continue to

operate the Bleach Plant Gas System and Bleach

Plant Scrubber at all times during a line outage.

Following a Line Outage: At anytime the Bleach

Plant Scrubber is not operating the mill will

insure that excess emissions of chlorinated

compounds have been reduced to the maximum

extent practicable. Following a Line Outage:

Verify that the Vent Gas System is operating

normally.

E1_Bleaching_Equip_detail 
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching SCBR 189 1 1 1 Per the SSM Plan, ensure Bleach Plant Scrubber

Operating. Startup Note: Verify that the Bleach

Plant Scrubber is collecting vent gases from

process equipment that uses chlorinated

compounds. By visual observation, check for

emissions from hoods, and enclosures, etc.

Per the SSM Plan, collection of

HVLC/LVHC System. Verify that

the Caustic and Additive Pumps

are running at greater than the

acceptable minimum flow rate,

as defined in mills standard

operating procedures. Verify

that one of the RecirculationPumps (32‐0708, 32‐0709) is

running at greater than the

acceptable minimum flow rate,

as defined in mills standard

operating procedures. Verify

that one of the Airpol Scrubber

Fans (32‐0335, 32‐0336) is

running. Verify that the ORP isin the proper operational range,

as defined in mills standard

operating procedures. Verify

that the Bleach Plant ScrubberSystem equipment is operating

normally, as defined by the

mills standard operating

procedures. Verify that the

Bleach Plant Scrubberoperation is stable before

chlorinated compounds are

d d h bl h

0.25 0.25 Per the SSM Plan, continue routing to Bleach

Plant Scrubber. Following a System Outage: Shut

down the Bleach Plant Scrubber following

standard operating procedures. Following a Line

Outage: The Crossett Mill will continue to

operate the Bleach Plant Gas System and Bleach

Plant Scrubber at all times during a line outage.

Following a Line Outage: At anytime the Bleach

Plant Scrubber is not operating the mill will

insure that excess emissions of chlorinated

compounds have been reduced to the maximum

extent practicable. Following a Line Outage:

Verify that the Vent Gas System is operating

normally. Following a System Outage: Shut

down the Bleach Plant Scrubber following

standard operating procedures. Following a Line

Outage: The Crossett Mill will continue to

operate the Bleach Plant Gas System and Bleach

Plant Scrubber at all times during a line outage.

Following a Line Outage: At anytime the Bleach

Plant Scrubber is not operating the mill will

insure that excess emissions of chlorinated

compounds have been reduced to the maximum

extent practicable. Following a Line Outage:

Verify that the Vent Gas System is operating

normally.

Bleaching SCBR 193 1 4 4 CMS parameters met through startup Making on spec bleached pulp 24 24 CMS parameters are met through shutdown

Bleaching SCBR 195 1 1 1 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Stock to the first Bleach Stage 0.5 0.5 All Control Equipment remain on‐line until

source is shut down.

Bleaching SCBR 196 3 8 8 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

stock and chemical feed to first

bleaching stage

1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Bleaching SCBR 198 1 0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

stock flow and chemcial feed

with normal operating ranges,

no alarms

0.083 0.083 continue routing emissions to bleach plant

scrubber

Bleaching SCBR 199 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chlorine dioxide flow to any

bleaching stage

0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Bleaching SCBR 199 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stock flow to first bleaching

stage

0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Bleaching SCBR 199 2 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stock flow to first bleaching

stage for 1 hour

0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Bleaching SCBR 200 1 6 6 bleach plant scrubber operational and follow

approriate startup procedure

stock flow stable, chemical feed

system online, no alarms

6 6 continue routing emissions to bleach plant

scrubber

Bleaching SCBR 201 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Completion of 1 hour of brown

stock flow to the first bleaching

stage

0.3 0.3 continue routing bleach plant emissions to

bleach plant scrubber while meeting minimum

continuous monitoring parameter values

Bleaching SCBR 202 1 4 Based on

Bleach Plant

SSM Plan

4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Bleach Plant ‐ Stock flow to D0

tower (466‐041‐009M is ON) for

4 hours AND bleached stock

flow to high density storage

(466‐041‐043.F1 is ON) for 4

hours

3 to 8 hours

in 2009

based on

SSM plans for

planned

shutdowns

8 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

E1_Bleaching_Equip_detail 
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching SCBR 202 1 Startup

requirement

not required

to be defined

in current

SSM Plans

NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

Startup requirement not

required to be defined in

current SSM Plans

Startup

requirement

not required

to be defined

in current

SSM Plans

NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Bleaching SCBR 203 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

SSM criteria is “Pulp pumps intoand out of BP running” (Blend

chest and D2 stage stock

pumps) (SSM plan criteria‐ that

means all BP towers are full and

pulp is coming out to storage

tanks)

12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Bleaching SCBR 205 2 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stock flow to bleach plant for

30 minutes and final bleaching

stage washer supply pump has

been running for 30 minutes

0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Bleaching SCBR 206 1 12 12 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When ClO2 is being applied in a

bleaching stage

12 12 emission unit and control device operates during

emission unit shutdown in compliance with all

NSPS/NESHAP parameter limits

Bleaching SCBR 206 1 14 14 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When ClO2 is being applied in a

bleaching stage

14 14 emission unit and control device operates during

emission unit shutdown in compliance with all

NSPS/NESHAP parameter limits

Bleaching SCBR 207 1 6.00 6 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

all components running on 1st,

2nd and 3rd stages and stock to

Hi Density tower

6 6 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Bleaching SCBR 242 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Chemical feed to system 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Bleaching SCBR 242 2 0.25 0.25 Scrubber in operation before unit startup. Chemical feed to system 0.25 0.25 Scrubber operating until unit is down 

Bleaching SCBR 243 2 1.5 1.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

For more than 2 hours, target

brightness is met andmaintained and thetemperatures meet requiredtarget temperatures.

0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Bleaching SCBR 243 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

For more than 2 hours, target

brightness is met andmaintained and the

temperatures meet requiredtarget temperatures.

0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Bleaching SCBR 243 2 8 8 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

For more than 2 hours, target

brightness is met andmaintained and the dirt/shive

specification is met. Also, the

D1 and D2 Tower temperatures

meet required target

temperatures.

0.25 0.25 Continue operating scrubber during shutdown

activities

Bleaching SCBR 243 1 8 8 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

For more than 2 hours, target

brightness is met andmaintained and thetemperatures meet required

target temperatures.

0.25 0.25 Continue operating scrubber during shutdown

activities

Bleaching SCBR 525 1 0 0 NA NA 0 0 NA Bleaching SCBR 525 4 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

all vent gases from process

equipment, that use

chlorinated compounds, are

being collected and sent to the

Bleach Plant Scrubber

1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

E1_Bleaching_Equip_detail 
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching SCBR 600 1 Hot Startup:

2‐4 hours;

Cold Startup:

4‐6 hours

6 (1) Exercise caution to prevent excess chlor HAPs

from being emitted; (2) Ensure BP scrubbers are

running and operating parameters are within

allowable limits; (3) Bleach washer hood doors

and tube sample doors are closed; (4) Apply

chemicals at a lesser rate until operations

stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels

Hot

Shutdown: 0‐

1 hours; Cold

Shutdown: 1‐

4 hours

4 (1)Exercise caution to prevent excess chlorinated

HAPs from being emitted. (2)Ensure Bleach Plant

scrubbers are running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits. (3) Ensure Bleach washer hood

doors and tube sample doors are

closed.(4)Reduce chemical application

rates.(5)Shut off chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

Bleaching SCBR 600 22 Hot Startup:

2‐4 hours;

Cold Startup:

4‐6 hours

6 (1)Exercise caution to prevent excess chlor HAPs

from being emitted (2)Ensure BP scrubbers are

running and operating parameters are within

allowable limits**Bleach washer hood doors and

tube sample doors are closed (4) Apply chemicals

at a lesser rate until operations stabilize.

All towers, residuals and

brightness sensors are at

specified set points and all

washer vats are at normal

levels

Hot

Shutdown: 0‐

1 hours; Cold

Shutdown: 1‐

4 hours

4 (1)Exercise caution to prevent excess chlorinated

HAPs from being emitted. (2)Ensure Bleach Plant

scrubbers are running and operating parameters

(ex, scrubber flow, ORP, fan amps) are within

allowable limits. (3) Ensure Bleach washer hood

doors and tube sample doors are

closed.(4)Reduce chemical application

rates.(5)Shut off chlorine dioxide flow at least 5

minutes before stock flow is cut off to allow ClO2

to be fully reacted.

Bleaching SCBR 610 1 1 1 emission unit and control device operates in

compliance with NESHAP parameter limits

during emission unit startup

When there is 500 gpm or more

stock flow out of level chest,

ClO2 flows to both the 10B and

40B Towers are greater than 5

gpm, caustic flow is at least 0.5

gpm, all towers and vats are full

and a target brightness of at

least 85 GE is achieved

1 1 emission unit and control device operates in

compliance with NESHAP parameter limits

during emission unit shutdown

Bleaching SCBR 610 1 1 1 emission unit and control device operates in

compliance with NESHAP parameter limits

during emission unit startup

when there is 800 gpm or more

stock flow out of level chest,

ClO2 flows to both the 10A and

40A Towers are greater than 5

gpm, caustic flow is at least 0.5

gpm, all towers and vats are full

and a target brightness of at

least 85 GE is achieved

1 1 emission unit and control device operates in

compliance with NESHAP parameter limits

during emission unit shutdown

Bleaching SCBR 615 5 1 1 Unit is only started if the associated collection

system is operating

Stock flow is established

through entire bleach line

0.5 0.5 Associated collection system is operated through

duration of shutdown

Bleaching SCBR 617 1 3 hours 3 start up bleach plant scrubber prior to collecting

gases

when scrubber operating

parameter limits are achieved

for 3 hours

0.25 hours 0.25 continue routing emissions to bleach plant

scrubber

Bleaching SCBR 617 1 6 hours

(empty

towers, stock

in front end

to out the

last washer)

6 start up bleach plant scrubber prior to process

start‐up

when scrubber operating

parameter limits are achieved

for 3 hours

6 hours (to

completely

empty all

tanks)

6 continue routing emissions to bleach plant

scrubber

Bleaching SCBR 208228535 2 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Completion of 4 hours of

bleached stock flow to pulp

storage

1 1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Bleaching SCBR stack 136 2 NA NA NA NA NA 

Bleaching SCBR1 102 1 NA ‐ no applicable emission or parameter limits NA ‐ no applicable emission or parameter limits

Bleaching SCBR1 102 4 See BP‐VC See BP‐VC See BP‐VC See BP‐VC See BP‐VC 

Bleaching: ClO2 Generator

Bleaching: ClO2 Generator SCBR 112 1 1 1 When ClO2 solution enters

tanks

continue routing emissions to collection system

and control system

Bleaching: ClO2 Generator SCBR 112 1 1 1 Collection and control systems operating before

start‐up

When ClO2 gasses exits

scrubber

continue routing emissions to collection system

and control system

Bleaching: ClO2 Generator SCBR 115 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Unit is operating and all CMS

parameters within limits

0.5 0.5 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

E1_Bleaching_Equip_detail 
Appendix E1

QAd_ProcessType RTI_APCD_Co

mbo

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Bleaching: ClO2 Generator SCBR 130 1 2 ‐ 8 8 ClO2 Generator operations are only initiated

after the Chilled Water Absorber is funtional and

the Packed Bed Tail Gas Scrubber operating

parameters are satisfied.

Normal operation is achievedwhen the ClO2 Generator is

consistently producing a

concentration of 12 grams/Liter

of ClO2 solution.

2‐8 8 Chilled Water Absorber operation is maintained

and Packed Bed Tail Gas Scrubber operating

parameters remain satisfied until ClO2 Generator

ClO2 gas generation has terminated.

Bleaching: ClO2 Generator SCBR 140 1 Chemicals to generate ClO2 are

going to the reactor vessel. The

scrubber fan is on, the ph of the

scrubber media is greater than

11, and the flow to the scrubber

is greater than the minimum.

The bleach scrubber fan is on, the ph of the

scrubber media is greater than 11, and the flow

to the scrubber is greater than the minimum

until chlorine dioxide generator is shutdown.

Bleaching: ClO2 Generator SCBR 146 1 0.25 0.25 Chlorate is not added to the reactor until the

scrubber pH > 9

Start up begins when chlorate is

added to reactor

0.1 0.1 Scrubber operation continues until the reactor is

empty

Bleaching: ClO2 Generator SCBR 147 1 0.25 0.25 Chlorate is not added to the reactor until the

scrubber pH > 9

Start up begins when chlorate is

added to reactor

0.1 0.1 Scrubber operation continues until the reactor is

empty

Bleaching: ClO2 Generator SCBR 150 1 0.3 0.3 continue routing emissions to primary control

system SCRBR8

Shut down chemical pumps

(Methanol in particular)

0.3 0.3 continue routing emissions to primary control

system SCRBR8

Bleaching: ClO2 Generator SCBR 152 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

chemical feed to the generator

is initiated

4 4 emission unit and control device operates in

compliance with NESHAP parameter limits

during emission unit shutdown

Bleaching: ClO2 Generator SCBR 184 2 Continue routing emissions to scrubber

collection system.

Bleaching: ClO2 Generator SCBR 185 2 <1.0 hour 1 In accordance with the IOM/SOP, whenever the

bleack plant or ClO2 generator are operating, the

associated scrubber must also be in operation

with all continuous monitoring parameters

within their specified limits.

When generating ClO2 above

2.0 g/L.

<1.0 hour 1 In accordance with the IOM/SOP, the control

device will continue to operate while the

emission unit is shutdown.

Bleaching: ClO2 Generator SCBR 186 1 1 1 1 1Bleaching: ClO2 Generator SCBR 193 1 Scrubber compliance parameters met during

startup

Scrubber compliance parameters met duringshutdown

Bleaching: ClO2 Generator SCBR 198 1 0.083 0.083 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

stock flow and chemcial feed

with normal operating ranges,

no alarms

0.083 0.083 continue routing emissions to bleach plant

scrubber

Bleaching: ClO2 Generator SCBR 198 1 0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

stock flow and chemcial feed

with normal operating ranges,

no alarms

0.25 0.25 continue routing emissions to bleach plant

scrubber

Bleaching: ClO2 Generator SCBR 203 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

ClO2 solution flow to storage

tanks established (divert valve

status = “Storage”)

1.5 1.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Bleaching: ClO2 Generator SCBR 243 1 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Acid and steam is introduced

into generator and nominal

chlorine dioxide production by

unit

0.25 0.25 Continue operating scrubber during shutdown

activities

Bleaching: ClO2 Generator SCBR 525 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

all vent gases from process

equipment, that use

chlorinated compounds, are

being collected and sent to the

Bleach Plant Scrubber

0.1 0.1 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

Bleaching: ClO2 Generator SCBR 615 1 1 1 Unit is only started if the associated collection

system is operating

Stock flow is established

through entire bleach line

0.5 0.5 Associated collection system is operated through

duration of shutdown

max 20 max 24

min 0 min 0

avg 3.7 avg 3.4

median 1.0 median 1.0

E1_Bleaching_Equip_detail 
Appendix E2

Information from PI Controls tab for Bleach Plant Scrubbers
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

100 Kraft NEI40686 100‐‐BPSCRB Bleaching: Scrubber PBSCBR NA UK UK White Liquor Yes 

102 Kraft NEI42341A 102‐‐BPS Bleaching SCBR White liquor 14 11 4 Five caternary grids fresh water Yes 

102 Kraft NEI42341A 102‐‐CD‐H2S Bleaching: ClO2 Generator SCBR Caustic 300 0.7 pvc fresh water Yes 

102 Kraft NEI42341A 102‐‐HYPO‐T Bleaching: ClO2 Generator SCBR Caustic 955 15 pvc fresh water Yes 

102 Kraft NEI42341A 102‐‐CD‐PS Bleaching: ClO2 Generator SCBR Caustic 199 0.1 stainless steel fresh water Yes 

102 Kraft NEI42341A 102‐‐HCl‐TG Bleaching: ClO2 Generator SCBR NA 26 7 14 NA ‐ Falling film fresh water No 

102 Kraft NEI42341A 102‐‐HClRRS Bleaching: ClO2 Generator SCBR NA 33 7 20 NA fresh water No 

102 Kraft NEI42341A 102‐‐HClSTP Bleaching: ClO2 Generator OTH NA NA fresh water No 

103 Kraft NEI9201 103‐‐BPS6, BPS7 Bleaching SCBR White Liquor 0.01 10 process water {white liquor} Yes 

103 Kraft NEI9201 103‐‐BPS6, BPS7 Bleaching SCBR White Liquor 0.02 10 5 process water {white liquor} Yes 

106 Soda NEI41599 106‐‐BPSCR Bleaching SCBR NaOH, Na2S2O3 0.84 NA fresh water Yes

107 Kraft NEI47074 107‐‐06‐P10 Bleaching SCBR White Liquor 35 4

CPCV Super interlock

saddle mixture {white liquor makeup} Yes 

109 Kraft NEI32869A 109‐‐BPSBR Bleaching SCBR white liquor 184 1.66 fresh water Yes 

111 Kraft NEI45206 111‐‐CD 425‐101 Bleaching; Wastewater (Kraft) SCBR Caustic 19.7

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

111 Kraft NEI45206 111‐‐CD 430‐531 Bleaching: ClO2 Generator PBSCBR CPVC fresh water No

112 Kraft NEI34064 112‐‐AA‐050b Bleaching: Scrubber SCBR Spent NaOH from EO tower 55 10.9 Mill Water 

112 Kraft NEI34064 112‐‐AA‐071 Bleaching SCBR Mill Water No 

114 Kraft NEI26506 114‐‐CDP3 Bleaching: ClO2 Generator PBSCBR 100 plastic packing surface water No115 Kraft NEI26476 115‐‐BL1S

Bleaching; Bleaching: ClO2

Generator

115 Kraft NEI26476 115‐‐BL01 Bleaching SCBR NaOH

0.283333333333333 11.4 11.7 fresh water Yes 

115 Kraft NEI26476 115‐‐CD01 Bleaching: ClO2 Generator SCBR fresh water Yes 

124 Kraft NEI8278 124‐‐BPSCBR Bleaching PBSCBR weak wash 37.5 9 plastic saddles weak wash Yes 

130 Kraft NEI18338 130‐‐18BPSC Bleaching: Scrubber PBSCBR

Weak Wash (White Liquor used as

back‐up scrubbing medium) 53 Saddles NA NA 

130 Kraft NEI18338 130‐‐CLOSCR Bleaching: ClO2 Generator PBSCBR

Weak Wash (White Liquor used as

back‐up scrubbing medium) 116 420 CPVC Saddles NA NA 

131 Kraft, Secondary NEI42254 131‐‐BP‐CD Bleaching PBSCBR NaOH, NaHS 43.2 11

Norton 2" PVC

Interlox Saddles

process water {specify source} White

water Yes 

133 Kraft NEI13363 133‐‐BPSE Bleaching SCBR white liquor 18 plastic packing

135 Kraft NEI33118 135‐‐008‐2 Bleaching SCBR white liquor 15 2.9 ceramic saddles water is not used in the scrubber Yes 

135 Kraft NEI33118 135‐‐008‐1 Bleaching SCBR white liquor 45 9 2 Lantec plastic packing water is not used in the scrubber Yes 

136 Kraft NEI12368 136‐‐CE 011 Bleaching SCBR White Liquor 32 11 2 NA NA NA 

137 Kraft NEI26581 137‐‐PC(48) Bleaching SCBR caustic & weak wash 43.45 10.6 40 NA NA Yes 

137 Kraft NEI26581

137‐‐PC(106) &PC(106)S Bleaching PBSCBR caustic 46.71 9.6 0.5 metal saddles mill water Yes 

137 Kraft NEI26581 137‐‐PC(107) Bleaching PBSCBR weak wash 36.13 11.1 40 saddles NA Yes 

138 Kraft NEI18652 138‐‐SCRB R8 Bleaching Absorber 125 7.5 125 fresh water No

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

138 Kraft NEI18652 138‐‐SCRB BL1 Bleaching PBSCBR Caustic 125 10.7 plastic packing process water {weak wash} Yes 

140 Kraft NEI13340

140‐‐431‐550

Bleach Plant

Scrubber

Bleaching; Bleaching: ClO2

Generator SCBR white liquor 0.004 4

Spray Nozzles to

produce small

droplets. process water with white liquor addition Yes 

145 Kraft NEI33135 145‐‐BR002‐02C SCBR Caustic/weak WL 11 Ceramic fresh water

146 Kraft NEI759 146‐‐BLL01 Bleaching PBSCBR White Liquor/Caustic 12 10 50 Plastic packing Process Water (Extraction Stage Filtrate) Yes 

146 Kraft NEI759 146‐‐BLL02 Bleaching PBSCBR White Liquor/Caustic 19 10 Plastic packing fresh water Yes 

146 Kraft NEI759 146‐‐BLL01 Bleaching PBSCBR White Liquor/Caustic 12 11 50 Plastic packing Process Water (Extraction Stage Filtrate) Yes 

146 Kraft NEI759 146‐‐CLO02 Bleaching: ClO2 Generator SCBR White Liquor 25 10 ceramic packing fresh water Yes 

147 Kraft NEI6450 147‐‐C‐150 Bleaching: ClO2 Generator Absorber Chilled Water / White Liquor 30 12 2 NA fresh water Yes 

147 Kraft NEI6450 147‐‐C‐137 Bleaching PBSCBR White Liquor ‐ Caustic 241 11.5 5.5 plastic packing fresh water Yes 

147 Kraft NEI6450 147‐‐C‐138 Bleaching SCBR White Liquor ‐ Caustic 435 11.8 3 NA fresh water Yes 

149 Kraft NEI40488

149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109 Bleaching SCBR EO Filtrate & 9% caustic 70 10.5 No water used No

149 Kraft NEI40488

149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109 Bleaching PBSCBR None NA 8 14 spherical balls process water ‐ chill water No

149 Kraft NEI40488

149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109 Bleaching PBSCBR None NA 8 65 spherical balls process water ‐ #2 Soft water No

149 Kraft NEI40488

149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109 Bleaching PBSCBR 9% Caustic 12.5 11.5 spherical balls No water used No

150 Kraft, Mechanical NEI6273

150‐‐SCRBA,SCRBB Bleaching PBSCBR White Liquor 47 13 6.2 2" CPVC Saddles fresh water Yes 

150 Kraft, Mechanical NEI6273

150‐‐SCRBA,SCRBB Bleaching PBSCBR White Liquor 47 13 2.9 2" CPVC Saddles fresh water Yes 

150 Kraft, Mechanical NEI6273 150‐‐SCRBR8 Bleaching: ClO2 Generator SCBR White Liquor 65 13 0.5 fresh water Yes 

152 Kraft NEI11338 152‐‐51‐SCBR Bleaching PBSCBR white liquor 62.8 10.8 4.9 2" HiFlow PVC fresh water Yes 

152 Kraft NEI11338 152‐‐R8‐SCBR Bleaching: ClO2 Generator PBSCBR fresh water 98 94

chemical porcelain

"Super Intalox" fresh water No 

154 Kraft NEI46739 154‐‐C19 & C08 Bleaching PBSCBR

White liquor and/or caustic

solution 48 10.9 2 CPVC/polypropylene

process water {white liquor) or caustic

solution Yes

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

154 Kraft NEI46739 154‐‐C19 & C08 Bleaching PBSCBR

White liquor and/or caustic

solution 50 9.8 3.4 CPVC/Kynar

process water {white liquor) or caustic

solution Yes 

155 Kraft, Mechanical NEI33883

155‐‐BP

SCRUBBER 1/BPSCRUBBER 2 Bleaching SCBR WEAK WASH; WHITE LIQUOR 28 340

155 Kraft, Mechanical NEI33883

155‐‐BP

SCRUBBER 1/BPSCRUBBER 2 Bleaching SCBR WEAK WASH; WHITE LIQUOR 26 330

157 Kraft NEI33104

157‐‐HVLC1/HVLC2/HVLC3

Bleaching; Kraft Pulping:

Washing; Kraft Pulping:Knotter/Screen OTH

157 Kraft NEI33104

157‐‐HVLC1/HVLC2/H

VLC3

Bleaching; Kraft Pulping:Washing; Kraft Pulping:Knotter/Screen PBSCBR plastic packing fresh water No 

157 Kraft NEI33104

157‐‐HVLC1/HVLC2/HVLC3

Bleaching; Kraft Pulping:Washing; Kraft Pulping:Knotter/Screen SCBR Caustic 0.1 13 0.5

158 Sulfite‐NH3 NEI42385 158‐‐BLSCRB Bleaching SCBR Caustic and NaSH 26 10 fresh water Yes 

162 Kraft NEI46760 162‐‐402A Bleaching PBSCBR white liquor 35 11 6

Intalox Snowflake,

CPVC mill water Yes 

162 Kraft NEI46760 162‐‐401U Bleaching PBSCBR white liquor 76 11 4

Intalox Snowflake,

CPVC mill water Yes 

165 Kraft NEI41628 165‐‐000029 Bleaching Absorber Weak wash, 2%

12.8205128205128 20

Norton 2" CPVC

Intalox Saddles process water {weak wash, 2%} Yes 

165 Kraft NEI41628 165‐‐000030 Bleaching Absorber Weak wash, 2%

15.5555555555556 20

Norton 2" CPVC

Intalox Saddles process water {weak wash, 2%} Yes 

165 Kraft NEI41628 165‐‐000031 Bleaching Absorber Weak wash, 2%

53.3333333333333 100

Norton 2" CPVC

Intalox Saddles process water {weak wash, 2%} Yes 

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

166 Kraft NEI41314 166‐‐C Scrubber Bleaching SCBR caustic UK 14 process water {weak wash} Yes 

166 Kraft NEI41314

166‐‐A&BScrubber Bleaching SCBR caustic UK 12 process water {weak wash} Yes 

171 Kraft NEI18658 171‐‐027 Bleaching SCBR UK 13 350 weak wash Yes 172 Kraft, Secondary NEI18335

172‐‐BP02

Scrubber1,BP02Scrubber2 Bleaching; Pulp Storage SCBR

Weak Wash (primary)/White

Liquor (backup for ORPmanagement) ~40 10 UK NA ‐ Weak Wash/White Liquor is scrubbingNA 

172 Kraft, Secondary NEI18335

172‐‐BP02Scrubber1,BP02Scrubber2 Bleaching; Pulp Storage SCBR

Weak Wash (primary)/WhiteLiquor (backup for ORPmanagement) ~40 10 UK NA ‐ Weak Wash/White Liquor is scrubbingNA 

172 Kraft, Secondary NEI18335

172‐‐BP01Scrubber1,BP01Scrubber2 Bleaching SCBR

Weak Wash (primary)/White

Liquor (backup for ORPmanagement) ~45 35 UK NA ‐ Weak Wash/White Liquor is scrubbingNA 

172 Kraft, Secondary NEI18335

172‐‐BP01Scrubber1,BP01Scrubber2 Bleaching SCBR

Weak Wash (primary)/White

Liquor (backup for ORPmanagement) ~45 5 UK NA ‐ Weak Wash/White Liquor is scrubbingNA 

173 Kraft NEI35908 173‐‐BP0094 Bleaching PBSCBR Weak wash and/or white liquor UK 50 Plastic (Saddle)

process water ‐  Weak wash and/or white

liquor Yes 

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

174 Kraft NEI40247 174‐‐G‐21SCRUB Bleaching SCBR Whilte Liquor 4.48‐5.12 11.8 Mill water Yes 

175 Kraft NEI26514 175‐‐BP3B Bleaching PBSCBR Weak Wash 48 10 1538

3.5in Rauschert

Hiflow rings weak wash with backup digester white liqu

175 Kraft NEI26514 175‐‐BP2B Bleaching PBSCBR Weak Wash 25 10 534

#2 & 3 CPVC Super

Intalox Saddles weak wash with backup digester white liqu

177 Kraft NEI33887 177‐‐CD0501 Bleaching PBSCBR White Liquor 13.4 13 0.5 2" CPVC Telerrettes Use white liquor only NA 

177 Kraft NEI33887 177‐‐CD0502 Bleaching PBSCBR White Liquor 12.65 13 1.5 2" CPVC Telerrettes Use white liquor only NA 

178 Kraft NEI26309 178‐‐05C016 Bleaching PBSCBR White Liquor 14.5

CPVC 2 in tellerette

type R white liquor Yes 

178 Kraft NEI26309 178‐‐05C016 Bleaching PBSCBR White Liquor 14.5

CPVC 2 in tellerette

type R white liquor Yes 

179 Kraft NEI45474

179‐‐BP1SCR,

BP2SCR Bleaching PBSCBR White Liquor 90‐100 10

CPVC and Kynar

Saddles fresh water Yes 

179 Kraft NEI45474

179‐‐BP1SCR,

BP2SCR Bleaching PBSCBR White Liquor 40‐50 9

CPVC and Kynar

Saddles fresh water Yes 

182 Kraft NEI7181 182‐‐C113A Bleaching SCBR White wash 20 150 mill water Yes 

183 Kraft NEI33103 183‐‐Scrb4 Bleaching PBSCBR NaOH/caustic 10

183 Kraft NEI33103 183‐‐Scrb1 Bleaching: ClO2 Generator PBSCBR NaOH/caustic184 Kraft NEI46817 184‐‐BP2SCB

Bleaching: Scrubber;Bleaching; Bleaching: ClO2

Generator PBSCBR caustic 72 10 3 CPVC saddles mill water (groundwater source) Yes 

184 Kraft NEI46817 184‐‐BP3SCB

Bleaching: Scrubber;Bleaching; Bleaching: ClO2Generator PBSCBR caustic 62 10 3 CPVC saddles mill water (groundwater source) Yes 

184 Kraft NEI46817 184‐‐BP1SCB

Bleaching: Scrubber;Bleaching; Bleaching: ClO2Generator PBSCBR caustic 62 10 3 CPVC saddles mill water (groundwater source) Yes 

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

185 Kraft NEI46599 185‐‐70

Bleaching; Kraft Pulping:Scrubber PBSCBR White Liquor 67.5 11 12

Chlorinated Polyvinyl

Chloride Mill Water Yes 

185 Kraft NEI46599 185‐‐61 Bleaching: ClO2 Generator PBSCBR White Liquor 29.2 12.5 10.3

Chlorinated Polyvinyl

Chloride Mill Water Yes 

186 Kraft NEI18334 186‐‐BP5 Bleaching SCBR Caustic 9.4 1.5 Mill Water Yes 

186 Kraft NEI18334 186‐‐CP10 Bleaching: ClO2 Generator SCBR Caustic 11.8 0.8 ECW Water Yes 186 Kraft NEI18334 186‐‐BP2 Bleaching SCBR Caustic 9.6 5 Mill Water Yes 

189 Kraft NEI54342 189‐‐SN30 Bleaching SCBR NAOH 0.015 9.6 surface water Yes 

193 Sulfite‐NH3 NEI39968 193‐‐00437 Bleaching PBSCBR Sodium Hydrosulfide 62 10.7 1

Norton 2" CPVC Super

Intalox Saddles fresh water Yes 

195 Kraft NEI46835 195‐‐BPSCR Bleaching Scrubber

196 Kraft NEI18660 196‐‐SN‐16 Bleaching PBSCBR Sodium Thiosulfate, White Liquor 6.38 10 17 super intalox saddles fresh water Yes 

196 Kraft NEI18660 196‐‐SN‐18 Bleaching PBSCBR Sodium Thiosulfate, White Liquor 6.38 10 78 super intalox saddles fresh water Yes 

196 Kraft NEI18660 196‐‐SN‐17 Bleaching PBSCBR Sodium Thiosulfate, White Liquor 6.38 10 24 super intalox saddles fresh water Yes 

198

Kraft, Mechanical,

Secondary NEI41565 198‐‐002_S Bleaching: ClO2 Generator SCBR White Liquor UK 13.5 UK NA

198

Kraft, Mechanical,Secondary NEI41565 198‐‐003_S1 Bleaching: ClO2 Generator SCBR UK 200 fresh water Yes 

198

Kraft, Mechanical,

Secondary NEI41565 198‐‐003_S2 Bleaching: ClO2 Generator SCBR Weak Wash UK 9.5 11.5 UK NA 

199 Kraft NEI18390 199‐‐E‐SCBR Bleaching PBSCBR

Weak wash (contains caustic and

residual sulfides) 53 10.3 14 #2 CPVC Saddles fresh water Yes 

199 Kraft NEI18390 199‐‐D‐SCBR Bleaching PBSCBR

Weak wash (contains caustic and

residual sulfides) 56 10.4 30 #2 CPVC Saddles fresh water Yes 

200 Kraft, Mechanical NEI47077 200‐‐5300C Bleaching SCBR weak wash, white liquor, caustic UK 12.1 2.7 CPVC Intalox Saddles NA Yes 

200 Kraft, Mechanical NEI47077 200‐‐1790C Bleaching: ClO2 Generator SCBR chilled water, white liquor UK 107 Super Intalox Saddles fresh water Yes 

200 Kraft, Mechanical NEI47077 200‐‐1790Ca Bleaching: ClO2 Generator SCBR weak wash, white liquor UK 11.8 8 Super Intalox Saddles NA Yes 

201

Kraft, Mechanical,

Secondary NEI7559 201‐‐EQT049 Bleaching SCBR sodium hydrosulfide 16.5 10 0.8 fresh water Yes 

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

202 Kraft NEI12411 202‐‐CE240 Bleaching PBSCBR Caustic Soda (10%)

95.8 gal /1000acfm per 2005

stack test Rashig Saddles Add caustic soda as makeup, not water Yes

202 Kraft NEI12411 202‐‐CE240 Bleaching PBSCBR Caustic Soda (10%)

95.8 gal /1000acfm per 2005

stack test Rashig Saddles Add caustic soda as makeup, not water Yes

203 Kraft, Sulfite‐Na NEI42410 203‐‐BPScrb Bleaching PBSCBR

White Liquor

(Sodium Sulfide / SodiumHydroxide) 41.4 13.5 3.4 plastic packing process water {White Liquor} Yes 

203 Kraft, Sulfite‐Na NEI42410 203‐‐R8VScr Bleaching: ClO2 Generator SCBR

Weak Wash(Sodium Sulfide / SodiumHydroxide) 145 11 90 process water {Weak Wash} No 

203 Kraft, Sulfite‐Na NEI42410 203‐‐R8TScr Bleaching: ClO2 Generator SCBR

White Liquor

(Sodium Sulfide / SodiumHydroxide) 121 13.5 4.5 process water {White Liquor} Yes 

205 Kraft, Secondary NEI8601

205‐‐BPSCL2,BPSCLO, and

BPSSEW Bleaching PBSCBR

white liquor mixed with

extraction‐stage washer filtrate 32 8 220 plastic saddles fresh water No 

205 Kraft, Secondary NEI8601

205‐‐BPSCL2,BPSCLO, and

BPSSEW Bleaching PBSCBR

white liquor mixed with

extraction‐stage washer filtrate 32 8 10 plastic saddles fresh water Yes 

205 Kraft, Secondary NEI8601

205‐‐BPSCL2,

BPSCLO, and

BPSSEW Bleaching PBSCBR

white liquor mixed with

extraction‐stage washer filtrate 32 8 220 plastic saddles fresh water No 

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

206 Kraft NEI40282

206‐‐No. 2BP

Scrubber Bleaching PBSCBR caustic

4.66666666666667E‐02 8.4 plastic fresh water Yes 

206 Kraft NEI40282

206‐‐No. 1BPSCRUB Bleaching PBSCBR caustic

1.58333333333333E‐02 9.2 plastic fresh water Yes 

207 Kraft NEI7104 207‐‐C33

Bleaching; Kraft Pulping:

Decker PBSCBR NaOH/White Liquor 56 10.5 2 Plastic Packing NaOH/White Liquor YES 

239 Nonwood NEW45005 239‐‐SCRB01 Bleaching: ClO2 Generator SCBR NaOH 227 10 40 plasric packing

well water and recirculated scrubber

outlet water Yes 

240 Kraft NEI26526 240‐‐ABC1

Kraft Pulping: Washing;

Bleaching PBSCBR white liquor UK 10.7 plastic packing

mixture {white liquor and process or fresh

water} Yes 

240 Kraft NEI26526 240‐‐BBC1

Bleaching; Kraft Pulping:Washing PBSCBR white liquor UK 10.7 plastic packing

mixture {white liquor and process or fresh

water} Yes 

240 Kraft NEI26526 240‐‐CBC3 Bleaching SCBR

hemicaustic and thiosulfate, or

white liquor UK 10.8

mixture {hemicaustic and thiosulfate or

white liquor, and process or fresh water} Yes 

241 Sulfite‐NH3 NEI26382 241‐‐BPSCRB Bleaching SCBR Caustic 16.3 7.5 3 fresh water Yes 

242 Kraft NEI34066

242‐‐BP‐19, BP‐

20 Bleaching PBSCBR white liquor UK 2.5 plastic packing fresh water No

242 Kraft NEI34066

242‐‐BP‐19, BP‐

20 Bleaching PBSCBR white liquor UK 2.5 plastic packing fresh water No

243 Kraft NEI8196 243‐‐BPS1 Bleaching PBSCBR weak wash/spent caustic 0.037 475 plastic unstructured243 Kraft NEI8196 243‐‐BPS3 Bleaching PBSCBR weak wash/spent caustic 0.013 750 plastic unstructured243 Kraft NEI8196 243‐‐BPS4 Bleaching PBSCBR weak wash/white liquor 0.065 500 plastic unstructured

243 Kraft NEI8196 243‐‐BPS2 Bleaching: ClO2 Generator PBSCBR chilled water NA 350 plastic unstructured451 Secondary NEI11645

451‐‐Scrubber ‐ packed bed Bleaching: Sec Fiber PBSCBR NaOH 13.125 tellerettes

451 Secondary NEI11645

451‐‐Scrubber ‐ packed bed Bleaching: Sec Fiber PBSCBR NaOH 13.125 tellerettes

451 Secondary NEI11645

451‐‐Scrubber ‐ packed bed Bleaching: Sec Fiber PBSCBR NaOH 13.125 tellerettes

451 Secondary NEI11645

451‐‐Scrubber ‐ packed bed Bleaching: Sec Fiber PBSCBR NaOH 13.125 tellerettes

451 Secondary NEI11645

451‐‐Scrubber ‐ packed bed Bleaching: Sec Fiber PBSCBR NaOH 13.125 tellerettes

451 Secondary NEI11645

451‐‐Scrubber ‐ packed bed Bleaching: Sec Fiber PBSCBR NaOH 13.125 tellerettes

525 Kraft NEI8265 525‐‐EU36

Bleaching; Bleaching: ClO2

Generator; Kraft Pulping:

Decker PBSCBR caustic 1 9 1 saddles 

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType RTI_APCDType Scrub_AlkaliType

Scrub_L_G_Ratio_gal_1000acf

m

Scrub_InletLiqui

dpH_num

Scrub_LiquidMake

up_gpm_num Pack_MaterialType Water_Source Water_Recirculat

600 Kraft NEI18357

600‐‐05‐CD‐01‐

002 Bleaching SCBR White Liquor 133.8 gal/1000acfm 593 NA NA 

600 Kraft NEI18357

600‐‐05‐CD‐01‐

001 Bleaching SCBR White Liquor 42.06 gal/1000acfm 736 NA NA 

606 Kraft NEI47091

606‐‐SW1, SW2,

SWP1 Bleaching PBSCBR White liquor or Caustic 71.4 12 4 Metal rings mixture {White Liquor} Yes 

606 Kraft NEI47091

606‐‐SW1, SW2,

SWP1 Bleaching SCBR

process water {reclaimed steam

condensates} Yes 

606 Kraft NEI47091

606‐‐SW1, SW2,

SWP1 Bleaching SCBR

process water {reclaimed steam

condensates} Yes 

610 Kraft, Mechanical NEI6261

610‐‐BBPS1,

BBPS2 Bleaching PBSCBR white liquor

10.0526315789474 12.4 1.5 plastic packing Process water (white liquor, weak wash) Yes 

610 Kraft, Mechanical NEI6261

610‐‐ABPS1,ABPS2 Bleaching PBSCBR white liquor

19.5652173913043 12.9 1.5 plastic packing Process water (white liquor, weak wash) Yes 

610 Kraft, Mechanical NEI6261

610‐‐ABPS1,ABPS2 Bleaching PBSCBR white liquor

18.695652173913 12.7 1.5 plastic packing Process water (white liquor, weak wash) Yes 

610 Kraft, Mechanical NEI6261

610‐‐BBPS1,

BBPS2 Bleaching PBSCBR white liquor

11.6315789473684 12.2 2 plastic packing Process water (white liquor, weak wash) Yes 

615 Kraft NEI40554 615‐‐BPSCRB01

SEE RTI NOTE ‐ Bleaching;Bleaching: ClO2 Generator;

Bleaching: Scrubber SCBR NaOH 20 11 50 process water Yes 

617 Kraft NEI42695 617‐‐C14 Bleaching PBSCBR caustic, ammonium thiosulfate 13 11 2 plastic saddles flltered fresh water Yes 

208228535 Kraft(1) NEI18373

208228535‐‐X020 Bleaching PBSCBR

Weak wash (contains caustic and

sulfides) 23 9.7 4 Plastic saddles fresh water Yes 

208228535 Kraft(1) NEI18373

208228535‐‐X023 Bleaching PBSCBR

Weak wash (contains caustic and

sulfides) 61 9.7 4 Plastic saddles fresh water Yes 

median 10.7 10

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

100‐‐BPSCRB102‐‐BPS102‐‐CD‐H2S102‐‐HYPO‐T

102‐‐CD‐PS102‐‐HCl‐TG102‐‐HClRRS102‐‐HClSTP103‐‐BPS6, BPS7

103‐‐BPS6, BPS7

106‐‐BPSCR107‐‐06‐P10

109‐‐BPSBR111‐‐CD 425‐101

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

pH, Scrubber Liquid Influent Flow Rate NA ~ 2 hrs 2

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate and pH are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses).

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units or

sources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAPonly generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

recirculated scrubbing liquid ORP

(while in primary operating mode),

alkaline bleach plant filtrate feed pH

(in backup operating mode), scrubber

liquid flow, and scrubber fan current 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

caustic flow, scrubbing liquid ORP 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

caustic flow, scrubbing liquid ORP, fan

current 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

caustic flow, hydrogen peroxide flow,

scrubbing liquid ORP Scrubber temperature (140F max) 1 1

The Peroxide Scrubber provides

supplemental control to the Hypo Tower

outlet gas stream, to assure "no visible

emissions". Under normal conditions,

supplementary control is not needed to

achieve this objective.

liquid flow rate temperature (104F design) 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

None 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

None 0 0

Control device is started up and meets

required operating parameter limits before

emission unit is started up. 

pressure drop, test port on inlet and

outlet, site glasses, level gauge 0.5 0.5

The bleach plant scrubber systems must be

started up and operational prior to

introducing vent gases to the control device

or system. This is accomplished by using the

applicable SOP and assured process

interlocks and operator alarms. None

Since this equipment is a control device,

there are no excess emissions during

startup.

pressure drop, test port on inlet and

outlet, site glasses, level gauge 0.5 0.5

The bleach plant scrubber systems must be

started up and operational prior to

introducing vent gases to the control device

or system. This is accomplished by using the

applicable SOP and assured process

interlocks and operator alarms. None

Since this equipment is a control device,

there are no excess emissions during

startup.

oxidation reduction potential (ORP),

pH, inlet pressure, recirculation flow

rate, fan amperage NA 1 ‐ 4 4

Control device is started up and meets

required operating parameter limits before

emission unit is started up. NA

Bleach Plant startup does not begin until

scrubber is running.

ORP (<= ‐400 mV), White liquor

recirculation flow rate (>= 100 gpm),

blower fan amperage (>= 13 Amps)

liquid flow rate, vacuum on collection

system, pH 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Emission Unit is not started until control is

steady state

liquid flow rate, pH 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Meet liquid flow and pH parameters prior

to process startup

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

111‐‐CD 430‐531

112‐‐AA‐050b112‐‐AA‐071114‐‐CDP3115‐‐BL1S115‐‐BL01115‐‐CD01124‐‐BPSCBR130‐‐18BPSC130‐‐CLOSCR131‐‐BP‐CD

133‐‐BPSE135‐‐008‐2

135‐‐008‐1

136‐‐CE 011137‐‐PC(48)137‐‐PC(106) &

PC(106)S137‐‐PC(107)138‐‐SCRB R8

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

liquid flow rate 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Meet liquid flow parameters prior to

process startup

liquid flow rate, pH, fan operation,

stock pH 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Scrubber pH above 8 before pulp flow to

process

water flow, temperature 0 0

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Scrubbant flow rate,

oxidation/reductoin potential, pH

Pressure drop, pH, recirculation flows 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

Ensure that parameters are met prior to

starting integrated component

Pressure drop, pH, recirculation flows 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

Ensure that parameters are met prior to

starting integrated component

pH, gas & liquid flow rate

n/a started prior toemission unit start up

Control device must be in operation before

and after EU startup/shutdown None ‐ control device started before EU 

Scrubber recirculation rate, scrubber

pH, ORP, fan operation

Scrubber recirculation rate: 500GPM, scrubber pH: > 9, ORP: ~ ‐

420 to‐300 milivolts < 1 Hr 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Scrubber recirculation rate, scrubber p

The bleach plant is not started up until the

bleach plant scrubber is started up and

meets its required operating parameter

limits

Scrubber Liquid Recirculation Rate,

Weak Wask Make‐up Flow

Scrubber Liquid Recirculation Rate:

140 ‐ 185 GPM, Weak Wask Make‐

up Flow: 4 ‐ 20 GPM < 1 Hr 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Scrubbing Liquid Flow, ORP

The ClO2 Generator is not started up until

the Tail Gas Scrubber is started up and

meets its required operating parameter

limits.

pH, scrubber reciruclation pump amps,

fan amps 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup NA

Fan status, liquid flow, liquid ORP 0.1 0.1

scrubber operation is established before the

process starts up

fan status 0.5 0.5

The bleach plant scrubber can be started

separate from the startup of the bleaching

system. White liquor needs to be available

from causticizing as the scrubbing media.

If the startup occurs late in the 3‐hr

block average period, and operation

of emission units starts shortlythereafter within the same 3‐hr

period, then the scrubber may show

non compliance due to the averagingof limited data.

Control device is started up prior to

startup of emissions unit.

ORP or pH, fan amps, liquid flow rate 0.5 0.5

The bleach plant scrubber can be started

separate from the startup of the bleaching

system. White liquor needs to be available

from causticizing as the scrubbing media.

If the startup occurs late in the 3‐hr

block average period, and operation

of emission units starts shortlythereafter within the same 3‐hr

period, then the scrubber may show

non compliance due to the averagingof limited data.

Control device is started up prior to

startup of emissions unit.

pH, Flow, fan load ORP, dP 0 0 Independent flow

Do not start process until collection

system operational

pH, flow rate, fan load 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

control device started up prior to starting

equipment

pH, flow rate 20 20

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

control device started up prior to starting

equipment

pH, flow rate, fan load 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

control device started up prior to starting

equipment

liquid flow rate, liquid temperature 0.1 0.1

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

138‐‐SCRB BL1

140‐‐431‐550Bleach Plant

Scrubber145‐‐BR002‐02C

146‐‐BLL01146‐‐BLL02146‐‐BLL01146‐‐CLO02147‐‐C‐150

147‐‐C‐137

147‐‐C‐138

149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109150‐‐SCRBA,

SCRBB150‐‐SCRBA,SCRBB150‐‐SCRBR8152‐‐51‐SCBR

152‐‐R8‐SCBR

154‐‐C19 & C08

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

liquid flow rate, pH, fan rpm's 0.1 0.1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

liquid flow rate, pH 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

control device is operating prior to

emission unit start up.

Fan rpm, Recycle gpm, ORP 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

close automatic by‐pass damper on blendchest roof

liquid flowrate, ORP, fan load NA 0.25 0.25

Chlorine dioxide addition is not allowed until

the scrubber flowrate meets the required

level

Flowrate setpoint must be met prior

to introduction of ClO2

Chlorine dioxide addition is not allowed

until the scrubber flowrate meets the

required level

liquid flowrate, ORP, gas flowrate NA 0.25 0.25

Chlorate addition is not allowed until the

scrubber flowrate meets the required level

Flowrate setpoint must be met priorto introduction of ClO2

Chlorate addition is not allowed until the

scrubber flowrate meets the required level

liquid flowrate, ORP, fan load NA 0.25 0.25

Chlorine dioxide addition is not allowed until

the scrubber flowrate meets the required

level

Flowrate setpoint must be met prior

to introduction of ClO2

Chlorine dioxide addition is not allowed

until the scrubber flowrate meets the

required level

pH, liquid flowrate NA 0.25 0.25

Chlorine dioxide addition is not allowed until

the scrubber flowrate meets the required

level

Flowrate setpoint must be met prior

to introduction of ClO2

Chlorate addition is not allowed until the

scrubber flowrate meets the required level

Liquid flow rate, pH NA 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

liquid flow rate, pH, Amperage, Temp NA 0.1 0.1

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Instant On Flow circulated through start‐up 

liquid flow rate, pH, Amperage, Temp NA 0.1 0.1

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Instant On Flow circulated through start‐up 

pH, liquid flow rate, scrubber fan "ON" 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

Emission unit not operating until APCD

startup complete

NA Water flow to scrubber (16 gpm) 0.25 0.25

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

Emission unit not operating until APCD

startup complete

NA

Chilled water flow to scrubber (65

gpm), ClO2 scrubber sump level

control 0.25 0.25

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

Emission unit not operating until APCD

startup complete

NA

Level control in scrubber sump,

circulation flow to the scrubber

(28 gpm) 0.25 0.25

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

Emission unit not operating until APCD

startup complete

recycle flow rate, pressure drop,

recycle flow ORP, fan amperage 0.2 0.2

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

meet recirc flow parameter and ORP set

point before starting associated emission

units

recycle flow rate, pressure drop,

recycle flow ORP, fan amperage 0.2 0.2

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

meet recirc flow parameter and ORP set

point before starting associated emission

units

recycle flow rate, pressure drop,

recycle flow ORP, fan on/off status 0.2 0.2

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

meet recirc flow parameter and ORP set

point before starting associated emission

units

liquid flow rate, pH, air flow 0.25 0.25

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

meet recirculation rate and pH set points

prior to starting associated emission units

liquid flow rate 0.25 0.25

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

meet chilled water flow rate prior to

starting emission units 

fan amps, recirculation flow,

recirculation pH

Scrubber pressure drop, caustic

material addition rate, inlet

pressure, stack pressure lower

demister pressure drop 0.5 0.5

Control device is not dependent on emission

uit startup or operation. The control device is

started prior to process operation and is not

shutdown until after process shutdown iscomplete. None

Process is not started until scrubber is

running

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

154‐‐C19 & C08

155‐‐BP

SCRUBBER 1/BP

SCRUBBER 2155‐‐BP

SCRUBBER 1/BP

SCRUBBER 2157‐‐HVLC1/HVLC2/HVLC3157‐‐HVLC1/HVLC2/HVLC3157‐‐HVLC1/HVLC2/HVLC3158‐‐BLSCRB162‐‐402A162‐‐401U165‐‐000029165‐‐000030165‐‐000031

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

fan amps, recirculation flow,

recirculation pH

Scrubber pressure drop, caustic

material addition rate, inlet

pressure, stack pressure 0.5 0.5

Control device is not dependent on emission

unit startup or operation. The control device

is started prior to process operation and is

not shutdown until after process shutdown is

complete. None

Process is not started until scrubber is

running

ORP, liquid flow rate, pressure drop 0.5 0.5

scrubber startup achieved in advanced of

bleach plant vent collection system

operation The applicable emission and parameteORP and liquid flow rate maintained

ORP, liquid flow rate, pressure drop 0.5 0.5

scrubber startup achieved in advanced of

bleach plant vent collection system The applicable emission and parameteORP and liquid flow rate maintained

0 0

Control device cannot function as designed

unless both TRS and chlorine compounds are

being introduced into the mixer

0 0

liquid flow rate 0 0liquid flow, oxidation/reduction

potential fan amps (40‐60) 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up. None

Ensure scrubberant is circulating and pH

and ORP are at target levels throughout

startup.

Scrubber Liquid recirculation flow,

influent pH, fan operation (amps) NA 1 1

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met

"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units or

sources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAP

only generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

Scrubber Liquid recirculation flow,

caustic makeup flow, effluent pH, fan

operation (amps) NA 1 1

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAP

only generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

Liquid flow rate, liquid pH, fan motor

current 0.5 0.5

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAP

only generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

Liquid flow rate, liquid pH, fan motor

current 0.3 0.3

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met

"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units or

sources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAPonly generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

Liquid flow rate, liquid pH, fan motor

current 0.5 0.5

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAPonly generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

166‐‐C Scrubber166‐‐A&B

Scrubber171‐‐027172‐‐BP02

Scrubber1,BP02Scrubber2172‐‐BP02Scrubber1,BP02Scrubber2172‐‐BP01Scrubber1,BP01Scrubber2172‐‐BP01Scrubber1,BP01Scrubber2173‐‐BP0094

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

ORP, flow, fan status

Hot Startup: 2‐4 HoursCold Startup: 4‐6 Hours

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units or

sources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAPonly generated by the emission un

sources (i.e., LVHC systems). There 

emissions during startup since the c

device

ORP, flow, fan status

Hot Startup: 2‐4 Hours

Cold Startup: 4‐6 Hours

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units or

sources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAPonly generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

pH

pH of scrubber effluent media, gas

scrubber recirculation flow rate,

constant operation of the fan 0.01 0.01

The scrubber is started when the Bleach

Plant is in operation

The applicable emission and

parameter limits are expected to be

met during startup

The scrubber is started prior to Bleach

Plant operation

liquid flow rate, oxidation/reduction

potential, scrubber fan amps NA

Approximately 1 to 3 hrs

depending on strength of

weak wash 3

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up. Flow rate, pH, fan amps are not met "i

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d There are no HAP emissions as a res

liquid flow rate, oxidation/reduction

potential, scrubber fan amps NA

Approximately 1 to 3 hrs

depending on strength of

weak wash 3

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up. Flow rate, pH, fan amps are not met "i

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d There are no HAP emissions as a res

liquid flow rate, oxidation/reduction

potential, scrubber fan amps NA

Approximately 1 to 3 hrs

depending on strength of

weak wash 3

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up. Flow rate, pH, fan amps are not met "i

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d There are no HAP emissions as a res

liquid flow rate, oxidation/reduction

potential, scrubber fan amps NA

Approximately 1 to 3 hrs

depending on strength of

weak wash 3

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up. Flow rate, pH, fan amps are not met "i

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d There are no HAP emissions as a res

Downtime of scrubber ID fan, scrubber

liquid flow rate, pH of scrubber

effluent NA

Startup from annual

outage = 1 hour. Bleach

plant scrubber not

normally shutdown

during routine

maintenance outages. 1

Bleach plant scrubber is started up and

meets required operating parameter limits

before emission unit is started up.

Flow rate and pH are not met

"instant on". They are transient in

nature (i.e., they change as startupprogresses). Fan On/Off is met

"instant on".

There are no emissions during startup

since the control device is started up and

meets the required operating parameter

limits before emission unit is started up.

Standard operating procedures and

personnel training ensure that the control

device remains

There are no emissions during start

since the control device is started u

meets the required operating param

limits before emission unit is starte

Standard operating procedures and

personnel training ensure that the c

device remains

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

174‐‐G‐21SCRUB

175‐‐BP3B175‐‐BP2B177‐‐CD0501177‐‐CD0502178‐‐05C016178‐‐05C016179‐‐BP1SCR,

BP2SCR179‐‐BP1SCR,

BP2SCR182‐‐C113A183‐‐Scrb4183‐‐Scrb1184‐‐BP2SCB184‐‐BP3SCB184‐‐BP1SCB

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

Liquid flow, pH Scrubber fan running

Hot Startup: 0.5 Hours

Cold Startup: 4 Hours 4

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAPonly generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

ORP, fan amps, flow rate and pressure

drop

Hot Startup: 2‐4 Hours

Cold Startup: 4‐6 Hours 6

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up. Flow rate, pH, fan amps are not met "i

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d There are no HAP emissions as a res

ORP, fan amps, flow rate and pressure

drop

Hot Startup: 2‐4 Hours

Cold Startup: 4‐6 Hours 6

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up. Flow rate, pH, fan amps are not met "i

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d There are no HAP emissions as a res

pH, liquid flow, circulation flow, fan

status

white liquor strength, 0.78 lb/gal

Na2O 0.033 0.033

Scrubber is started up and flows are attained

before emission unit is started The applicable emission and paramete

Emissions unit not operating while

scrubber down

pH, liquid flow, circulation flow, fan

status

white liquor strength, 0.78 lb/gal

Na2O 0.033 0.033

Scrubber is started up and flows are attained

before emission unit is started The applicable emission and paramete

Emissions unit not operating while

scrubber down

pH 12 minimum

temp. 50F maximum, flow 25 gpm

minimum 1 hr 1

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAPonly generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

pH 12 minimum

temp. 50F maximum, flow 25 gpm

minimum 1 hr 1

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up.

Flow rate, pH, fan amps are not met

"instant on". They are transient in

nature (i.e., they changes as startup

progresses). Fan On/Off is met"instant on".

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d

There are no HAP emissions as a res

starting up a control device. Contro

devices do not generate HAPS. HAPonly generated by the emission un

sources (i.e., bleaching systems). Th

no emissions during startup since th

control d

pH, scrubber liquid influent flowrate,

fan RPM 0.5‐1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

N/A ‐ Control device is started up before

process is started up

pH, scrubber liquid influent flowrate,

fan RPM 0.5‐1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

N/A ‐ Control device is started up before

process is started up

recirculation flow, reagent pH fan amperage 0.333333333333333 0.3333333

Emission unit (bleach plant) will not operate

prior to scrubber operation. Meet flow and pH parameters 

dP, pH, flowdP, flow ORPpH, fan amps, recirculation flow 0.75 0.75

Control device is started up and meets

required operating parameter limits before

emission unit is started up. fan amps, recirculation flow

pH, fan amps, recirculation flow 0.75 0.75

Control device is started up and meets

required operating parameter limits before

emission unit is started up. fan amps, recirculation flow

pH, fan amps, recirculation flow 0.75 0.75

Control device is started up and meets

required operating parameter limits before

emission unit is started up. fan amps, recirculation flow

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

185‐‐70185‐‐61186‐‐BP5186‐‐CP10186‐‐BP2189‐‐SN30193‐‐00437195‐‐BPSCR196‐‐SN‐16

196‐‐SN‐18

196‐‐SN‐17

198‐‐002_S198‐‐003_S1198‐‐003_S2199‐‐E‐SCBR199‐‐D‐SCBR200‐‐5300C200‐‐1790C200‐‐1790Ca201‐‐EQT049

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

Fan Amps, Differential Pressure,

Recirculation Flow, pH, and D2 ClO2

Application Rate

White Liquor Flow (average 1‐2

gpm); 0.02 0.02

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup.

Per the SSM and SOP procedures,

operators review the scrubber conditions

(caustic supply, caustic flow, and vent

lines) prior to startup.

Differential Pressure, Recirculation

Flow, and pH

White Liquor Flow (average 0.3

gpm); Fan Amps (20.5 amps) 0.02 0.02

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup.

Per the SSM and SOP procedures,

operators review the scrubber conditions

(caustic supply, caustic flow, and vent

lines) prior to startup.

pH, Recirculation Flow, Scrubber fan

on 0.16 0.16

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

pH, Scrubber flow, and white liquor

flow 0.16 0.16

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

pH, Recirculation Flow, Scrubber fan

on 0.16 0.16

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

amperage, pH 0.15 0.15

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

Per the SSM Plan, met amp and flow limits.

Verify that the Bleach Plant Scrubber iscollecting vent gases from process

equipment that uses chlorinated

compounds. By visual observation, check

for emissions from hoods, and enclosures,

etc.

ph, recirc pump amps, ID fan amps 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

CMS parameters are met before starting

up emission unit 

liquid flow rate, fan amperage, pH

ORP, best practice to maintain

negative 1.5 1.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Establish required parameters prior

to introducing bleach plant gas forscrubbing

Establish required parameters prior to

introducing bleach plant gas for scrubbing

liquid flow rate, fan amperage, pH

ORP, best practice to maintain

negative 1.5 1.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Establish required parameters priorto introducing bleach plant gas for

scrubbing

Establish required parameters prior to

introducing bleach plant gas for scrubbing

liquid flow rate, fan amperage, pH

ORP, best practice to maintain

negative 1.5 1.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Establish required parameters priorto introducing bleach plant gas for

scrubbing

Establish required parameters prior to

introducing bleach plant gas for scrubbing

Re‐circulation flow rate, Fan Motor

Amperage, ORP 0.033 0.033

Control device is started up and meets

required operating parameter limits before

emission unit is started up. ORP

Control device i(or backup device) is

operational before process startup

liquid flow rate water temp (40 ‐ 50 deg F) 0.033 0.033

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Control device i(or backup device) is

operational before process startup

liquid flow rate pH, ORP 0.033 0.033

Control device is started up and meets

required operating parameter limits before

emission unit is started up. ORP

Control device i(or backup device) is

operational before process startup

scrubber recirculating liquid flow,

scrubber effluent pH, and fan

operation (fan motor amperage) NA 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup NA

scrubber recirculating liquid flow,

scrubber effluent pH, and fan

operation (fan motor amperage) NA 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup NA

recirculation flow, pH, fan status NA 0.083 0.083

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

Source generally not operating during

control device startup

NA NA 0.167 0.167

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

Source generally not operating during

control device startup

liquid flow rate, liquid pH, pressure

drop NA 0.167 0.167

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

Source generally not operating during

control device startup

scrubber liquid flow, scrubber effluent

oxidation‐reduction potential, and

scrubber fan motor amperage

Scrubber bypass valve position

(normally closed) 0.2 0.2

Control device is started up and meets

required operating parameter limits before

emission unit is started up. NA NA

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

202‐‐CE240202‐‐CE240203‐‐BPScrb203‐‐R8VScr203‐‐R8TScr205‐‐BPSCL2,

BPSCLO, and

BPSSEW205‐‐BPSCL2,

BPSCLO, and

BPSSEW205‐‐BPSCL2,

BPSCLO, and

BPSSEW

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

Pressure Drop, Liquid Flow, pH based

on 3 hour average Fan running

APCD

_

SU

_

Duration

_

hrs:

0.083 hours ‐ Startup

time estimated to be 1 to2 minutes to get scrubberflow up to rate ‐ a few

more minutes to make

scrubbing effective.Bleach Plant Scrubber

System Normal operating

parameters: (1) Scrubber

Fan (466‐041‐056.F1):

“Running” (2) CirculatingFlow to Chlorine Scrubber

(466‐FIC‐608): 3 121 gpm

(or from test); (3)

Scrubber Medium pH

(466‐AI‐612)): pH>11.4.

Scrubber is broughtonline prior to starting up

the bleach plant. Proper

startup of the bleach

plant scrubber systeminvolves (1) bringing the

scrubber system online,

(2) verifying that thebleach plant scrubbers

are operating within

normal parameter ranges, 0.083

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

Ensure operating parameters are met prior

to starting operation.

Pressure Drop, Liquid Flow, pH based

on 3 hour average Fan running

APCD

_

SU

_

Duration

_

hrs:

0.083 hours ‐ Startup

time estimated to be 1 to2 minutes to get scrubberflow up to rate ‐ a few

more minutes to make

scrubbing effective.Bleach Plant Scrubber

System Normal operating

parameters: (1) Scrubber

Fan (466‐041‐056.F1):

“Running” (2) CirculatingFlow to Chlorine Scrubber

(466‐FIC‐608): 3 121 gpm

(or from test); (3)

Scrubber Medium pH

(466‐AI‐612)): pH>11.4.

Scrubber is broughtonline prior to starting up

the bleach plant. Proper

startup of the bleach

plant scrubber systeminvolves (1) bringing the

scrubber system online,

(2) verifying that thebleach plant scrubbers

are operating within

normal parameter ranges, 0.083

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

Ensure operating parameters are met prior

to starting operation.

other (ORP),liquid flow rate,other (Fan status (off/on)) 0 0

Scrubber operating parameters are

established before starting up bleach plant

The applicable emission and

parameter limits are expected to be

met during startup

Chilled water flow, chilled water

temperature 0 0

Chilled water flow to scrubber is established

before generator is started up The applicable emission and paramete 

Recirculation flow, scrubbing liquid pH 0.16 0.16

Scrubber operating parameters are

established before starting up R8 generator

The applicable emission and

parameter limits are expected to be

met during startup

liquid flow rate, effluent pH, fan

operation (rpm) NA 0.2 0.2

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

liquid flow rate, effluent pH, fan

operation (rpm) NA 0.2 0.2

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

liquid flow rate, effluent pH, fan

operation (rpm) NA 0.2 0.2

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

206‐‐No. 2BP

Scrubber206‐‐No. 1BP

SCRUB207‐‐C33239‐‐SCRB01240‐‐ABC1240‐‐BBC1240‐‐CBC3241‐‐BPSCRB242‐‐BP‐19, BP‐

20242‐‐BP‐19, BP‐

20243‐‐BPS1243‐‐BPS3243‐‐BPS4243‐‐BPS2451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ 

packed bed525‐‐EU36

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

pH, and liquid flow rate 0.5 0.5

Scrubber flows within specification prior to

introducing ClO2 to the bleach stages. pressure drop

Scrubber in operation prior to introducing

ClO2 to bleach line

pH. Liquid flow rate 0.5 0.5

Scrubber flows within specification prior to

introducing ClO2 to the bleach stages. pressure drop

Scrubber in operation prior to introducing

ClO2 to bleach line

recirculation flow, pH, ID fan amps sump level and pressure 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup NA

liquid flow, pH NA 0.1 0.1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup None 

liquid flow rate, pH, and fan amperage 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Control device is started up and

meets required operating parameter

limits before emission unit is started

up.

Control device is started up and meets

required operating parameter limits

before emission unit is started up.

liquid flow rate, pH, and fan amperage 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Control device is started up and

meets required operating parameter

limits before emission unit is started

up.

Control device is started up and meets

required operating parameter limits

before emission unit is started up.

liquid flow rate and pH, and fan

amperage 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

Control device is started up and

meets required operating parameter

limits before emission unit is started

up.

Control device is started up and meets

required operating parameter limits

before emission unit is started up.

ORP, liquid recirculation flow 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

liquid flow rate, fan amps, liquid ORP 0.1 0.1

Ensure water is recirculated through

control device throughout startup

liquid flow rate, fan amps, liquid ORP 0.1 0.1

Ensure water is recirculated through

control device throughout startup

Gas press. Drop, Recirc. Flow, ORP,

liq/air ratio 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Gas press. Drop, Recirc. Flow, liq/air ra

Bring scrubber to permit parameters

before starting up bleach plants

Gas press. Drop, Recirc. Flow, ORP,

liq/air ratio 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Gas press. Drop, Recirc. Flow, liq/air ra

Bring scrubber to permit parameters

before starting up bleach plant

Recirc. Flow, ORP, liq/air ratio 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Recirc. Flow, liq/air ratio

Bring scrubber to permit parameters

before starting up bleach plant

Scrubbant temperature and Flow rate 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up. recirculation flow rate

Bring scrubber to permit parameters

before starting up generator

caustic pH, caustic flow rate, air flow

rate, 0.05‐0.08 0.08

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

introduce chlorine after scrubber is

running and within permit limits

caustic pH, caustic flow rate, air flow

rate, 0.05‐0.08 0.08

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

introduce chlorine after scrubber is

running and within permit limits

caustic pH, caustic flow rate, air flow

rate, 0.05‐0.08 0.08

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

introduce chlorine after scrubber is

running and within permit limits

caustic pH, caustic flow rate, air flow

rate, 0.05‐0.08 0.08

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

introduce chlorine after scrubber is

running and within permit limits

caustic pH, caustic flow rate, air flow

rate, 0.05‐0.08 0.08

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

introduce chlorine after scrubber is

running and within permit limits

caustic pH, caustic flow rate, air flow

rate, 0.05‐0.08 0.08

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

introduce chlorine after scrubber is

running and within permit limits

liquid flow rate, conductivity motor status 0.2 0.2

Control device is started up and meets

required operating parameter limits before

emission unit is started up. The applicable emission and paramete

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

600‐‐05‐CD‐01‐

002600‐‐05‐CD‐01‐

001606‐‐SW1, SW2,

SWP1606‐‐SW1, SW2,

SWP1606‐‐SW1, SW2,

SWP1610‐‐BBPS1,

BBPS2610‐‐ABPS1,

ABPS2610‐‐ABPS1,ABPS2610‐‐BBPS1,

BBPS2615‐‐BPSCRB01617‐‐C14208228535‐‐X020208228535‐‐X023

Parameter_Continuous Parameter_Other APCD_SU_Duration_hrs

APCD_SU_D

uration_hrs

_num APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas Memo_APCD_SU_EmissRednM

ORP, Recycle Flow, Fan Amps White Liquor Flow Rate 0.1 ‐ 0.3 Hrs. 0.3

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up. Flow rate, pH, fan amps are not met "i

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d There are no HAP emissions as a res

ORP, Recycle Flow, Fan Amps White Liquor Flow Rate 0.1 ‐ 0.3 Hrs. 0.3

The bleach plant control device is started up

and meets the required operating parameter

limits before the emission unit is started up. Flow rate, pH, fan amps are not met "i

There are no HAP emissions as a result of

starting up a control device. Control

devices do not generate HAPS. HAPS are

only generated by the emission units orsources (i.e., bleaching systems). There are

no emissions during startup since the

control d There are no HAP emissions as a res

pH, liquid flow rate, scrubber fan

on/off 1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Minimum liquid flow rate

1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Minimum liquid flow rate

1 1

Control device is started up and meets

required operating parameter limits before

emission unit is started up. Minimum liquid flow rate

ph, recirculation flow, amps ORP, DP, makeup flow 0.75 0.75

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

ph, recirculation flow, amps ORP, DP, makeup flow 0.75 0.75

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

ph, recirculation flow, amps ORP, DP, makeup flow 0.75 0.75

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

ph, recirculation flow, amps ORP, DP, makeup flow 0.75 0.75

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

liquid flow rate, pH, pressure drop 0.1 0.1

scrubber parameters established prior to

process startup No "D" stages are allowed to start up

liquid flow rate, ORP, inlet pressure pH (back‐up )3 3

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

device fully started up prior to process

startup

scrubber liquid recirculating flow,

scrubber effluent oxidation/reduction

potential, and fan operation (as

indicated by fan current load) 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

scrubber liquid recirculating flow,

scrubber effluent oxidation/reduction

potential, and fan operation (as

indicated by fan current load) 0.5 0.5

Control device is started up and meets

required operating parameter limits before

emission unit is started up.

The applicable emission and

parameter limits are expected to be

met during startup

max 20min 0avg 0.83median 0.5

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

100‐‐BPSCRB102‐‐BPS102‐‐CD‐H2S102‐‐HYPO‐T

102‐‐CD‐PS102‐‐HCl‐TG102‐‐HClRRS102‐‐HClSTP103‐‐BPS6, BPS7

103‐‐BPS6, BPS7

106‐‐BPSCR107‐‐06‐P10

109‐‐BPSBR111‐‐CD 425‐101

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

~ 2 hrs 2

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate and pH are not met "instant on". They are

transient in nature (i.e., they changes as startup

progresses).

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stoke flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

0 0

BP Scrubber remains in operation until

Bleach Plant processes are shut down

(chlorine dioxide feed to D1 and D2 reactors

is shut off). Fan down and/or scrubber liquid flow shut off.

0 0

Control device is an integral part of

production process and must be up for the

process to operate

0 0

Hypo Tower scrubber remains in operation

until the ClO2 Plant is fully shut down. Fan down and/or scrubber liquid flow shut off.

0 0

Independent; under normal and low load

conditions, Peroxide Scrubber operation is

not required to achive "no visible emissions". Fan down and/or scrubber liquid flow shut off.

0 0

Control device is an integral part of

production process and must be up for the

process to operate

0 0

Control device continues to operate and

meets required operating limits whileemission unit is shut down. Fan and water flow are turned off

0 0

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

0.5 0.5

Control device operates until bleaching lines

have completed start up.

The bleach plant scrubbers will remain in

operation through out the shutdown ofthe bleach plant.

The bleach plant scrubber system will only be

shutdown after brown stock feed and chemical

feeds to the bleach plants are shutdown.

0.5 0.5

Control device operates until bleaching lines

have completed start up.

The bleach plant scrubbers will remain in

operation through out the shutdown of

the bleach plant.

The bleach plant scrubber system will only be

shutdown after brown stock feed and chemical

feeds to the bleach plants are shutdown.

UK

Control device continues to operate and

meets required operating limits whileemission unit is shut down. NA

Shutdown does not begin until the

Bleach Plant is shut down. Bleach plant is shut down.

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

1 1

Control device is shutdown after the

emission unit is shutdown

Control device is shutdown after the

emission unit is shutdown System has been flushed for 1 hour

0.5 0.5

Control device continues to operate and

meets required operating limits while

emission unit is shut down

Maintain liquid flow and pH parameters

until process is shutdown

Brownstock and chemical feed to the Bleach

Plant are shutdown. Bleach Plant collected

sources are offline. s

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

111‐‐CD 430‐531

112‐‐AA‐050b112‐‐AA‐071114‐‐CDP3115‐‐BL1S115‐‐BL01115‐‐CD01124‐‐BPSCBR130‐‐18BPSC130‐‐CLOSCR131‐‐BP‐CD

133‐‐BPSE135‐‐008‐2

135‐‐008‐1

136‐‐CE 011137‐‐PC(48)137‐‐PC(106) &

PC(106)S137‐‐PC(107)138‐‐SCRB R8

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

0.5 0.5

Control device continues to operate and

meets required operating limits whileemission unit is shut down

Maintain liquid flow parameters until

process is shutdown R8 sytem is off line

0.5 0.5

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

Wait until process down to shut down

control Pulp processed through last bleaching stage.

0.5 0.5

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

Wait until process down to shut down

control Raw materials sfeed stoppedto process

0.5 0.5

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

The applicable emission and parameter

limits are expected to be met during

startup No flow

0.5 0.5

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

The applicable emission and parameter

limits are expected to be met during

startup No flow

0 0 n/a no parameters needed with EU down. n/a no measures needed with EU down stop ClO2 feed‐EU shutdown

< 1 Hr 1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

Scrubber recirculation rate, scrubber pH, ORP, fan

operation

The bleach plant scrubber continues to

meet its required operating parameter

limits until the bleach plant shut down

When the bleach plant scrubber can no longer

meet its operating parameter limits, the control

device is considered to have begun its

shutdown

< 1 Hr 1

Control device continues to operate and

meets required operating limits while

emission unit is shut down. Scrubbing Liquid Flow, ORP

The ClO2 Generator Scrubber continues

to meet its operational parameters until

the ClO2 Generator is shutdown.

When the ClO2 Generator Scrubber can no

longer meet its operating parameter limits, the

control device is considered to have begun its

shutdown

1 1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup NA Bleach plant is shut down

0.1 0.1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

fan is turned off and/or liquid flow is turned off

and/or chemical addition is turned off

0.5 0.5

Control device can be operated separatefrom the emissions unit.

If the shutdown occurs early in the 3‐hr block average

period, and operation of emission units stopped shortly

before scrubber shutdown, then the scrubber may

show non compliance due to the averaging of limited

data.

Control device is operated after the

shutdown of emissions unit.

The white liquor addition to the scrubber is

shut off,

0.5 0.5

Control device can be operated separatefrom the emissions unit.

If the shutdown occurs early in the 3‐hr block average

period, and operation of emission units stopped shortly

before scrubber shutdown, then the scrubber may

show non compliance due to the averaging of limited

data.

Control device is operated after the

shutdown of emissions unit.

The white liquor addition to the scrubber is

shut off,

0 0 Independent NA

Shut down process before collection

system shutdown

Loss of established pH, recirculation flow, and

fan load limits

12 12

Control device continues to operate and

meets required operating limits while

emission unit is shut down or re‐routed.

The applicable emission and parameter limits are

expected to be met during startup NA

Flow to No.1 PO Washer > 500 gpm or for 2

hours

1 1

Control device continues to operate and

meets required operating limits whileemission unit is shut down or re‐routed.

The applicable emission and parameter limits are

expected to be met during startup Route NCG back to lime kiln for control

All continuous monitoring parameters at set

point and NCG incinerator is up to

temperature.

12 12

Control device continues to operate and

meets required operating limits whileemission unit is shut down or re‐routed.

The applicable emission and parameter limits are

expected to be met during startup NA Flow to washers at normal rates or for 2 hours

0.1 0.1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup ClO2 Generator shutdown

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

138‐‐SCRB BL1

140‐‐431‐550Bleach Plant

Scrubber145‐‐BR002‐02C

146‐‐BLL01146‐‐BLL02146‐‐BLL01146‐‐CLO02147‐‐C‐150

147‐‐C‐137

147‐‐C‐138

149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109149‐‐SC‐106, SC‐

107, SC‐108, SC‐

109150‐‐SCRBA,

SCRBB150‐‐SCRBA,SCRBB150‐‐SCRBR8152‐‐51‐SCBR

152‐‐R8‐SCBR

154‐‐C19 & C08

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

0.1 0.1

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup bleach plant shutdown

1 1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

bleach plant & generator shutdown

prior to scrubber shutdown.

Shutdown begins after the bleach plant has

been properly shutdown and the clo2 plant has

been properly shutdown.

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup shutdown of No. 2 & No. 3 Bleach Rooms

0.1 0.1

The scrubber operation continues until after

all pulp is processed through the bleach line NA

The scrubber operation continues until

after all pulp is processed through the

bleach line

Shutdown begins when chlorine dioxide

application is stopped

0.1 0.1

The scrubber operation continues until

reactor is empty NA

The scrubber operation continues until

after all pulp is processed through the

bleach line

Shutdown begins when chlorine dioxide

application is stopped

0.1 0.1

The scrubber operation continues until after

all pulp is processed through the bleach line NA

The scrubber operation continues until

after all pulp is processed through the

bleach line

Shutdown begins when chlorine dioxide

application is stopped

0.1 0.1

The scrubber operation continues until the

reactor is empty NA

The scrubber operation continues until

the reactor is empty Shutdown begins when chlorate addition stops

1 1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

0.1 0.1

Control device continues to operate and

meets required operating limits whileemission unit is shut down. Instant off Flow circulated through shutdown Shut off liquid flow

0.1 0.1

Control device continues to operate and

meets required operating limits while

emission unit is shut down. Instant off Flow circulated through shutdown Shut off liquid flow

0 0

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

APCD continues operating until emission

unit shutdown complete No scrubber media flow and fan off

0 0

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

APCD continues operating until emission

unit shutdown complete No scrubber media flow

0 0

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

APCD continues operating until emission

unit shutdown complete No scrubber media flow

0 0

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

APCD continues operating until emission

unit shutdown complete No scrubber media flow

0.2 0.2

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Shutdown associated emission unitsprior to control device shutdown

Emission units are shut down, scrubber fans

and recirculation pumps stopped

0.2 0.2

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Shutdown associated emission units

prior to control device shutdown

Emission units are shut down, scrubber fans

and recirculation pumps stopped

0.2 0.2

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Shutdown associated emission unitsprior to control device shutdown

Emission units are shut down, scrubber fans

and recirculation pumps stopped

0.25 0.25

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

shutdown associated emission units

prior to control device shutdown

emission units are shutdown, scrubber fan and

recirculation pumps are stopped

0.25 0.25

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

shutdown associated emission units

prior to control device shutdown

emission units are shutdown, chilled water is

shut off

0.5 0.5

Control device continues to operate and

meets required operating limits while

emission unit is shut down. None

Control device is not shutdown until

process is down

Recirculation pump is stopped and thescrubber is considered shutdown at that time.

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

154‐‐C19 & C08

155‐‐BP

SCRUBBER 1/BP

SCRUBBER 2155‐‐BP

SCRUBBER 1/BP

SCRUBBER 2157‐‐HVLC1/HVLC2/HVLC3157‐‐HVLC1/HVLC2/HVLC3157‐‐HVLC1/HVLC2/HVLC3158‐‐BLSCRB162‐‐402A162‐‐401U165‐‐000029165‐‐000030165‐‐000031

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

0.5 0.5

Control device continues to operate and

meets required operating limits whileemission unit is shut down. None

Control device is not shutdown until

process is down

Recirculation pump is stopped and the

scrubber is considered shutdown at that time.

0.5 0.5

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup Maintain scrubber liequid feed and ORP. Shut off liquid flow

0.5 0.5

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup Maintain scrubber liequid feed and ORP. Shut off liquid flow

0 00 00 00.25 0.25

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Shutdown affected process unit prior to

shutting down the control device. shut off liquid flow

1 1

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associatedwith equipment malfunctions)

There are no HAP emissions as a resultof shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stock flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

1 1

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associatedwith equipment malfunctions)

There are no HAP emissions as a resultof shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stock flow to the bleach plant

the emission unit is down. The control device

can then be shutdown.

1 1

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stock flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

1 1

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stock flow to the bleach plant

the emission unit is down. The control device

can then be shutdown.

1 1

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stock flow to the bleach plant

the emission unit is down. The control device

can then be shutdown.

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

166‐‐C Scrubber166‐‐A&B

Scrubber171‐‐027172‐‐BP02

Scrubber1,BP02Scrubber2172‐‐BP02Scrubber1,BP02Scrubber2172‐‐BP01Scrubber1,BP01Scrubber2172‐‐BP01Scrubber1,BP01Scrubber2173‐‐BP0094

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

Hot Shutdown: 1 Hour

Cold Shutdown: 4 Hour 4

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stock flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

Hot Shutdown: 1 Hour

Cold Shutdown: 4 Hour 4

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stock flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

0.5 0.5

Control device is not to be shut down while

collecting stream

Control device is not to be shut down

while collecting stream

Bleach plant is down (ClO2 flow less than 5

gpm), then reduction of scrubber liquor flow

Approximately 1 to 3 hrs 3

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stoke flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

Approximately 1 to 3 hrs 3

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stoke flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

Approximately 1 to 3 hrs 3

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stoke flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

Approximately 1 to 3 hrs 3

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stoke flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

0 ‐ 0.08 0.08

Control device (bleach plant scrubber)

continues to operate and meets requiredoperating limits until bleach plant is shut

down.

Flow rate and pH are not met when control device is

shutdown. Fan On/Off is "instant off" when the control

device is shutdown.

There are no emissions during shutdownsince the control device continues to

meet the required operating parameter

limits while the emission unit is

operating. Control device (bleach plant

scrubber) continues to operate and

meets required operating limit

When there is no stock flow and ClO2 to the

bleach plant the emission unit is considered as

having shutdown. The control device can then

be shutdown.

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

174‐‐G‐21SCRUB

175‐‐BP3B175‐‐BP2B177‐‐CD0501177‐‐CD0502178‐‐05C016178‐‐05C016179‐‐BP1SCR,

BP2SCR179‐‐BP1SCR,

BP2SCR182‐‐C113A183‐‐Scrb4183‐‐Scrb1184‐‐BP2SCB184‐‐BP3SCB184‐‐BP1SCB

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

Hot Shutdown: 0.5 Hours

Cold Shutdown: 4 Hours 4

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stoke flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

Hot Shutdown: 1 Hour

Cold Shutdown: 4 Hours 4

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

Hot Shutdown: 1 Hour

Cold Shutdown: 4 Hours 4

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

0.03 0.03

Emission unit must be down before control

device NA

Emission device shuts down prior to

scrubber shutdown Liquid flow<.5 gpm

0.03 0.03

Emission unit must be down before control

device NA

Emission device shuts down prior to

scrubber shutdown Liquid flow< 1.0 gpm

0.5 hr 0.5

Control device continues to operate and

meets required operating limits untilemission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associatedwith equipment malfunctions)

There are no HAP emissions as a resultof shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stoke flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

0.5 hr 0.5

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associatedwith equipment malfunctions)

There are no HAP emissions as a resultof shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When there is no stoke flow to the bleach plant

the emission unit is down. The control devicecan then be shutdown.

0.5‐1 1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

N/A ‐ Process is shut down before

control device shut down commences.

Control device shutdown commences when the

No. 1 Bleach Plant stops running.

0.5‐1 1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

N/A ‐ Process is shut down before

control device shut down commences.

Control device shutdown commences when the

No. 2 Bleach Plant stops running.

0.166666666666667 0.166666667

Control device continues to operate and

meets required operating limits while

emission unit is shut down or re‐routed. shut off liquid flow

0.5 0.5

Control device continues to operate and

meets required operating limits whileemission unit is shut down. fan amps, recirculation flow

Ensure emission unit is down prior to

control device shutdown. liquid flow is reduced below normal rates

0.5 0.5

Control device continues to operate and

meets required operating limits while

emission unit is shut down. fan amps, recirculation flow

Ensure emission unit is down prior to

control device shutdown. liquid flow is reduced below normal rates

0.5 0.5

Control device continues to operate and

meets required operating limits while

emission unit is shut down. fan amps, recirculation flow

Ensure emission unit is down prior to

control device shutdown. liquid flow is reduced below normal rates

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

185‐‐70185‐‐61186‐‐BP5186‐‐CP10186‐‐BP2189‐‐SN30193‐‐00437195‐‐BPSCR196‐‐SN‐16

196‐‐SN‐18

196‐‐SN‐17

198‐‐002_S198‐‐003_S1198‐‐003_S2199‐‐E‐SCBR199‐‐D‐SCBR200‐‐5300C200‐‐1790C200‐‐1790Ca201‐‐EQT049

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

0.02 0.02

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Per the SSM and SOP procedures, the

scrubber will only be shutdown once the

process is completely shutdown.

When ClO2 is no longer being applied and the

Bleach Plant operations are completely

shutdown.

0.02 0.02

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Per the SSM and SOP procedures, the

scrubber will only be shutdown once the

process is completely shutdown.

No longer generating ClO2 (however, normally

leave scrubber running at all times).

0.08 0.08

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

Once Hardwood Bleach Plant and Broke Bleach

Plant are down

0.08 0.08

Control device continues to operate and

meets required operating limits while

emission unit is shut down. Once the ClO2 Generator is down

0.08 0.08

Control device continues to operate and

meets required operating limits whileemission unit is shut down. Once Hardwood Bleach Plant is down

0.25 0.25

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Per the SSM Plan, continue routing to

Bleach Plant Scrubber. Following a

System Outage: Shut down the Bleach

Plant Scrubber following standardoperating procedures. Following a LineOutage: The Crossett Mill will continue

to operate the Bleach Plant Gas

Per the SSM Plan, stop ClO2. Verify that all

Bleach Plant Lines have been completely

shutdown including: All process stock pumps

have been shutdown. The ClO2 generator has

been completely shutdown as indicated by

Methanol flow. Follow the proper shutdown

1 1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

Emission unit is shutdown prior to

initiating shutdown of control device

1 1 If down, Bleach Plant is also shutdown

The applicable emission and parameter limits are

expected to be met during startup

Bleach Plant gases cease prior to

shutdown of control equipment

Bleach Plant gases cease prior to shutdown of

control equipment

1 1 If down, Bleach Plant is also shutdown

The applicable emission and parameter limits are

expected to be met during startup

Bleach Plant gases cease prior to

shutdown of control equipment

Bleach Plant gases cease prior to shutdown of

control equipment

1 1 If down, Bleach Plant is also shutdown

The applicable emission and parameter limits are

expected to be met during startup

Bleach Plant gases cease prior to

shutdown of control equipment

Bleach Plant gases cease prior to shutdown of

control equipment

0.033 0.033

Control device continues to operate and

meets required operating limits whileemission unit is shut down. ORP

control device continues to operate as

long as possible while process shuts

down

scrubbing liquid flow drops below normal

operating range

0.033 0.033

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

control device continues to operate aslong as possible while process shuts

down

scrubbing liquid flow drops below normal

operating range

0.033 0.033

Control device continues to operate and

meets required operating limits whileemission unit is shut down. ORP

control device continues to operate aslong as possible while process shuts

down

scrubbing liquid flow drops below normal

operating range

0.1 0.1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown NA Scrubber recirculation pump is turned off

0.1 0.1

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown NA Scrubber recirculation pump is turned off

0.083 0.083

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Source generally shutdown prior to

control device shutdown Shut off liquid flow

0.167 0.167

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Source generally shutdown prior to

control device shutdown Shut off liquid flow

0.167 0.167

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Source generally shutdown prior to

control device shutdown Shut off liquid flow

0.05 0.05

Control device continues to operate and

meets required operating limits whileemission unit is shut down. NA

Emission unit is shut down before

control device Emission unit is shutdown

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

202‐‐CE240202‐‐CE240203‐‐BPScrb203‐‐R8VScr203‐‐R8TScr205‐‐BPSCL2,

BPSCLO, and

BPSSEW205‐‐BPSCL2,

BPSCLO, and

BPSSEW205‐‐BPSCL2,

BPSCLO, and

BPSSEW

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

Bleach Plant ‐ No stock flow

to D0 tower (466‐041‐009M

is OFF) AND Bleached stock

Flow to high density storage

(466‐041‐043.F1 is OFF) AND

Bleach Plant Scrubber

System ‐ Scrubber Fan (466‐

041‐056.F1): “Off” OR

Circulating Flow to Chlorine

Scrubber (466‐FIC‐608): “No

Flow”

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown including venting

allowance.

Ensure operating parameters are met

throughout operation shutdown.

The control device planned shutdown happens

after there is No stock flow to Do Tower with

operator intending to shutdown bleach plant

operations. Operations normally leaves theAPCD running even if sources shutdown.

Bleach Plant ‐ No stock flow

to D0 tower (466‐041‐009M

is OFF) AND Bleached stock

Flow to high density storage

(466‐041‐043.F1 is OFF) AND

Bleach Plant Scrubber

System ‐ Scrubber Fan (466‐

041‐056.F1): “Off” OR

Circulating Flow to Chlorine

Scrubber (466‐FIC‐608): “No

Flow”

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown including venting

allowance.

0.08 0.08

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Bleach plant stops production before

scrubber shut down pulp production stops

0 0

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

generator shut down before scrubber

shut down generator shut down

0 0

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

generator shut down before scrubber

shut down generator shut down

0.05 0.05

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

Emission unit is shut down before

control device Emission unit is shutdown

0.05 0.05

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

Emission unit is shut down before

control device Emission unit is shutdown

0.05 0.05

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

Emission unit is shut down before

control device Emission unit is shutdown

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

206‐‐No. 2BP

Scrubber206‐‐No. 1BP

SCRUB207‐‐C33239‐‐SCRB01240‐‐ABC1240‐‐BBC1240‐‐CBC3241‐‐BPSCRB242‐‐BP‐19, BP‐

20242‐‐BP‐19, BP‐

20243‐‐BPS1243‐‐BPS3243‐‐BPS4243‐‐BPS2451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ packed bed451‐‐Scrubber ‐ 

packed bed525‐‐EU36

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

0.5 0.5

Control device operates during fiberline

shutdown but may not be able to meetrequired pressure drop pressure drop

Control device remains in operation until

ClO2 is no longer being applied to the

bleach line. Scrubber flows are discontinued

0.5 0.5

Control device operates during fiberline

shutdown but may not be able to meetrequired pressure drop pressure drop

Control device remains in operation until

ClO2 is no longer being applied to the

bleach line. Scrubber flows are discontinued

3 3

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup NA ID fan off, recirculation off, sump empty

0.1 0.1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup None Shutdown of bleaching system

UK

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

Control device continues to operate and meets required

operating limits while emission unit is shut down. UK

Control device shutdown begins after

emissions unit shutdown is complete

UK

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

Control device continues to operate and meets required

operating limits while emission unit is shut down. UK

Control device shutdown begins after

emissions unit shutdown is complete

UK

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

Control device continues to operate and meets required

operating limits while emission unit is shut down. UK

Control device shutdown begins after

emissions unit shutdown is complete

0.5 0.5

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Failure to meet operational parameters due to

shutdown.

0.1 0.1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

Control device continues to operate and

meets required operating limits while

emission unit is shut down. Bleaching chemical off to bleaching system

0.1 0.1

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

Control device continues to operate and

meets required operating limits whileemission unit is shut down. Bleaching chemical off to bleaching system

0 0

Scrubber can go down at any time

independent of emission source. Gas press. Drop, Recirc. Flow, liq/air ratio

Continue to operate scrubber until

bleach plants are down.

Scrubber no longer achieves all permit

parameter limits and the bleach plant is down

0 0

Scrubber can go down at any timeindependent of emission source. Gas press. Drop, Recirc. Flow, liq/air ratio

Continue to operate scrubber until

bleach plant is down.

Scrubber no longer achieves all permit

parameter limits and the bleach plant is down

0 0

Scrubber can go down at any time

independent of emission source. Recirc. Flow, liq/air ratio

Continue to operate scrubber until

bleach plant is down.

Scrubber no longer achieves all permit

parameter limits and the bleach plant is down

0 0

Scrubber can go down at any timeindependent of emission source. recirculation flow rate

Continue to operate scrubber until

generator is down.

Scrubber no longer achieves all permit

parameter limits and the generator is down

0.05‐0.08 0.08

Control device continues to operate and

meets required operating limits until after

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Emissions unit is shut down first.

Scrubber continues to run. chlorine flow is shut off

0.05‐0.08 0.08

Control device continues to operate and

meets required operating limits until after

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Emissions unit is shut down first.

Scrubber continues to run. chlorine flow is shut off

0.05‐0.08 0.08

Control device continues to operate and

meets required operating limits until after

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Emissions unit is shut down first.

Scrubber continues to run. chlorine flow is shut off

0.05‐0.08 0.08

Control device continues to operate and

meets required operating limits until after

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Emissions unit is shut down first.

Scrubber continues to run. chlorine flow is shut off

0.05‐0.08 0.08

Control device continues to operate and

meets required operating limits until after

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Emissions unit is shut down first.

Scrubber continues to run. chlorine flow is shut off

0.05‐0.08 0.08

Control device continues to operate and

meets required operating limits until after

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

Emissions unit is shut down first.

Scrubber continues to run. chlorine flow is shut off

1 1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup scrubber pump down

E2_bleaching_controls Table is 3 pages wide 
Appendix E2. Information from PI Controls tab for Bleach Plant Scrubbers

RTI_APCDID

600‐‐05‐CD‐01‐

002600‐‐05‐CD‐01‐

001606‐‐SW1, SW2,

SWP1606‐‐SW1, SW2,

SWP1606‐‐SW1, SW2,

SWP1610‐‐BBPS1,

BBPS2610‐‐ABPS1,

ABPS2610‐‐ABPS1,ABPS2610‐‐BBPS1,

BBPS2615‐‐BPSCRB01617‐‐C14208228535‐‐X020208228535‐‐X023

APCD_SD_Duration_hrs

APCD_SD_Dur

ation_hrs_nu

m APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas APCD_SD_MarkBegin

0.1 ‐ 0.3 Hrs. 0.3

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When stock pumps to T15, T45, T55 are less

than 4%; ClO2 pumps in Bleach Plant chemical

area are less than 4%

0.1 ‐ 0.3 Hrs. 0.3

Control device continues to operate and

meets required operating limits until

emission unit is shut down.

Flow rate, pH, fan amps are not met when control

device is shutdown. Fan On/Off is "instant off" when

the control device is shutdown.

SHUTDOWN (Does not include

unplanned shutdown events associated

with equipment malfunctions)

There are no HAP emissions as a result

of shutting down a control device.

Control devices do not generate HAPS.

HAPS are only generated by the

emission unit o

When stock pumps to stock pumps to CD Stage

and D Stage are less than 4%; Repulper motor

loads on CD Washer and D Washer are less

than 4%; and ClO2 pumps in Bleach Plant

chemical area are less than 4%.

0.5 0.5

Process is completely shutdown prior to

control device shutdown Minimum liquid flow rate

Maintain minimum liquid flow rate until

shutdown complete Stop feeding pulp to bleach plant

0.5 0.5

Process is completely shutdown prior to

control device shutdown Minimum liquid flow rate

Maintain minimum liquid flow rate until

shutdown complete Stop feeding pulp to bleach plant

0.5 0.5

Process is completely shutdown prior to

control device shutdown Minimum liquid flow rate

Maintain minimum liquid flow rate until

shutdown complete Stop feeding pulp to bleach plant

0.25 0.25

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

Process shutdown prior to control device

shutdown

Bleach plant process equipment is completely

shutdown before scrubber are shutdown

0.25 0.25

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

Process shutdown prior to control device

shutdown

Bleach plant process equipment is completely

shutdown before scrubber are shutdown

0.25 0.25

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

Process shutdown prior to control device

shutdown

Bleach plant process equipment is completely

shutdown before scrubber are shutdown

0.25 0.25

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

Process shutdown prior to control device

shutdown

Bleach plant process equipment is completely

shutdown before scrubber are shutdown

0.1 0.1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

0.25 0.25

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during startup

device is fully operational until process is

shut down bleach plant process shutdown is complete

0.1 0.1

Control device continues to operate and

meets required operating limits whileemission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

Bleach plant is shut down; scrubber

recirculating pump is turned off

0.1 0.1

Control device continues to operate and

meets required operating limits while

emission unit is shut down.

The applicable emission and parameter limits are

expected to be met during shutdown

Bleach plant is shut down; scrubber

recirculating pump is turned off

max 12min 0avg 0.73median 0.25

E2_bleaching_controls Table is 3 pages wide 
Appendix F

Selected Vent Gas Collection System ICR Responses Flagged for Further 

Consideration 

Note: This appendix only contains responses of particular interest for vent gas collection 

systems. All other responses pertaining to vent gas collection systems appear in 

Appendices C through E. 

Appendix F1 - Part I Survey Data Base (PI Equip detail tab) Responses Flagged for Gas 

Collection Systems

Appendix F2 - Part I Survey Data Base (PI Controls tab) Responses Flagged for Gas 

Collection Systems
Appendix F1 

Part I Survey Data Base (PI Equip detail tab) Responses Flagged for Gas Collection 

Systems
Appendix F1

QAd_ProcessType RTI_APCD_Comb

o

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Condensate Stripper INC/SCBR 136 1 0 0 Do not start process until collection system

operational

Vent valves closed and

emissions routed to IQS/Power

Boilers

0 0 Shut down process before collection system

shutdown

V

Condensate Stripper INC_TO/SCBR 189 1 0.25 0.25 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. Check the LVHC System and verify

that there are no visible emissions and no

noticeable odors from all possible excess

emission points. Startup each area source

following mill standard operating proc

Per the SSM Plan, collection of

HVLC/LVHC System. Follow the

LVHC Pre‐Startup checklist asdefined by the mills standard

operating procedures. Verifythe Incinerator, Lime Kiln, or 9A

Boiler is online and at a

temperature ready to accept

LVHC gases.

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System. Shutdown theLVHC Collection System including associated

Ejectors, Coolers, Scrubbers, and other

equipment following standard operating

procedures.

P

v

sd

o

th

L

sap

Condensate Stripper INC1 189 1 0.25 0.25 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. Check the LVHC System and verify

that there are no visible emissions and no

noticeable odors from all possible excess

emission points. Startup each area source

following mill standard operating proc

Per the SSM Plan, collection of

HVLC/LVHC System. Follow the

LVHC Pre‐Startup checklist asdefined by the mills standardoperating procedures. Verify

the Incinerator, Lime Kiln, or 9A

Boiler is online and at a

temperature ready to accept

LVHC gases.

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System. Shutdown theLVHC Collection System including associated

Ejectors, Coolers, Scrubbers, and other

equipment following standard operating

procedures.

P

v

s

d

o

th

L

sap

ICI Boiler/PH NOT PROVIDED (S 156 2 4.5 4.5 follow SSM manual procedures Weak NCG Vent is closed to

atmosphere

4.5 4.5 follow SSM manual procedures c

lo

Incineration Control Device SCBR 109 2 8 8 The scrubber must be operational before process

unit is started up

Emission unit is not started up if APCD is not

operational, venting can occur if both primary

and backup incinerator points are down (but this

isn't the only time).

N

a

Incineration Control Device SCBR 226 1 12 12 Thermal Oxidizer temperature

>1400 + any burn valve open

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

T<

Kraft Pulping: Digester LVHC INC1 240 1 18 18 (1) Insure that all water seal levels are indicated

on DCS. Verify that all seals are in place. (2)

Verify accumulator temp is within normal

operating ranges and that flows to/from

accumulator are available .**Verify that all

temper are normal for turpen

Normal operation begins when

NCG vent to atmosphere is

closed and NCGs are divered to

the powerhouse and the first

digester blows.

6 6 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

S

a

pA

p

to 

s

c

fr

c

Kraft Pulping: Digester LVHC INC1 240 1 8 8 (1) Insure that all water seal levels are indicated

on DCS. Verify that all seals are in place. (2)

Verify accumulator temp is within normal

operating ranges and that flows to/from

accumulator are available**Verify that all

temper are normal for turpenti

Normal operation begins when

NCG vent to atmosphere is

closed and NCGs are divered to

the powerhouse and the first

digester blows.

4 4 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

S

a

pA

p

to 

s

c

fr

c

Kraft Pulping: Digester LVHC INC1 613 2 2 2 Per the SSM Plan, Monitor the pressure relief

valves and other points where possible excess

emissions could occure due to a malfunction.

Per the SSM Plan, Follow

procedures for Kiln/Oxidizer

System and NCG/SOG collection

system, found in the mill's SSM

plan. Verify that the NCG/SOG

system is ready to accept vent

gases from the turpentine

system. Veryif y that theturpentine recovery syst

2 2 Per the SSM Plan, By visual observation, the

operator should insure that vent gases are no

longer being generated before shutting down

the NCG/SOG gas collection system or diverting

blow tank vent gases to atmosphere.

P

R

F1_Gas_Coll_system_Equip_detail 
Appendix F1

QAd_ProcessType RTI_APCD_Comb

o

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Kraft Pulping: Evaporator LVHC INC_BOIL 145 1 4 4 confirm that the condensate bypass valves are

closed

Vacumn reaches 20" Hg or

greater, steam valve open, seal

tank pressure controlled at set

point, product solids are 48% or

greater

1 1 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

st

e

Kraft Pulping: Evaporator LVHC SCBR/INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Condensates designated for

collection in the Evaporator

Foul Condesnsate tank arebelow 800 micromhos..Evaporator steam and liquor

flows are stable. Foul

condensate flow sent to

Condensate Stripper Feed Tank.

All pressure relief devides are

not ventin

continue routing emissions to LVHC‐1 collection

system and primary or backup control system

F

d

Kraft Pulping: HVLC COND/TO/SCBR 206 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When all three blowers are in

operation and the RTO

temperature have stabilized

above the minimum required

operating temperature.

0.1 0.1 emission unit and control device operates during

emission unit shutdown (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

V

a

st

Kraft Pulping: HVLC INC/SCBR 136 1 0 0 Do not start process until collection system

operational

Vent valves closed and

emissions routed to IQS/Power

Boilers

0 0 Shut down process before collection system

shutdown

V

Kraft Pulping: HVLC INC_BOIL 103 1 0.1 0.1 Source vent and/or collection valves positions

are verified using preliminary checklist. Basic

Care and Condition Monitoring Routes provide

routine visual checks of the collection system.

DCS hand switches vent/auto at each of the

HVLC sources must be in

Startup has been achieved

when all the safety and

permissive interlocks have beenmet. DCS data and the mill

information managementsystem, Process Explorer,provide data in regards to HVLC

collection system startupevents.

1 1 Operators receive DCS alarms for opening of vent

valves or collect valve closing during shutdown

indicating process conditions have fallen out of

normal operating ranges for the purpose of

shuting down the process.

S

th

H

cp

Kraft Pulping: HVLC INC_BOIL 135 1 0.5 0.5 HVLC System: The No1, No2 Power Boiler, or

Recovery Boiler is operating and ready to accept

HVLC gases for combustion.

HVLC System: The safety vent

valve has closed and the HVLC

fan rate is steady and gases are

being combusted in the No1 or

No2 Power Boiler.

0.5 0.5 HVLC System: All emission units have been shut

down prior to shutting down the HVLC collection

system.

H

b

e

H

p

Kraft Pulping: HVLC INC_BOIL 156 1 8.333333333

33333E‐02

0.083333333 follow SSM manual procedures Weak NCG flow into one or

more Kiln/Boiler, Weak NCG

Vent is closed to atmosphere

8.333333333

33333E‐02

0.083333333 follow SSM manual procedures W

b

Kraft Pulping: HVLC INC_BOIL 176 1 1 1 Restrict washer startup until PB1 is on line Switching valve is opened to

allow introduction of NCGs

1 1 Incineration point in operation until washers

reach non‐emit state

C

Kraft Pulping: HVLC INC_LK 226 2 0.25 0.25 ensure primary and backup control are available Any digester set is operating

and HVLC blower speed is

satisfied, and HVLC flow is >0.0

and HVLC vent valve is closed.

0.25 0.25 N

H

a

v

Kraft Pulping: HVLC INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

The HVLC Gas System operation

is stable and all operating

problems have been addressed.

shut down the HVLC Gas sytem sources before

venting the Lean Gas System gases.

A

a

c

Kraft Pulping: HVLC INC_RF 185 1 0.1 0.1 Operators verify that the valves on the collection

lines are arranged to allow HVLC's into the

collection system

Vent valves closed and the

valve to the combustion unit is

open

0.1 0.1 NA ‐ Collection system only shutdown when

incineration device is no longer operating

V

Kraft Pulping: HVLC INC_TO/SCBR 189 1 0.25 0.25 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. I started up the HVLC System

Collection fan. I have verified that all gas

collection points have been checked for no

visible emissions. (If gases are not being drawn to

the collection system, make a

Per the SSM Plan, collection of

HVLC/LVHC System. I have

verified that the Incinerator is

running and is ready to accept

the HVLC vent gases. I have

verified that the Gas Cooler

cooling water valve (TV‐003) is

operational. I have verified that

the vent

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System. Proceed to

shutdown all HVLC system equipment.

P

v

v

F1_Gas_Coll_system_Equip_detail 
Appendix F1

QAd_ProcessType RTI_APCD_Comb

o

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Kraft Pulping: Knotter INC1 151 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

A negative draft has been

established for the foul

condensate filter and F‐

secondary knotter Lean (HVLC)

Gas Vent lines.

shut down the HVLC Gas system sources before

venting the lean gases

Aa

c

Kraft Pulping: Knotter/Screen INC1 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

A negative draft has been

established for the foul

condensate filter and F‐

secondary knotter Lean (HVLC)

Gas Vent lines.

shut down the HVLC Gas system sources before

venting the lean gases

Aa

c

Kraft Pulping: Knotter/Screen INC1 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

The G‐Washer lean gases are

boing collected.

shut down the HVLC Gas system sources before

venting the lean gases

Aa

c

Kraft Pulping: LVHC INC/SCBR 136 1 0 0 Do not start process until collection system

operational

Vent valves closed and

emissions routed to IQS/Power

Boilers

0 0 Shut down process before collection system

shutdown

V

Kraft Pulping: LVHC INC_BOIL 150 1 2 2 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

satisfy control devicepermissives, opening steam

valves to the eductors, closing

bypass vent valves.

0.25 0.25 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

v

s

v

Kraft Pulping: LVHC INC_BOIL 156 1 8.333333333

33333E‐02

0.083333333 follow SSM manual procedures Strong NCG flow into one or

more Kiln/Boiler, Strong NCG

Vent is closed to atmosphere

8.333333333

33333E‐02

0.083333333 follow SSM manual procedures S

b

Kraft Pulping: LVHC INC_BOIL 185 1 0.02 0.02 Seal tank valves on evaporators are arranged to

allow dilution air to be drawn into the seal tanks

to dilute NCGs

Vent valves closed and the

valve to the combustion unit is

open

0.02 0.02 NA ‐ Collection system only shutdown when

incineration device is no longer operating

V

Kraft Pulping: LVHC INC_LK 135 1 0.5 0.5 LVHC System: The kiln is operating and ready to

accept LVHC gases for combustion. Or the No1

Boiler is operating and HVLC gases are being

combusted prior to diverting the LVHC gases into

the HVLC system for combustion.

LVHC System: The safety ventvalves have closed and the lime

kiln steam eductor rate is

steady or the LVHC gases are

being diverted into the HVLCsystem.

0.5 0.5 LVHC System: All emission units have been shut

down prior to shutting down the LVHC collection

system.

L

e

th

N

b

w

s

Kraft Pulping: LVHC INC_LK 202 1 variable ‐  

Based on

LVHC SSM

Plan ‐ In 2009

varied froim

4 hours to 21

hours

depending

on when

conditions

were met.

NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup‐ 

with venting allowances for HVLC and LVHC

sources

LVHC System normal operating

conditions are as follows:(1)

Batch Digester System (with

Blow Heat Recovery and

Turpentine Recovery) ‐ 

Completion of one sequence of

digester blows following startup

(exceeding minimum steam

flow to headers for Nos. 1‐4

diges

variable ‐  

Based on

LVHC SSM

Plan ‐ In 2009

varied froim

2.5 hours to

7 hours

depending

on when

conditions

were met.

NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown‐ 

with venting allowances for HVLC and LVHC

sources

B

w

a

o

s

pD

H

Rh

Kraft Pulping: LVHC INC_LK 203 1 0.33 0.33 NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup

emission source isolation valvesopen, emission source vent

valves closed, incineration point

isolation valve open (as per

SSM plan)

0.33 0.33 NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown

S

fo

Kraft Pulping: LVHC INC_LK 226 1 0.25 0.25 ensure primary and backup control are available The condensate stripper is

operating and SOG vent valve

at Kiln and Thermal Oxidizer is

closed.

0.25 0.25 T

o

a

c

Kraft Pulping: LVHC INC_TO/SCBR 189 1 0.25 0.25 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. Check the LVHC System and verify

that there are no visible emissions and no

noticeable odors from all possible excess

emission points. Startup each area source

following mill standard operating proc

Per the SSM Plan, collection of

HVLC/LVHC System. Follow the

LVHC Pre‐Startup checklist asdefined by the mills standard

operating procedures. Verify

the Incinerator, Lime Kiln, or 9A

Boiler is online and at a

temperature ready to accept

LVHC gases.

0.25 0.25 Per the SSM Plan, continue routing to

LVHC/HVLC Collection System. Shutdown the

LVHC Collection System including associatedEjectors, Coolers, Scrubbers, and other

equipment following standard operating

procedures.

P

v

sd

o

th

L

s

ap

F1_Gas_Coll_system_Equip_detail 
Appendix F1

QAd_ProcessType RTI_APCD_Comb

o

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Kraft Pulping: LVHC SCBR/INC_LK 226 1 0.25 0.25 ensure primary and backup control are available Any Digester set or evaporator

set is ioperating and steam flow

to NCG eductor >1520 lbs/hr

and steam pressure to NCG

eductor >45 psig, and LVHC

vent valve is closed.

0.25 0.25 N

s

to 

a

ev

Kraft Pulping: NCG System INC_BOIL 145 1 0.1 0.1 close and secure all system drains and sample

ports

NCG pressure @ 3psig and NCG

auto vent valve is closed

shutdown the NCG gas compressor and close the

discharge hand valve on the NCG compressor

sc

d

N

Kraft Pulping: NCG System INC_TO 242 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When flow through by‐pass

ceases

0.1 0.1 continue routing emissions to LVHC‐ AA‐026

collection system and primary or backup control

system

W

Kraft Pulping: NCG System INC_TO/SCBR 243 1 0 0 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Lines at desired

pressures/vacuums to meet

safety requirements

0 0 Make sure all emission units are down before

shutting down collection system

N

d

Kraft Pulping: NCG System SCBR/INC_TO/SCB 190 1 0.25 0.25 Ensure adequate water flow to pressure/vacuum

breakers. Ensure all flame arrestors have been

checked for proper differential pressure at each

operating source. Divert the NCG vent gases for

each process source into collection header

following the startu

NCG incineration device is

operating , meets safetypermissive, and NCG gases have

been verified to be directed to

the incineration device.

0.25 0.25 Continue to operate the NCG collection system

until all process equipment that is a source of

NCG gases has been shutdown.

O

Kraft Pulping: Turpentine LVHC INC_LK 202 1 See LVHC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup‐ 

with venting allowances for HVLC and LVHC

sources

See LVHC System ‐ not further

defined

See LVHC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown‐ 

with venting allowances for HVLC and LVHC

sources

S

d

Kraft Pulping: Turpentine LVHC INC1 169 1 Hot ‐ 0.5‐2;

Cold 6‐8

BEFORE startup of the Turpentine Recovery

System (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

When the reclaimed steam is

valved in to the chip bin(s) and

steaming vessel(s), the normal

extraction flow(s) has been

established, and the blow

valves have been opened.

Hot ‐ 0.5‐1;

Cold 4‐8

Continuing routing emissions to the LVHC

Collection System and Control Device

W

d

Kraft Pulping: Turpentine LVHC INC1 169 1 Hot ‐ 0.5‐2;

Cold 6‐8

BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases: and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

When the reclaimed steam is

valved in to the chip bin(s) and

steaming vessel(s), the normal

extraction flow(s) has been

established, and the blow

valves have been opened.

Hot ‐ 0.5‐1;

Cold 4‐8

Continuing routing emissions to the LVHC

Collection System and Control Device

W

d

Kraft Pulping: Turpentine LVHC INC1 613 1 2 2 Per the SSM Plan, Startup following PSM

procedure. Verify that turpentine system is

ready to accept blow tank tgases before sending

gases from either blow tank to the turpentine

recovery system. Send the digester relief gases

from flow tanks to the turp

Per the SSM Plan:**Requiredcooling water pumps are

running as specified in the mill's

PSM plan; verify that the

condensate pump is running as

specified; NCG vent valve will

divert vent gases to NCG/SOG

Gas collection system and not

to the atmosphere

2 2 Per the SSM Plan:**Shutdown per PSM

procedure. Shutdown the Turpentine Recovery

system before shutting down or diverting the

NCG vent gases and condensates form the

colelction system. By visual obervation, the

operator should insure that vent gases and

PV

dV

b

T

nN

Kraft Pulping: Washing INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

The F‐Washer lean gases are

being collected.

shut down the HVLC Gas system sources before

venting the lean gases

Aa

c

Kraft Pulping: Washing INC_RF 202 1 See HVLC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during startup‐ 

with venting allowances for HVLC and LVHC

sources

See HVLC System ‐ not further

defined

See HVLC

System ‐ not

further

defined

NA ‐ applicable emission and parameter limits

not expected to be exceeded during shutdown‐ 

with venting allowances for HVLC and LVHC

sources

S

d

Kraft Pulping: Washing INC1 102 1 1 1 When NCG‐TO is available and able to maintain

minimum temperature limit for firing HVLC, the

HVLC NCG system is collecting and treating gases

prior to startup of sources.

Pulp flow from PDW 1 1 Whenever possible, HVLC NCG system is

collecting and treating vent gases during

shutdown of sources.

N

F1_Gas_Coll_system_Equip_detail 
Appendix F1

QAd_ProcessType RTI_APCD_Comb

o

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Kraft Pulping: Washing INC1 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

A negative draft has been

established for the foul

condensate filter and F‐

secondary knotter Lean (HVLC)

Gas Vent lines.

shut down the HVLC Gas system sources before

venting the lean gases

Aa

c

Kraft Pulping: Washing INC1 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

The G‐Washer lean gases are

boing collected.

shut down the HVLC Gas system sources before

venting the lean gases

A

a

c

Kraft Pulping: Washing INC1 181 2 0.2 0.2 emissions collected and routed to a control

device during startup (except following cold

outage)

Sheet on 2nd stage and hoods

closed

0.2 0.2 continue routing emissions to collection system

and control device until unit down

Lime Kiln SCBR 156 1 42 42 follow SSM manual procedures Open Weak NCG supply valve

to No. 3 Lime Kiln Primary Air

Fan inlet Stack

24 24 follow SSM manual procedures W

a

a

Lime Kiln SCBR 156 1 42 42 follow SSM manual procedures Open Weak NCG supply valve

to No. 4 Lime Kiln Primary Air

Fan inlet Stack

24 24 follow SSM manual procedures W

a

a

NSSC Pulping INC1 156 1 2.5 2.5 follow SSM manual procedures Chemi‐washer vent valve and

blow line refiner drain valve is

closed

1.5 1.5 follow SSM manual procedures F

lo

Semichem Pulping INC_BOIL 245 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC Operating = Vacuumgreater than ‐15 H2O ANDhotwell Vent closed AND

temperature on Pressure ReliefOK AND rupture Disk OK and

Overflow Loop OK AND 15 min.

rolliing average of steam flowto ejectors greater than 1000

lbs/hr AND surface condenser

vacuu

4 4 continue routing emissions to HVHC collection

system and primary or backup control system

1

fl

1

c

2

Semichem Pulping INC_BOIL 245 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC Operating = Vacuumgreater than ‐15 H2O ANDhotwell Vent closed AND

temperature on Pressure ReliefOK AND rupture Disk OK and

Overflow Loop OK AND 15 min.

rolliing average of steam flow

to ejectors greater than 1000

lbs/hr AND surface condenservacuu

4 4 continue routing emissions to HVHC collection

system and primary or backup control system

A

th

Semichem Pulping INC_BOIL 245 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC Operating = Vacuum

greater than ‐15 H2O ANDhotwell Vent closed AND

temperature on Pressure Relief

OK AND rupture Disk OK and

Overflow Loop OK AND 15 min.

rolliing average of steam flowto ejectors greater than 1000

lbs/hr AND surface condenservacuu

4 4 continue routing emissions to LVHC collection

system and primary or backup control system

1

fl

1c

2

Semichem Pulping INC_BOIL 245 1 4.5 4.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Either (HVLC‐M&A Fan is ON

and vacuum > < ‐15") AND

(HVLC‐M&A Vent bypass valve

at the No. 1 WFB (13‐ZsC‐

5620)is closed AND the boiler

select is #1WFB OR the No. 2WFB (13‐ZsC‐5622) is CLOSED

AND the boiler select is #2WFB)AND condenser outlet temp is

1 1 continue routing emissions to HVHC collection

system and primary or backup control system

A

th

F1_Gas_Coll_system_Equip_detail 
Appendix F1

QAd_ProcessType RTI_APCD_Comb

o

RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas 

Semichem Pulping INC_BOIL 245 1 4.5 4.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Either (HVLC‐M&A Fan is ON

and vacuum > < ‐15") AND

(HVLC‐M&A Vent bypass valve

at the No. 1 WFB (13‐ZsC‐

5620)is closed AND the boiler

select is #1WFB OR the No. 2

WFB (13‐ZsC‐5622) is CLOSED

AND the boiler select is #2WFB)AND condenser outlet temp is

1 1 continue routing emissions to HVLC collection

system and primary or backup control system

T

thsy

sy

Semichem Pulping INC_BOIL 245 1 4.5 4.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

LVHC‐M&A Vent bypass valves

(#1 OR #2) at the selected

combustion device (#1=13‐zso‐

5702 and 13‐zso‐5709 OR #2

=13‐zso‐5703 and 13‐zso‐5718)

are CLOSED and vacuum > < ‐

15" H2O AND the S1 Digester

Set OR the S2 Digester Set OR

the Evaporator system OR LHT

1 1 continue routing emissions to LVHC collection

system and primary or backup control system

D

s

sy

Storage Tanks INC_BOIL 245 2 4.5 4.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Either (HVLC‐M&A Fan is ON

and vacuum > < ‐15") AND(HVLC‐M&A Vent bypass valve

at the No. 1 WFB (13‐ZsC‐

5620)is closed AND the boiler

select is #1WFB OR the No. 2

WFB (13‐ZsC‐5622) is CLOSED

AND the boiler select is #2WFB)AND condenser outlet temp is

1 1 continue routing emissions to HVHC collection

system and primary or backup control system

A

th

F1_Gas_Coll_system_Equip_detail 
Appendix F2

Part I Survey Data Base (PI Controls tab) Responses Flagged for Gas Collection Systems
Appendix F2. Part I Survey Data Base (PI Controls tab) Responses Flagged for Gas Collection Systems

RTI

Code Pulp Type NEISiteID RTI_APCDID RTI_EmissionUnitType

RTI_SubpartS_Pr

ocessType APCDType

APCD_SU_Du

ration_hrs_n

um APCD_SU_Integration APCD_SU_ParamDeviation APCD_SU_EmissRednMeas

Memo_APC

145 Kraft NEI33135

145‐‐Other ‐ 

(NCG001‐01C)

Condensate Stripper; Kraft Pulping: Digester

LVHC; Kraft Pulping: Evaporator LVHC; Kraft

Pulping: HVLC; Kraft Pulping: NCG System;

Kraft Pulping: Turpentine LVHC; Kraft

Pulping: Washing NCG Flare 1

Control device cannot be

started prior to emission unit

starting up due to safety issue

or risk of property damage.

{Explain}

Collection system must vent to

purge O2 to avoid explosive gas

mixture.

146 Kraft NEI759 146‐‐HVLC1

Kraft Pulping: O2 Delig HVLC; Kraft Pulping:

Washing NCG

Thermaloxidizer/incinerator 0.25

The unit is not allowed to begin

operation until the NCG

collection system and

combustion device are in

service.

Negative pressure at all hood

openings cannot be maintained

The unit is not allowed to beginoperation until the NCG

collection system and

combustion device are in

service.

171 Kraft NEI18658 171‐‐043 Incineration Control Device

IncinerationControl Device

Thermaloxidizer/incinerator 0.1

Control device cannot bestarted prior to emission unit

starting up due to safety issue

or risk of property damage.Startup commenes upondetection of primiary treatmentdevice trouble.

LVHC gases are vented during

change over from primary to

secondary treatment device.

Quick startup; secondary

treatment device on line prior toany "planned" treatment device

down time.

F2_PI_Controls_Gas_Coll Table is 2 pages wide 
Appendix F2. Part I Survey Data Base (PI Controls tab) Responses Flagged for Gas Collection Systems

RTI_APCDID

145‐‐Other ‐ 

(NCG001‐01C)

146‐‐HVLC1171‐‐043

APCD_SD_Du

ration_hrs_n

um APCD_SD_Integration APCD_SD_ParamDeviation APCD_SD_EmissRednMeas

Memo_APCD_SD_EmissRednMe

as APCD_SD_MarkBegin APCD_SU_SD_Recommend APCDComment

1

Control device continues to

operate and meets requiredoperating limits while emission

unit is shut down.

Collection system must vent to

purge O2 to avoid explosive gas

mixture. unit offline

0.1

NCG system and combustion

device remain in service until

system is completely off‐line NA

NCG system and combustion

device remain in service until

system is completely off‐line

Shutdown begins when the

knotter feed pump is shutdown NA

Control device removal

efficiencies are based on design

characteristics. Actualefficiencies are unknown

0.1

This is the secondary treatment

device. The unit is limited in

hours of operation.

The applicable emission and

parameter limits are expected

to be met during startup

The flare will not be shutdown if

still needed for control of LVHC

gases.

Shutdown begins when NCGs

are removed from the flare.

Emergency Flare ‐ NCG

destruction source back up for

kilns

F2_PI_Controls_Gas_Coll Table is 2 pages wide 
Appendix G 

Information from PI Equip detail for Condensate Strippers and Biotreatment Units
Appendix G

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas S

Condensate Stripper COND/INC_BOIL 112 1 When condensate enters tank Black liquor 

Condensate Stripper COND/INC_TO 112 1 1.5 1.5 When condensate exits scrubber 0.5 0.5 continue routing emissions to LVHC collection

system and primary or backup control system

Condensate 

Condensate Stripper INC 148 1 2 2 emission unit and control device operates in

compliance parameter limits during emission unit

startup

When ratio of condensate to steam is

at 18

1 1 Incineration source is still online until source is

shutdown

When conde

off

Condensate Stripper INC 196 1 0.5 0.5 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

steam flow on stripper column 0.25 0.25 NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

steam off st

Condensate Stripper INC/SCBR 136 1 0 0 Do not start process until collection system

operational

Vent valves closed and emissions

routed to IQS/Power Boilers

0 0 Shut down process before collection system

shutdown

Vent valves 

Condensate Stripper INC_BOIL 115 2 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Product Flow 0.5 0.5 NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

no flow

Condensate Stripper INC_BOIL 115 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When all CMS temperatures and

flows are in compliance with limits

0.5 0.5 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Stop Feed Fl

Condensate Stripper INC_BOIL 127 5 3 3 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Establish desired black liquor solids

concentration from Evaporator Set

1 1 Emissions routed to Power Boiler 3 / Thermal

Oxidizer

Close steam 

valves to eva

Condensate Stripper INC_BOIL 145 1 0.1 0.1 confirm that the bypass vents are closed and that

both the evaporators and pulp mill are down

steam flow and foul condensate are

sent to the stripper

NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

stop steam f

flow to the s

Condensate Stripper INC_BOIL 145 1 0.5 0.5 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

miniumum feed flow to the stripper

is 312gpm

0.5 0.5 stop routing process condensates to stripper

before beginning shutdown

shut off stea

Condensate Stripper INC_BOIL 150 1 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stripper feed tank level control in

automatic

1 1 NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

Steam flow s

Condensate Stripper INC_BOIL 154 1 0.1 0.1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Start up pump 10 10 Continue routing emissions to LVHC collection

system and primary or backup control system

Stop feeding 

Condensate Stripper INC_BOIL 154 1 0.1 0.1 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Start up pump 8 8 Continue routing emissions to LVHC collection

system and primary or backup control system

Stop feeding 

Condensate Stripper INC_BOIL 154 1 0.25 0.25 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stripper feed pump starts 0.5 0.5 Continue routing emissions to LVHC collection

system and primary or backup control system

Stripper feed 

Condensate Stripper INC_BOIL 154 1 2 2 Emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When stripper feed pump is started 2 2 Continue routing emissions to LVHC collection

system and primary or backup control system

Shutdown st

Condensate Stripper INC_BOIL 174 1 .25 Hours 0.25 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System

.02 hrs 0.02

Condensate Stripper INC_BOIL 174 1 .25 Hours 0.25 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

.02 hrs 0.02

Condensate Stripper INC_BOIL 174 1 NA BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Condensate Stripper INC_BOIL 174 1 NA There are no HAP emissions as a result of starting

up the collection system. HAPS are only generated

by the emission units and not the collection

system. The collection system and control device

must be operational prior to startup of an

emission source

NA‐Not an emission unit NA There are no HAP emissions as a result of starting

up the collection system. HAPS are only generated

by the emission units and not the collection

system. The collection system and control device

must be operational prior to startup of an

emission source

NA‐Not an e

Condensate Stripper

AppG_Equip_detail_stripper 
Appendix G

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas S

Condensate Stripper INC_BOIL 195 1 0.5 0.5 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Temperature and Condensate Feed

Rate Ratio to Set point

0.2 0.2 All Control Equipment remain on‐line until source

is shut down.

Stop Conden

Condensate Stripper INC_BOIL 200 1 24 24 At least one combination boiler should be fully

operational before the generation of the

regulated pollutants is initiated

Combination boiler No. 1 or No. 2

online, rupture disks intact, no

alarms

24 24 continue routing emissions to primary or backup

control system

shutdown co

standard op

Condensate Stripper INC_BOIL 200 1 24 24 At least one combination boiler should be fully

operational before the generation of the

regulated pollutants is initiated

liquid feed temperature and steam

application rate at target levels, no

alarms

24 24 stop routing process condensates to stripper

before beginning shutdown

When conde

operating an

to the sewer

Condensate Stripper INC_BOIL 201 2 0.3 0.3 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Completion of 15 minutes of foul

condensate flow and steam flow to

stripper

0.3 0.3 continue routing emissions to stripper off‐gas

collection system to primary or backup control

system

No steam flo

minutes

Condensate Stripper INC_BOIL 304 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

weak liquor feed 0.25 0.25 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

no weak liqu

Condensate Stripper INC_BOIL 531 1 NA There are no HAP emissions as a result of starting

up the collection system. HAPS are only generated

by the emission units and not the collection

system. The collection system and control device

must be operational prior to startup of an

emission source

NA‐Not an emission unit NA There are no HAP emissions as a result of shutting

down the collection system. HAPS are only

generated by the emission units and not the

collection system. The collection system and

control device must be operational while one or

more emission units are

NA‐Not an e

Condensate Stripper INC_BOIL 617 1 1 hour 1 start up boilers prior to collecting gases gases are routed to power boilers 1 hour 1 continue routing emissions to power boiler until

steam stripper is down

steam stripp

Condensate Stripper INC_LK 176 1 1 1 Condensates not sent to stripper until thy have

reached temperature.

Steam ejector vacuum at 3" psia and

condensate temperature at 170F

1 1 Condensates will go directly to the hard pipe

system. Gases incinerated until stripper reaches a

non‐emitting state

When both f

feed pump a

stripper feed 

Condensate Stripper INC_LK 178 1 <1 1 There are no HAP emissions as a result of starting

up the collection system. HAPS are only generated

by the emission units and not the collection

system. The collection system and control device

must be operational prior to startup of an

emission source

N/A not an emissions unit <1 1 There are no HAP emissions as a result of shutting

down the collection system. HAPS are only

generated by the emission units and not the

collection system. The collection system and

control device must be operational while one or

more emission units are

N/A not an e

Condensate Stripper INC_LK 178 2 1 1 BEFORE startup of the Steam Stripper Off‐Gas

System: 1) Confirm the LVHC System control

device is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.

Based on stable pressure in the SOG

at the outlet of the reflux condensor.

0.25 0.25 Continuing routing emissions to the LVHC

Collection System and Control Device

Shutdown b

steam is shu

column

Condensate Stripper INC_LK 199 1 0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Operation above minimum

monitoring parameter values for 30

minutes

0.5 0.5 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Stripper stea

for 30 minut

Condensate Stripper INC_LK 203 1 0 0 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

0 0 NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

Condensate Stripper INC_LK 206 1 2 2 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

When normal steam flow and

condensate flow rates are achieved.

2 2 stop routing process condensates to stripper

before beginning shutdown

When foul c

ramped blow 

ranges

Condensate Stripper INC_LK 206 1 NA emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When normal steam flow and

condensate flow rates are achieved.

NA stop routing process condensates to stripper

before beginning shutdown

When foul c

ramped blow 

ranges

Condensate Stripper INC_LK 206 1 NA NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

When any one of the processes that

feed condensate to the tank begin

operation.

NA NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

When all of 

condensate 

completed a 

Condensate Stripper INC_LK 226 1 3 3 ensure primary and backup control are available Stripper feed flow > 50 gpm and

effective steam ratio is >.17

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

No Stripper 

steam ratio 

Condensate Stripper INC_LK 226 1 4 4 ensure primary and backup control are available Any Stripper feed flow and effective

steam ratio is >.17

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

No Stripper 

steam ratio 

Condensate Stripper INC_LK 226 1 4 4 ensure primary and backup control are available steam is on vessel and condensate

feed is on

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

steam is not 

condensate 

Condensate Stripper INC_LK 242 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Steam flow to the stripper 0.1 0.1 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Steam flow t

AppG_Equip_detail_stripper 
Appendix G

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas S

Condensate Stripper INC_LK 600 1 Hot/Cold

Startup: 0.25‐

1 hours

1 BEFORE startup of the of the Steam Stripper Off‐

Gas System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

NA‐Not an emission unit Hot/Cold

Shutdown:

0.25 hours

0.25 Continuing routing emissions to the LVHC

Collection System and Control Device

NA‐Not an e

Condensate Stripper INC_LK 600 1 Hot/Cold

Startup: 0.25‐

1 hours

1 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System

NA‐Not an emission unit Hot/Cold

Shutdown:

0.25 hours

0.25 Continuing routing emissions to the LVHC

Collection System and Control Device

NA‐Not an e

Condensate Stripper INC_LK 600 9 Hot/Cold

Startup: 0.25‐

1 hours

1 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

NA‐Not an emission unit Hot/Cold

Shutdown:

0.25 hours

0.25 Continuing routing emissions to the LVHC

Collection System and Control Device

NA‐Not an e

Condensate Stripper INC_LK 600 2 Hot/Cold

Startup: 1‐2

hours

2 There are no HAP emissions as a result of starting

up the collection system. HAPS are only generated

by the emission units and not the collection

system. The collection system and control device

must be operational prior to startup of an

emission source

NA‐Not an emission unit Hot/Cold

Shutdown: 1

hour

1 There are no HAP emissions as a result of shutting

down the collection system. HAPS are only

generated by the emission units and not the

collection system. The collection system and

control device must be operational while one or

more emission units are

NA‐Not an e

Condensate Stripper INC_LK/MC/SCBR 120 1 <1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Inlet Temperature is greater than 167

F

0.33 0.33 NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

Kiln operate

shutdown. S

pre‐evapora

Condensate Stripper INC_LK/SCBR 159 1 2 2 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

once approximately four digesters

are running

2 2 continue routing emissions to LVHC collection

system and primary or backup control system

stabilize, low

temperature 

Condensate Stripper INC_LK/SCBR 177 1 1‐2 hours 2 continue routing emissions to EU0905 or EU1151 When normal condensate and steam

flows are established and the reflux

condenser and stripper gas cooler

termperatures are at setpoint.

1‐2 hours 2 continue routing emissions to EU0905 or EU1151 When conde

reduced for 

down.

Condensate Stripper INC_LK/SCBR 177 1 6‐8 hours

(range

includes

startup of

evaporator

process

equipment)

8 continue routing emissions to EU0905 or EU1151 When evaporators are at target

production rate and product liquor is

being pumped to the heavy liquor

storage tank.

6‐8 hours

(range

includes

shutdown of

evaporator

process

equipment)

8 continue routing emissions to EU0905 or EU1151 When first r

steam flow a

Condensate Stripper INC_LK/SCBR 198 1 0.05 0.05 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Product solids, steam pressure,

vacuum system, liquor and

condensate flows within normal

operating ranges, no alarms, no

rupture disk failures

8 8 continue routing emissions to LVHC‐1 and HVLC‐1

collection system and primary or backup control

system

Reduction/tor steam to 

Condensate Stripper INC_LK/SCBR 198 1 1 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Product solids, steam pressure,

vacuum system, liquor andcondensate flows within normal

operating ranges, no alarms, no

rupture disk failures

8 8 continue routing emissions to LVHC‐1 and HVLC‐1

collection system and primary or backup control

system

Reduction/tor steam to 

Condensate Stripper INC_RF 104 1 Startup Hot ‐ 

0, Startup

Cold ‐ 0.5

BEFORE startup of the Steam Stripper Off‐Gas

System: 1) Confirm the LVHC System control

device is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.

operation is stable with constant SOG

flow to the incineration source

Shutdown

Hot ‐ 0,

Shutdown

Cold ‐ 0

0 Under normal operation conditions and including

times when the stripper is down, concentrated

NCG gases from the stripper feed tank are

collected.**The stripper feed tank is equipped

with high level and overflow alarms.**During a

normal stripper shutdown,

The shutdow

foul conden

is stopped.

Condensate Stripper INC_RF 108 2 1 1 BEFORE startup of the Evaporator System: 1)

Confirm the LVHC System control device is ready

to accept gases and 2) Ensure equipment is

properly valved to the LVHC Collection

System.**Cut out hogging jet before starting

regular feed of liquor.

When stripper off gases are being

burned in the destruction device and

the effective steam ratio or process

wastewater feed rate, steam feed

rate, and process wastewater column

feed temperature conditions are met.

1 1 stop routing process condensates to stripper

before beginning shutdown

When stripp

being burne

Condensate Stripper INC_RF 108 1 NA There are no HAP emissions as a result of starting

up the collection system. HAPS are only generated

by the emission units and not the collection

system. The collection system and control device

must be operational prior to startup of an

emission source

NA‐Not an emission unit NA There are no HAP emissions as a result of shutting

down the control device. HAPS are only generated

by the emission units and not the control device.

The control device must be operational while one

or more emission units are running.

NA‐Not an e

AppG_Equip_detail_stripper 
Appendix G

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas S

Condensate Stripper INC_RF 180 1 1 1 Monitor rupture discs Stripper steam application rate

reaches target; and begin flow of

process condensates from tank to

the process, not recirculating to foul

condensate tank, conductivities in

range

1 1 Stop routing of process condensates to stripper,

monitor rupture discs

Shut off stea

Condensate Stripper INC_RTO/SCBR/WESP 166 1 There are no HAP emissions as a result of starting

up the collection system. HAPS are only generated

by the emission units and not the collection

system. The collection system and control device

must be operational prior to startup of an

emission source

NA‐Not an emission unit There are no HAP emissions as a result of shutting

down the collection system. HAPS are only

generated by the emission units and not the

collection system. The collection system and

control device must be operational while one or

more emission units are

NA‐Not an e

Condensate Stripper INC_TO 106 1 24 24 Verify primary or backup control device is

available prior to startup.

Stripper, evaporator, brown stock

washer, and digester startups are

complete.

12 12 Collected gases are routed to a control device

until the stripper, evaporator, brown stock

washer, and digester systems are all shutdown.

Stripper, eva

washer, and 

shutdown.

Condensate Stripper INC_TO 107 2 <1 hr 1 emission unit and control device operates during

emission unit startup (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Gases are collected and control

device is operating withing required

range.

<1 hr 1

Condensate Stripper INC_TO 146 1 0.25 0.25 The unit is not allowed to begin operation until

the NCG collection system and combustion device

are in service.

Start‐up ends when steam is

introduced to the stripper

0.1 0.1 Condensates are diverted to the BSW when the

stripper is down. Emissions are collected within

HVLC1

Shutdown b

taken off the 

Condensate Stripper INC_TO 148 1 NA NA NA NA NA

Condensate Stripper INC_TO 178 1 1 1 BEFORE startup of the Turpentine Recovery

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Based on stable pressure in the SOG

at the outlet of the reflux condensor.

0.25 0.25 Continuing routing emissions to the LVHC

Collection System and Control Device

Shutdown b

steam is shu

column

Condensate Stripper INC_TO 242 1 0.1 0.1 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

Steam flow to the stripper 0.1 0.1 NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

Steam flow t

Condensate Stripper INC_TO/SCBR 143 1 Hot or Cold:

1.0 ‐2.5 hours

2.5 Confirm Condensate Collection System and

Stripper System are operating and confirm that

SOGs may be sent to the SOG Collection System

and Treatment Unit

Reach minimum steam flow to the

Stripper System, minimum column

temperature, SOG Collection and

Treatment System permissives,

moderate the Foul Condensate flow.

Hot or Cold:

0.5 ‐ 1.0

hours

1 Maintain SOG Collection and Treatment until the

steam is shut off and lower the Stripper Feed

Tank Level to approximately 40%.

Taking the 5

Stripper Syst

Condensate Stripper INC_TO/SCBR 155 4 4 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

when steam flow >5,000 lbs/hr for 4

hrs

0.25 0.25 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

when steam 

15 minutes

Condensate Stripper INC_TO/SCBR 189 1 0.25 0.25 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. Check the LVHC System and verify that

there are no visible emissions and no noticeable

odors from all possible excess emission points.

Startup each area source following mill standard

operating proc

Per the SSM Plan, collection of

HVLC/LVHC System. Follow the LVHCPre‐Startup checklist as defined by

the mills standard operating

procedures. Verify the Incinerator,Lime Kiln, or 9A Boiler is online and at

a temperature ready to accept LVHC

gases.

0.25 0.25 Per the SSM Plan, continue routing to LVHC/HVLC

Collection System. Shutdown the LVHC Collection

System including associated Ejectors, Coolers,

Scrubbers, and other equipment following

standard operating procedures.

Per the SSM 

Follow the Lprocedures 

standard op

Verify that a

LVHC vent g

shutdown fo

shutdown p

Condensate Stripper INC_TO/SCBR 190 1 1.5 1.5 Foul condensates are not directed to the stripper

during startup.

Appropriate operating temperature

and pressure achieved.

4 4 Foul condensates are not directed to the stripper

during shutdown.

cease flow o

stripper

Condensate Stripper INC_TO/SCBR 243 2 6 6 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Stripper meets permit parametric

requirements

0.25 0.25 continue routing emissions to NCG collection

system and primary or backup control system

When steam 

removed an

meets requi

Condensate Stripper INC_TO/SCBR 525 2 4 4 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

all compliance parameters are in

range and condensate is introduced

into the stripper

0.5 0.5 NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

condensate 

Condensate Stripper INC1 100 1 ~8 hrs 8 Stop liquor flow and steam flow to the

evaporators prior to initiating shutdown of the

HVLC collection system.

Operation has stabilized and

evaporator product is at target

percent solids.

~6 hrs 6 Ensure the HVLC collection and treatment system

is in operation and all system valves are in the

appropriate position until completing shutdown

of the Evaporator System(s).

Weak liquor 

Condensate Stripper INC1 100 3 ~8 hrs 8 Stop liquor flow and steam flow to the

evaporators prior to initiating shutdown of the

LVHC collection system.

Operation has stabilized and

evaporator product is at target

percent solids.

~6 hrs 6 Ensure the LVHC collection and treatment system

is in operation and all system valves are in the

appropriate position until completing shutdownof the Evaporator System(s).

Weak liquor 

AppG_Equip_detail_stripper 
Appendix G

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas S

Condensate Stripper INC1 102 1 12 12 Under normal operation conditions and including

times when the stripper is down, unless isolated

for maintenance, LVHC gases from the stripper

feed tank, decant tank and reflux tank are

collected. The stripper feed tank is equipped with

high level and ov

Startup is complete when feed and

product flows and temperatures are

stable and rectified methanol is being

combusted in NCG‐TO.

Stable vacuum on column, level in

vessels, and steam on reboiler verify

that startup is complete.

1 1 Under normal operation conditions and including

times when the stripper is down, unless isolated

for maintenance, LVHC gases from the stripper

feed tank, decant tank and reflux tank are

collected for control.

The stripper feed tank is equipped with high

Stripper shusteam is shu

foul conden

Condensate Stripper INC1 103 1 4 4 Under normal conditions and including times

when the stirpper is down, LVHC gases from the

stripper feed tank are collected, The stripper feed

tank is equipped with high level and overflow

alarms, and the Lime Kiln or No. 2 Hog Fuel Boiler

are ready to re

When foul condensate is being

introduced to the stripper and the

operation is stable the unit isconsidered to have completed

startup.

4 4 During shutdown, SOG is still being collected and

controlled.

A ramp dow

condensate 

purpose of s

Condensate Stripper INC1 103 1 8 8 Use the proper sequence for evaporator and

concentrator system startup to minimize

emissions. Verify that the evaporator system is

operating within normal ranges for process

temperatures, pressures, flows, and conductivity.

The conductivity diversion syst

The transition from startup to normal

operations will be consideredcomplete when the listed conditions

have been achieved.

3 3 Follow the standard operating procedures for

shutdown of the evaporator and concentrator

systems. Maintain collection of the LVHC NCG

sources as long as the LVHC system is online

unless safety or maintenance SOP requires

otherwise.

EVAPS: The 

operations tcomplete wh

1st effect is 

system is off

transition fro

the shutdow

when the ste

Condensate Stripper INC1 111 1 1.357695810

6

1.357695811 0.028005464

481

0.028005464

Condensate Stripper INC1 112 1 1.5 1.5 Collection and control systems operating before

start‐up

When condensate exits preheater 0.5 0.5 continue routing emissions to LVHC collection

system and primary or backup control system

Condensate 

Condensate Stripper INC1 116 1 ~3 hrs 3 BEFORE startup of the Steam Stripper Off‐Gas

System: 1) Confirm the LVHC System control

device is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System

Dependant on equipment systems

feeding tank

~3 hrs 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Dependant o

feeding tank

Condensate Stripper INC1 116 7 ~3 hrs 3 BEFORE startup of the Steam Stripper Off‐Gas

System: 1) Confirm the LVHC System control

device is ready to accept gases and 2) Ensure

equipment is properly valved to the LVHC

Collection System.

Dependant on equipment systems

feeding tank

~3 hrs 3 Continuing routing emissions to the LVHC

Collection System and Control Device

Dependant o

feeding tank

Condensate Stripper INC1 135 1 1 1 Air Stripper System: The HVLC is operating prior to

putting condensate or air to the stripper.

Air Stripper System: The air strippercondensate feed rate is stable. The

condensate feed is not high in

conductivity and causing foam to be

created in the stripper.

0.5 0.5 Air Stripper System: The HVLC continues to

operate while the air stripper is shut down.

Air Stripper 

feed rate is 

range.

Condensate Stripper INC1 135 1 1 1 Steam Stripper System: The LVHC is operating

prior to putting condensate or steam to the

stripper.

Steam Stripper System: Thecondensate feed and steam feed is

stable and continuous. The

condensors have reached a steady

state outlet temperature.

1 1 Steam Stripper System: The LVHC continues to

operate while the steam stripper is shut down.

Steam Stripp

feed rate is 

range.

Condensate Stripper INC1 143 2 Hot: 3.0 ‐ 8.0

hours Cold:

8.0 ‐ 12.0

hours

12 Confirm all condensates are collected and are

sent for treatment to either the Condensate

Stripper or to the Chemiwasher enclosed system

(1) Foul Condensates: Condensate

Stripper meets permissives and Foul

Condensates are sent to the StripperSystem. (2) Other Regulated

Condensates: No. 4 ChemiwasherSystem meets permissives and Other

Regulated Condensates are sent to

the No. 4 Chemiwasher

Hot and Cold:

0.5 ‐ 2.5

hours

2.5 ‐ Foul Condensates: Maintain Condensate

Stripper System and SOG Collection and

Treatment Systems until after Foul Condensates

are stopped being fed to the Stripper.** Other

Regulated Condensates: Maintain No. 4Chemiwasher System and HVLC Collection and T

Stop feeding 

Other Regul

their respec

Condensate Stripper INC1 149 1 4 4 Primary or alternate control device on prior to

startup

Normal steam flow to stripper and

stripper feed pump on

0 0 Primary or alternate control device on throughout

shutdown

Stripper feed 

Condensate Stripper INC1 150 1 0.3 0.3 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Tank is full 0.3 0.3 continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Feed pump t

Condensate Stripper INC1 162 1 0.5 0.5 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

0.5 0.5

Condensate Stripper INC1 162 2 NA BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases and (2) Ensure equipment is properly valved

to the LVHC Collection System.

Dependant on equipment systems

feeding tank

NA Continuing routing emissions to the LVHC

Collection System and Control Device

Dependant o

feeding tank

AppG_Equip_detail_stripper 
Appendix G

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas S

Condensate Stripper INC1 162 1 NA BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

NA Continuing routing emissions to the LVHC

Collection System and Control Device

Condensate Stripper INC1 163 1 0.5 to 1.5 1.5 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the HVLC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the HVLC

Collection System.

Appropriate operating temperature

and pressure achieved.

3 to 4 4 Continuing routing emissions to the HVLC System

and Control Device

Foul conden

the stripper 

Condensate Stripper INC1 163 2 2 2 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the SOG System control

device is ready to accept gases; and (2) Ensure

equipment is properly valved to the SOG

Collection System.

Appropriate operating temperature

and pressure achieved.

5 to 6 6 Continuing routing emissions to the SOG

Collection System and Control Device

Foul conden

the stripper 

Condensate Stripper INC1 166 1 0.5 0.5 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

0.08 0.08

Condensate Stripper INC1 166 1 NA BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases and (2) Ensure equipment is properly valved

to the LVHC Collection System.

Dependant on equipment systems

feeding tank

NA Continuing routing emissions to the LVHC

Collection System and Control Device

Dependant o

feeding tank

Condensate Stripper INC1 169 1 1 1 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases; and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

When either of these conditions is

met: 1) the reclaimed steam is valved

in to the chip bin(s) and steaming

vessel(s), 2) the normal extraction

flow(s) has been established and the

blow valve(s) have been opened, or

3) the product valves are switched to

t

1 1 Continuing routing emissions to the LVHC

Collection System and Control Device

When either 

met: 1) the c

down or 2) W

flow to the e

Condensate Stripper INC1 176 1 1 1 Condensates not sent to stripper until they have

reached temperature.

Steam ejector vacuum at 3" psia and

condensate temperature at 170F

1 1 Condensates will go directly to the hard pipe

system. Gases incinerated until stripper reaches a

non‐emitting state

When both f

feed pump a

stripper feed 

Condensate Stripper INC1 185 1 3.0 3 SOG stream must be directed to incineration

device before starting the feed pump

Stable streams and condensate flows 0.1 0.1 SOG stream must be directed to incineration

device while feed pump is running

Reducing ste

pump shutd

Condensate Stripper INC1 185 1 Integrated

with No. 4

Concentrator

‐ 8.0 hours

8 Integrated with No. 4 Concentrator ‐ NCG system

is operating before steam application

Integrated with No. 4 Concentrator Integrated

with No. 4

Concentrator

Shutdown ‐ 

8.0 hours

8 Integrated with No. 4 Concentrator Integrated w

Condensate Stripper INC1 185 1 NA NA Tank Level NA NA No level in t

Condensate Stripper INC1 189 1 0.25 0.25 Per the SSM Plan, ensure HVLC/LVHC Systems

Collecting. Check the LVHC System and verify that

there are no visible emissions and no noticeable

odors from all possible excess emission points.

Startup each area source following mill standard

operating proc

Per the SSM Plan, collection of

HVLC/LVHC System. Follow the LVHCPre‐Startup checklist as defined by

the mills standard operating

procedures. Verify the Incinerator,Lime Kiln, or 9A Boiler is online and at

a temperature ready to accept LVHC

gases.

0.25 0.25 Per the SSM Plan, continue routing to LVHC/HVLC

Collection System. Shutdown the LVHC Collection

System including associated Ejectors, Coolers,

Scrubbers, and other equipment following

standard operating procedures.

Per the SSM 

Follow the Lprocedures 

standard op

Verify that a

LVHC vent g

shutdown fo

shutdown p

Condensate Stripper INC1 190 1 1.5 1.5 Foul condensates are not directed to the stripper

during startup.

Appropriate operating temperature

and pressure achieved.

4 4 Foul condensates are not directed to the stripper

during shutdown.

cease flow o

stripper

Condensate Stripper INC1 531 1 Hot Startup:

.25‐1 hours

Cold Startup:

1‐4 hours

4 BEFORE startup of the Steam Stripper Off‐Gas

System: (1) Confirm the LVHC System control

device is ready to accept gases and (2) Ensure

equipment is properly valved to the LVHC

Collection System.

Standard operating conditions are

met

Hot

Shutdown:

0.1‐1 hour

Cold

Shutdown: 1‐

2 hours

2

Condensate Stripper INC1 531 1 NA BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases and (2) Ensure equipment is properly valved

to the LVHC Collection System.

Dependant on equipment systems

feeding tank

NA Continuing routing emissions to the LVHC

Collection System and Control Device

Dependant o

feeding tank

Condensate Stripper INC1 613 1 0 0 NA NA NA

AppG_Equip_detail_stripper 
Appendix G

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas S

Condensate Stripper INC1 613 1 2 2 Per the SSM Plan: Foul condensate to

stripper, 250‐900 gpm. Conductivity

set point on foul condensate to

stripper <2000 umhos. 35000‐95000

pph steam flow. <80 lbs steam

pressure. Foul condensate feedtemperature, 240‐295 F.

2 2 Per the SSM 

flow = 0

Condensate Stripper INC1 617 1 2 hours 2 start up LVHC‐1 collection system prior to

emission unit start‐up

>80 gpm condensate feed, meets

conductivity target, steam flow

@3000 pph min., steam/condensate

ratio at 1.2 min.

1 hour 1 continue routing emissions to LVHC‐1 collection

system

steam and c

off

Condensate Stripper INC1/SCBR 136 1 1 1 Supplement SOG flow with makeup steam to

establish continuous flow to IQS

Stripping steam supply >= 12kpph for

1 hour

0 0 Supplement SOG flow with makeup steam to

establish continuous flow to IQS

Stripping ste

Condensate Stripper INC1/SCBR 136 4 NA NA NA NA NA NACondensate Stripper INC1_TO 106 5 24 24 Verify primary or backup control device is

available prior to startup.

Stripper, evaporator, brown stockwasher, and digester startups are

complete.

12 12 Collected gases are routed to a control device

until the stripper, evaporator, brown stock

washer, and digester systems are all shutdown.

Stripper, evawasher, and 

shutdown.

Condensate Stripper SCBR 143 1 Hot: 0.5 ‐ 1.0

hours Cold:

3.0 ‐4.0 hours

4 Confirm all condensates are collected and are

sent for treatment to the Chemiwasher enclosed

system

Other Regulated Condensates: No. 4

Chemiwasher System meets

permissives and Other Regulated

Condensates are sent to the No. 4

Chemiwasher.

Hot or Cold:

0.5 ‐ 1.5

hours

1.5 Other Regulated Condensates: Maintain No. 4

Chemiwasher and HVLC Collection and Treatment

System until after Other Regulated Condensates

are stopped being fed to the No. 4 Chemiwasher.

Stop feeding 

Other Regul

their respec

Condensate Stripper SCBR/INC_LK 103 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

When stripper operation is stable 1 1 SOG is routed to the associated control device for

a minimum of one hour after which SOG is being

produced to evacualte lines

The condens

down.

Condensate Stripper SCBR/INC_LK 226 1 0.25 0.25 ensure primary and backup control are available #1 or #2 kraft digesters in operation,

Turpentine decanter condensate

pump on, flash evaporator hotwell

pump on,

0.2 0.2 continue routing emissions to collection system

and primary or backup control system

#1 or #2 kra

operation, T

condensate 

evaporator h

Condensate Stripper SCBR/INC_LK 226 1 0.25 0.25 ensure primary and backup control are available HPD evaporator train is in operation

and the evaporator hot well pump is

on

0.5 0.5 continue routing emissions to collection system

and primary or backup control system

HPD evapor

operation an

well pump is 

Condensate Stripper SCBR/INC_LK/ESP 151 1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Condensate Stripper feed is in range

of 500‐1000gpm and, temperature is

greater than 280F and stripper steam

flow is greater than 30000 lb/hr.

continue routing emissions to LVHC‐1 collection

system and primary or backup control system

Condensatestripping col

Condensate Stripper SCBR/INC_LK/ESP 151 1 12 12 stripper steam application rate

reaches target; and begin flow of

process condensates from tank

8 8 stop steam f

Condensate Stripper SCBR/INC_LK/SCBR 167 1 0 0 BEFORE startup of any of the equipment systems

feeding condensate to the tank: (1) Confirm the

LVHC System control device is ready to accept

gases; and (2) Ensure equipment is properly

valved to the LVHC Collection System.

Dependant on equipment systems

feeding tank

0 0 Continuing routing emissions to the LVHC

Collection System and Control Device

Dependant o

feeding tank

Condensate Stripper SCBR/INC_TO/SCBR 130 1 1 1 BEFORE placing tank into service: 1) Confirm the

LVHC System control device is ready to accept

vent gases and 2) Ensure equipment is properly

valved to the LVHC Collection System

Operation has stabilized.

Condensate streams are free of any

liquor contamination.

0.5 ‐ 16 Continuing routing emissions to the LVHC

Collection System and Control Device

Foul conden

idividual con

process area

Condensate Stripper SCBR/INC_TO/SCBR 198 1 0.05 0.05 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Product solids, steam pressure,

vacuum system, liquor and

condensate flows within normal

operating ranges, no alarms, no

rupture disk failures

8 8 continue routing emissions to LVHC‐1 and HVLC‐1

collection system and primary or backup control

system

Reduction/tor steam to 

Condensate Stripper SCBR/INC_TO/SCBR 240 1Condensate Stripper SCBR/INC_TO/SCBR 525 1 0 0 NA NA 0 0 NA NACondensate Stripper SCRB/INC_BOIL/CYC/ESP 200 1Condensate Stripper STRIP/INC_TO/SCBR 143 2 Hot or Cold:

2.0 ‐ 3.0

hours

3 Confirm all condensates are collected and are

sent for treatment to either the Chemiwasher

enclosed system or the condensate stripper

(1) Foul Condensates: Condensate

Stripper meets permissives and Foul

Condensates are sent to the Stripper

System. (2) Other Regulated

Condensates: No. 4 Chemiwasher

System meets permissives and Other

Regulated Condensates are sent to

the No. 4 Chemiwasher

Hot or Cold:

0.5 ‐ 1.5

hours

1.5 ‐ Foul Condensates: Maintain Condensate

Stripper System and SOG Collection and

Treatment Systems until after Foul Condensates

are stopped being fed to the Stripper.** Other

Regulated Condensates: Maintain No. 4Chemiwasher System and HVLC Collection and T

Stop feeding 

Other Regul

their respec

AppG_Equip_detail_stripper 
Appendix G

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas S

Condensate Stripper STRIP/INC_TO/SCBR 143 1 Hot or Cold:

2.0 ‐ 3.0

hours

3 Confirm all condensates are collected and are

sent for treatment to either the Chemiwasher

enclosed system or the condensate stripper

(1) Foul Condensates: Condensate

Stripper meets permissives and Foul

Condensates are sent to the Stripper

System. (2) Other Regulated

Condensates: No. 4 Chemiwasher

System meets permissives and Other

Regulated Condensates are sent to

the No. 4 Chemiwasher

Hot or Cold:

0.5 ‐ 1.5

hours

1.5 **Foul Condensates: Maintain Condensate

Stripper System and SOG Collection and

Treatment Systems until after Foul Condensates

are stopped being fed to the Stripper.** Other

Regulated Condensates: Maintain No. 4Chemiwasher System and HVLC Collection and T

Stop feeding 

Other Regul

their respec

Condensate Stripper STRIP/INC_TO/SCBR 143 2 Hot or Cold:

2.0 ‐ 3.0

hours

3 Confirm all condensates are collected and are

sent for treatment to either the Chemiwasher

enclosed system or the condensate stripper

(1) Foul Condensates: Condensate

Stripper meets permissives and Foul

Condensates are sent to the Stripper

System. (2) Other Regulated

Condensates: No. 4 Chemiwasher

System meets permissives and Other

Regulated Condensates are sent to

the No. 4 Chemiwasher

Hot or Cold:

0.5 ‐ 1.5

hours

1.5 ‐ Foul Condensates: Maintain Condensate

Stripper System and SOG Collection and

Treatment Systems until after Foul Condensates

are stopped being fed to the Stripper.**‐ Other

Regulated Condensates: Maintain No. 4Chemiwasher System and HVLC Collection and

Stop feeding 

Other Regul

their respec

Condensate Stripper STRIP/SCBR 143 1 Hot or Cold:

2.0 ‐ 3.0

hours

3 Confirm all condensates are collected and are

sent for treatment to either the Chemiwasher

enclosed system or the condensate stripper

(1) Foul Condensates: Condensate

Stripper meets permissives and Foul

Condensates are sent to the Stripper

System. (2) Other Regulated

Condensates: No. 4 Chemiwasher

System meets permissives and Other

Regulated Condensates are sent to

the No. 4 Chemiwasher

Hot or Cold:

0.5 ‐ 1.5

hours

1.5 ‐ Foul Condensates: Maintain Condensate

Stripper System and SOG Collection and

Treatment Systems until after Foul Condensates

are stopped being fed to the Stripper.** Other

Regulated Condensates: Maintain No. 4Chemiwasher System and HVLC Collection and T

Stop feeding 

Other Regul

their respec

Condensate Stripper STRIP/SCBR 143 1 Hot or Cold:

2.0 ‐ 3.0

hours

3 Confirm all condensates are collected and are

sent for treatment to either the Chemiwasher

enclosed system or the condensate stripper

(1) Foul Condensates: Condensate

Stripper meets permissives and Foul

Condensates are sent to the Stripper

System. (2) Other Regulated

Condensates: No. 4 Chemiwasher

System meets permissives and Other

Regulated Condensates are sent to

the No. 4 Chemiwasher

Hot or Cold:

0.5 ‐ 1.5

hours

1.5 **Foul Condensates: Maintain Condensate

Stripper System and SOG Collection and

Treatment Systems until after Foul Condensates

are stopped being fed to the Stripper.** Other

Regulated Condensates: Maintain No. 4Chemiwasher System and HVLC Collection and T

Stop feeding 

Other Regul

their respec

Condensate Stripper WW 133 1 0.25 0.25 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

named condensate steams are

collected, transferred to and treated

in UNOX system

0.25 0.25 continue routing foul condensate to UNOX unit all

sources are shut down

Condensate Stripper WW 175 1Condensate Stripper WW 181 1 0.1 0.1 condensate collected and routed to wastewater

treatment during startup

Condensate pump starts 0.1 0.1 condensate collected and routed to wastewater

treatment during shutdown

Condensate 

Condensate Stripper WW 182 1 UK Ensure waste water treatment system is

operational prior to startup.

UK UK Shutdown sources of foul condenstates prior to

shutdown.

UK

Condensate stripper: min 0 min 0

max 24 max 24

avg 3.0 avg 2.4

median 1 median 1

AppG_Equip_detail_stripper 
Appendix G

QAd_ProcessType RTI_APCD_Combo RTI CODE CountOfRTI

CODE

SU_Duration

_hrs

SU_Duration

_hrs_num

SU_EmissRednMeas SU_MarkEnd SD_Duration

_hrs

SD_Duration

_hrs_num

SD_EmissRednMeas S

Wastewater (Kraft) WW 117 1 24‐48 Minimize incoming load as much as possible COD < 238 mg / L 1.5 1.5 emission unit and control device operates during

emission unit shutdown (but not necessarily in

compliance with all NSPS/NESHAP parameter

limits)

Flow to UNO

stopped.

Wastewater (Kraft) WW 207 1 4.00 4 NA ‐ applicable emission and parameter limits not

expected to be exceeded during startup

sump is full and accumulator level is

up to >120 " or evaps producing

greater than 63% solids

8 8 NA ‐ applicable emission and parameter limits not

expected to be exceeded during shutdown

accmulator 

condensate 

flow to evap

Wastewater (Kraft) WW 615 1 0.1 0.1 Verify minimum aeration prior to accepting foul

condensate

Aerators above minimum level. 0.1 0.1 Aeration is operated above minimum until foul

condensate flow is shut off

Foul conden

aeration bas

Wastewater (Kraft):Biogas collection

INC_BOIL 205 1 0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Production of biogas at normal rate

(78 scf/ODTP)

0.1 0.1 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit shutdown

Anaerobic re

pump is shu

Wastewater (Kraft):Biogas collection

INC_BOIL 205 1 4.0 4 emission unit and control device operates in

compliance with NSPS and NESHAP parameter

limits during emission unit startup

Production of biogas at normal rate

(78 scf/ODTP)

1.0 1 continue routing emissions to biogas collection

system and primary or backup control system

Anaerobic re

pump is shu

Wastewater (Kraft): Biogas collection

Wastewater (Kraft)

AppG_Equip_detail_stripper