### Date: November 1 1 , 2011

Subject: Inputs to the Pulp and Paper Industry October 2011 Residual Risk Modeling

EPA Contract No. EP

- D

- 0 7

- 019 ; Work Assignment No. 4

- 0 9

From: Thomas Holloway

, Katie Hanks , Corey Gooden, and Matt Hakos

To: John Bradfield and Bill Schrock

U.S. Envir onmental Protection Agency Research Triangle Park, NC 27711

I

. Introduction

Section 112(f)(2) of the Clean Air Act (CAA) directs the U.S. Environmental Protection Agency ( EPA ) to conduct risk assessments on each source category subject to maximum achievable control technology (MACT) standards and determine if additional standards are

needed to reduce residual risks. Section 112(d)(6) of the CAA requires EPA to revie w and revise the MACT standards, as necessary, taking into account developments in practices, processes, and control technologies. The section 112(f)(2) residual risk review and sect ion 112(d)(6) technology

review are to be done 8 years after promulgation of the original standards

. The national

emissions standards for hazardous air pollutants (NESHAP) for the pulp and paper industry (40 CFR part 63, subpart S) w ere promulgated in 1998 and are due for review under CAA section s 112(f)(2) and 112(d)(6)

.

In Fe bruary 2011

, the EPA initiated a three

- part Information Collection Request (ICR) to gather information from U.S. pulp and paper manufacturers needed to conduct the CAA

- required regulatory reviews

. The second part of the ICR (Part II), which concluded in June 2011, was targeted towards facilities that are major sources of HAP emissions, and involved an update of

pre

- populated National Emissions Inventory (NEI) data spreadsheets (or creation of new NEI data sets). The response rate for Part II of EPA’s ICR was 100 percent, with respondents submitting NEI spreadsheets for 17 1 major sources ( 2 of which were new NEI data sets for mills not previously included in the NEI)

.

Two substantial quality assurance (QA) efforts were conducted on the P art II data in

orde r to create the modeling files needed for the residual risk assessment : (1) QA of the spreadsheets submitted by each mill prior to import into the compiled database , and (2) QA and standardization of the compiled database . These QA efforts are discussed in sections II and III of

this memo. (Note: Modeling files were needed for both the subpart S category and the whole facility, so QA efforts focused on data for all emission sources at pulp and paper facilities.)

### 2 The purpose of this memorandum is to document the inputs to the residual risk modeling file, specifically (1) QA and standardization of the NEI data for the pulp and paper industry including the default parameters used (Sections II and III) , (2) pollutant speciation and apportionment factors (Section IV) , ( 3 ) emission process groups assigned to the pulp and paper source classification codes (SCCs) (Section V) , ( 4 ) a llowable emissions multipliers (Section VI)

, ( 5 ) acute emissions multipliers (Section VII) , and (6) information relating to acrolein emissions estimation (Section VIII)

.

II

. QA of Part II NEI Update Spreadsheets

A

. Review Checklist

The first step in preparing the inputs to the residual risk modeling file was to QA the individual NEI update spreadsheets received from each of the pulp and paper mills in response to Part II of the February 2011 survey sent to the pulp and paper industry. NEI update spreadsheets

for 17 1 major sources were reviewed.

W e began our QA of the pulp and paper NEI update spreadsheets using a checklist, which is provided in Appendix A to this memorandum . The checklist looked at consistency in facility name, information in the wrong column, equipment we expected to see, pollutants we expected to see, missing stack and fugitive parameters, missing latitude/longitude values, and any other observations, such as recommendations for follow

- up with the mills (e.g., if the spreadsheets were missing the information we expected to see). Associated tables of the subpart S equipment we expected to see are also provided in Appendix A.

In addition to providing recommendations for follow

- up, the checklists were also useful

in informing the later, more in

- depth review and revision of each inventory spreadsheet

. If we found any obvious errors (e.g., providing text in code columns), we corrected them. If any information was provided in the wrong column (e.g., new data placed in revision columns), we

moved it to the correct column. Because some columns in the inven tory files did not have revision columns (e.g., facility name, emission unit ID, etc.), we included an “RTI Notes” column in the revised files that noted any changes to those columns. Revisions to the inventory

fi les were highlighted in yellow. Several mil ls were contacted with follow

- up questions, and these clarifications were incorporated into the Part II spreadsheets before further processing.

The re vised inventory files were transferred to the NEI team for compilation into a

database file. Prior to transferring the files, we also made any necessary formatting changes to facilitate the compilation (e.g., eliminating merged cells, merging/copying notes that had been spread across rows).

The following sections discuss in greater detail the in

- depth QA we conducted of the inventory spreadsheets. It should be noted that, over the course of reviewing the many inventory spreadsheets, the scope of the QA evolved (increased) , such that some of the QA activities

discussed below were only conducted in the later reviews

.

### 3 B

. Recommended Inventory Deletions

A t the st art of each in

- depth QA , we evaluated the acceptability of each mill’s

recommended inventory deletions to ensure that the mills did not mark for deletion something

that was no t replaced and would be neede d for subpart S modeling or whole

- facility modeling. If the file included detailed reasons for why certain records were deleted (e.g., equipment no longer in operation, r eplacement data provided in specified rows, emissions vented to a vent gas

collection system) we evaluated those reasons and provided our recommendation regarding those deletions in the “RTI Notes” column. If the file did not include detailed reasons, we determined the acceptability of the deletions by first filtering on the rows selected f or deletion and noting the SCCs included in that dataset, and then filtering on the replacement rows and noting which SCCs in the deletion dataset were included in the replacement dataset. (This approach was necessary

because mills often used emission unit IDs in their replacement inventories that were completely different from the emission unit IDs in the inventories marked for deletion.)

If an SCC was not included in the replacement dataset, we attempted to determine the reason why (e.g., equipment no lo nger in operation, emissions vented to a vent gas collection
system , not a source of hazardous air pollutant [ HAP ] emissions , a different SCC was use d for the same process, etc.). In most cases, we found the deletions to be reasonable, and noted “OK to

del ete” in the “RTI Notes” column. If we could find no reason why a particular SCC was selected for deletion, we included a note in the “RTI Notes” column stating that the emission unit associated with that SCC should not be deleted and exp laining why. W here necessary, we followed up with mills regar ding these suggested deletions.

Some of the emission units consistently marked for deletion and not replaced include methanol storage tanks, chlorine dioxide generators, coating operations, boilers, landfills,

sal tcake mix tanks, etc., presumably because these equipment are not regulated under subpart s S or MM or were not specifically required to be reported in the Part II survey . (Note: We only kept the HAP data for these emission units, since only those data are needed for risk modeling.)

Once we had decided which records to keep (i.e., not delete), we reviewed those records to ensure that they would be consistent with the replacement inventory (e.g., same facility name, facility ID, etc.). If we found additional records that needed deletion (e.g., not emission points), we marked those rows for deletion (with the rows highlighted in yellow in the spreadsheet ) and noted the reasons for the deletion in the “RTI Notes” column. After reviewing all recommended

deletion s, we filtered the inventory spreadsheets to view only the accepted records, and we conducted the rest of our review looking at just the filtered (accepted) data.

C

. ID Fields

After filtering the data, w e checked each inventory spreadsheet for gaps in the various ID

fields

— emission unit ID, process ID, and emission release point ID. Where there were gaps, we filled them where possible

, consistent with the numbering approach used in each file. If the gaps were significant and no clear way wa s found to determine the IDs, we followed up with the mill to obtain the IDs. We also checked the process ID against the SCC to ensure that there was only one SCC per process ID. If there was more than one SCC (e.g., for a different boiler fuel type)

,

### 4 we a dded more process IDs (one for each SCC for a given emission unit). We also checked the emission release point ID against the stack and fugitive parameters to ensure that there was only one set of parameters per emission release point ID. If there was more than one set of parameters, we added more emission release point IDs (one for each set of parameters for a given emission unit).

D

. S ource Classification Codes

After checking the IDs, we reviewed the SCCs to ensure that they reasonably matched

the emission unit description, as well as the mill type ( e.g., kraft, sulfite, non

- sulfur semichemical, neutral sulfite semichemical (NSSC), thermo mechanical, groundwood, secondary fiber, paper only) and were internally consistent within the spreadsheet . For boilers, w e looked to see that the SCC was for industrial boilers (as opposed to commercial, institutional

, or utility boilers) and matched the SCC to the fuel type (e.g., coal, wood, oil, natural gas) in the emission unit description

. Where we determined the SCCs w ere incorrect, we replaced them with more appropriate SCCs from the SCC listing provided in the lookup spreadsheet file included with Part II of the survey.

We also tried to substitute a more precise SCC for any generic SCC (e.g., 30700199, 30700499, 3999 9999), where possible. We used emission unit descriptions to come up with more precise SCCs. If emission unit descriptions were missing, we checked the emission unit ID against the mill’s Part I survey response and/or permit to determine the ident ity of th e emission

unit and make a more precise SCC assignment.

E

. Pollutants and Emissions

We then checked for gaps in the pollutant fields

— pollutant code, pollutant description, and HAP category name. Where we found gaps in these fields, we filled them using the p ollutant code table provided in the lookup spreadsheet file included with Part II of the p ulp and p aper survey. If a pollutant code was not provided in the lookup table, we found the CAS number for the pollutant online and entered that into the inventory f ile as the pollutant code. If a CAS

number was not available for a particular pollutant (e.g., m,p

- xylene), we left the cell blank (with the problem to be resolved later in the QA of the compiled database file )

.

We also checked for missing emissions data and, if we were no t able to fill the data gaps easily (e.g., the data were not for an identical type of emission unit ), we followed up with the

mill to obtain the missing data. We did not check the reasonableness of the emissions data in the spreadsheets o r whether there were any duplicate emissions data ( that would be done in the QA

of the compiled file), unless it was obvious. Where emissions data were obviously suspicious, we followed up with the mill regarding the data. Where there were obviously duplicate emissions data, our approach varied depending on the situation. We either followed up with the mill, added more process IDs or emission release point IDs to eliminate duplication for a given emission unit, or added a note to the “RTI Notes” colum n to combine or delete the duplicate data at a later time (during the QA of the compiled file)

. We also noted where HAP data were completely missing from a mill’s inventory of subpart S sources , but deferred any solution to that problem until the compiled file had been received

.

### 5 F

. MACT Codes

We compared the MACT codes to the SCCs in the inventory spreadsheets to determine whether they were reasonable and internally consistent within the spreadsheet , for example:

• Subpart S MACT code (1626

- 1) for SCCs associa ted with pulp and paper production

• Subpart MM MACT code (1626

- 2) for SCCs associated with pulp and paper chemical

recovery

• Pulp and paper n on

- MACT facility MACT code (1626

- 3) for SCCs associated with landfills, wood handling, etc. at pulp and paper mills

• B oiler MACT codes (0107

- 1,

- 2,

- 3,

- 4) for SCCs associated with boilers at pulp and paper mills

• Paper and other web coating MACT code (0711) for SCCs associated with paper coating that was not specifically identified as on

- machine coating.

If we determined that the MACT codes were incorrect, we replaced them with the correct MACT codes from the MACT code listing provided in the lookup spreadsheet file included with Part II of the survey.

G

. Latitudes / Longitudes

After reviewing the MACT codes, we checked for g aps in the latitude and longitude data. If we found gaps, we checked the rest of the file to see if latitude and longitude data were provided elsewhere for that particular emission point and could be copied. Otherwise, we used

the default latitude and long itude values for the entire mill. We did not check the accuracy of the latitude and longitude data in this step

. That task was to be handled by EPA in the compiled file.

H

. Stack and Fugitive Parameters

We also checked the stack and fugitive parameters against emission release point type to see whether they were consistent. If an emission point had stack parameters but was labeled as a fugitive emission source (emission release point type of “01”), we changed the emission release point type to “02,” c onsistent with a stack emission source. Similarly, if an emission point had fugitive parameters but was labeled as a stack emission source (emission release point type of

“02” through “0 6 ”), we changed the emission release point type to “01,” consistent wit h a fugitive emi ssion source. This check was performed by filtering on emission release point type (i.e., filtering on “01” to review fugitive parameters and filtering on the other emission release point types to review stack parameters).

Lastly, we check ed the stack and fugitive parameters for data gaps and errors. Where

there we re data gaps for stack emission sources, we checked the rest of the file to see if stack parameter data were provided elsewhere for that particular emission point and could be cop ied. Where possible, we calculated the missing data. For example, if exit gas velocity was missing but we had exit gas flow rate and stack diameter, we calculated the velocity using the following equation: Exit gas velocity = exit gas flow rate/stack area, where stack area = π * (diameter/2) 2

### 6 We also estimate d missing gas flow rate and stack diameter data using this equation. Where the exit gas flow rate provided by the mill was suspiciously high, we used this equation to determine if the flow rate might b e in units of actual cubic feet per minute (acfm), instead of actual cubic feet per second (acfs). If we determined that was the case, we divided the exit gas flow rate by 60.

If it appeared the mill had left the data blank deliberately (e.g., by indicati ng in a note that the data were unknown, by indicating in a note or stack default flag that they wanted stack defaults, or by leaving only certain columns blank), we added a note to the “RTI Notes” column to provide stack defaults for those missing paramet ers during the QA of the compiled database

file. If the mill used the term “ambient” for exit gas temperature, we assumed a temperature of 72°F. If the mill used the term “NA” for exit gas flow rate, we assumed a flow rate of 0 acfs according to the NEI de fault for fugitive sources

.

If it appeared the mill had left the data blank mistakenly (e.g., because this type of emission unit would typically have stack parameters, because the mill did not indicate they wanted stack defaults, or because all columns we re left blank), we followed up with the mill to see if they had the stack parameters.

Where there were data gaps for fugitive emission sources (i.e., fugitive length, fugitive width, fugitive angle), we left the data gaps and did not follow up with the mi ll. (Measurements of some fugitive parameters may not be readily available or easy to obtain

. ) Instead, we decided

to fill t he data gaps with fugitive defaults during our QA of the compiled file. Because such data gaps were numerous in the individual inven tory files, we did not include any notes about them in

the “RTI Notes” column.

In the course of our QA , w e also provided stack defa ults for each fugitive emission

source. If a mill provided release height and temperature values for a fugitive source, we k ept those values and provided national default values for the rest of the stack parameters : 0.003 foot ( ft ) stack diameter, 0.0003 foot per second ( ft/sec ) exit gas velocity, and 0 acfs exit gas flow rate. If a mill provided release height but not temperature, we provided the national default temperature (72°F) for fugitive source s . If a mill provided neither release height nor temperature, we provided the national defaults for both (10 ft, 72°F). If a mill provided a release height of 0 ft (e.g., f or a wastewater basin), we changed the release height to the closest whole number (1 ft), consistent with EPA guidance.

III

. QA of Compiled NEI Database

Once the inventory spreadsheets had been compiled into an NEI database file , we conducted a second level of QA that could not have been effectively done on the individual inventory spreadsheets (e.g., compar ing and standardizing SCCs, pollutant codes, emissions, etc. across the industry). The QA of the compiled database file was also designed to catch any error s or omissions that were missed in the previous level of QA (i.e., the QA of the individual inventory spreadsheets).

### 7 The intermediate draft compiled file for QA was composed of a Facility table which

include d detailed facility information and a KEEP table which included the emissions and parameter information that we had indicated should be kept , plus some limited facility

information that could be linked back to the Facility tab le

. (Note: There was another compiled

file that also included all records from the inventory spreadsheets, including those we marked for

deletion. We did not QA this file but used it for reference .) At the beginning of our QA, t he

KEEP table contained over 1 45 ,000 records covering HAP, criteria air pollutants (CAP), total

reduced su lfur (TRS) and other pollutants

. Columns were included to reflect original data from the pre

- populated Part II NEI data spreadsheets

, edited Part II data from respondents , and final

data to be included in the NEI modeling file

.

Any additional records ide ntified for deletion in the course of our QA of the compiled file

were moved to a Deleted_items table in the file

. We entered line

- by

- line review notes in the

“ RTI Notes ” and “ Delete Comment ” columns as needed to reflect changes made to the data. We

insert ed a few “QAd” columns in the data base as needed to reflect our changes. However, due to

Access table width constraints, in some cases we just entered revisions into the “FINAL” column (e.g., for MACT code).

A

. Facilit y

/Emission Unit Information

Number of facilities

. We first checked the Facility and KEEP tables in the compiled file

to ensure that both tables included all the mills we expected to see

. No issues were found.

Major/area source status

. We double

- checked the major/area status of each mill and

c oncluded that all we re major sources

, with the exception of NEIWI4430444

- ST Paper, LLC

, Oconto Falls, WI. Our P art I survey records indicate this is a synthetic area source that should be removed from the Part II inventory prior to risk modeling. The fac ility did not make a ny updates to their Part II survey ( but instead indicated all the data were okay as is).

There were a handful of facilities that left their inventory labeled as “area” source, but

whose Part I survey response indicates they are a major source. We updated the FINAL Facility Category Code to reflect major source status for these facilities

.

Facility name

. We checked to ensure the facility name used by each facility wa s consistent throughout the database. A few instances of different name s being used for the same

mill were detected (a carryover from a few spreadsheets that were not complete inventory replacements)

. We corrected the facility names in the KEEP table where necessary to match the

names in the Facility table

.

Emission unit des cription

. We noted that some of the facility records for emission unit description were blank. If other fields contained descriptive information, we copied that to the

e mission unit d escription column for convenience. However, some blanks remain.

### 8 B

. Codes, ID s, and Dates

Emission unit/process/emission release point IDs . Gaps in these IDs were resolved first before we did any further work in the database. Next, we added the following concatenations to the beginning of the table to facilitate a review of records by unique emission unit: RTI_Unit: NEI ID

-- Emission Unit ID

-- Process ID
RTI_EmPt: NEI ID

-- E mission Unit ID

- - P rocess ID

- - Emissio n Release Point ID

We a lso added the following concatenations to the end of the table to facilitate detection of duplica te and differing values for stack parameters and latitudes/longitudes : Release_point_combo: State County FIPs

-- NEI ID

-- Emission Release Point ID Process_combo: State County FIPs

- - N EI ID

-- Emission Unit ID

SIC/NAICS codes

. Many Part II survey respondents used text different from the lookup

table in their Standard Industrial Classification ( SIC ) code descriptions and North American Industry Classification System ( NAICS ) code descriptions. We reviewed the SIC and NAICS

codes t o ensure they were consistent with the text used by the respondents and made any appropriate corrections

. The final codes reside in the corresponding “FINAL” columns. We deleted the column with respondents’ SIC description s after reviewing the SIC and NA I C S codes

to save space due to database size limitations (e.g., character limitation across rows ). The final SIC or NAICS descriptions can be linked from a standard lookup table, as needed.

SCC /MACT codes

. We spent considerable time on standardizing SCCs and MACT codes to ensure consistency within in the database . First, we reviewed each SCC by the emission unit description (and other descriptive columns) to ensure they were consistent. Next, we cross

tabbe d SCC vs. MACT code to look for inconsistencies. Except for the not

- elsewhere classified SCC ( 39999999 ), each SCC is now affiliated with only one MACT code. We reduced the

number of not

- elsewhere classified SCCs (e.g., ***** 999 s) by reviewing available pro cess descriptions and assigning more specific SCCs where possible. Table 1 at the end of this memorandum lists the MACT codes used in the compiled file.

Once the MACT codes were standardized, we removed the lengthy un

- standardized

MACT code and SCC descri ptions supplied by the respondents in order to save space

. As with SIC and NAICS descriptions, final code descriptions can be linked from a standard lookup table,

as needed.

Start and end dates

. We reviewed the base year information th at facilities provid ed in their Part II responses and corrected any obvious errors. Missing dates were populated with dates

from the mill ’s NEI update spreadsheets.

Note: The Buckeye, Perry FL mill ( NEI ID No. NEI47091) submitted data for a direct contact evaporator ( DCE ) re covery furnace that was converted to a non

- direct contact evaporator ( NDCE ) recovery furnace mid

- year. DCE data were supplied for Jan uary through June 2010, and NDCE data were provided for July through Dec ember 2010. Rather than model the now obsolete

DCE data, we converted the NDCE data to reflect one year’s worth of operation (i.e., multiplied

### 9 by 2) from July 2010 through June 2011. The DCE data were flagged for deletion and moved to

the Deleted _i tems table.

Data source code

. We corrected any respondent misspellings and errors. Respondents

were asked to enter “RTR09” for new records

, but there were some obvious drag errors, misspellings, etc

.

Control measure codes

. We reviewed these codes for consistency with code definitions in the lookup table and stan dardized them

. Since these columns are not critical for the modeling file, we did not copy all codes down where they appeared for just some rows for a given

emission unit.

Emission release point type code s . Emission release point type codes were reviewed against the stack and fugitive parameters included in the database to ensure they were identified correctly. An emission release point type code of “01” indicates fugitive emissions, while all other emission release point type codes ( “ 02 ” through “ 0 6 ” ) ind icate stack emissions. Where it

was obvious that the code was in error, the emission release point type code was revised accordingly.

C

. Pollutants and Emissions

Pollutant codes

. The pollutant codes and names received with the Part II survey responses required extensive QA and standardization. There were missing and invalid codes, various permutations of pollutant names, etc. We made several specific changes to pollutant codes whe re necessary (e.g., coding thallium as a radionuclide).

There were also many non

- HAP pollutants included in the Part II responses that were not previously included in the NEI lookup table. For these “new” pollutants, we looked up their CAS

numbers ( either to verify the codes submitted by respondents or to obtain missing pollutant

codes ) and ensured the compiled database file included these pollutant codes. We created a lookup table for the compiled file that contains all of the old pollutant codes from the original NEI code lookup table and added to this table the “new” pollutants for pulp and paper (giving standardized names to the new pollutants

, based generally on the most commonly reported name). The EPA NEI team reviewed and provided comments on the ta ble , and we made the corresponding corrections. Table 2 presents the new non

- HAP pollutants added to the NEI pollutant lookup table.

Actual Emissions

. We reviewed the magnitude of emission s. We followed up with mills (as needed) for correction of obvious errors (e.g., 4.5 million tons per year [ tpy ] of chloroform). In many cases, there was a conversion error made by the respondent. We looked at HAP

emission s from individual processes above 100 tpy to identify obvious errors

.

Th e QA of emission s data focused more on HAP (particularly from 1626 MACT codes)

than on CAP or TRS due to time constraints. Some potentially random high emissions remain for

non

- 1626 processes and for CAP and TRS releases

.

### 10 In a couple of cases where emissions were obviously in error, and where emission factors were used in creating the estimates, we used ratios of emission factors to revise the emission s estimate s

.

Duplicate pollutant s . Numerous duplicate pollutants app eared in the database for each

RTI

_ EmPt. The reasons for most of the duplicates appeared to be:

• Part II respondent error (e.g., respondents updating old data and including new data for the same pollutant but not necessarily the same emission rate, etc.).

• Pollutant coding issues where only one code applied for what respondents considered a separate pollutant (e.g., cresols, xylenes, synonyms of pollutants).

• Coding of emission units that was not de tailed enough (e.g., multi

- fuel

- fired boilers

with different emissions estimates for each fuel but only one RTI_EmPt).

We spent a considerable amount of time resolving these duplicate issues. We resolved duplication issues relating to xylene that resulted from the double

- counting of mixed and individual xylene isom ers (with several xylene rows being moved to the Deleted_items table). For example, some data for m,p

– xylenes in the compiled file received pollutant code 1330207 [for “Xylenes (mixed isomers”)]

, which resulted in a problem if there was already data for to tal xylenes with pollutant code 1330207 (resulting in two rows with the same pollutant code and different emissions).

In many cases, the solution to duplicate pollutants was to recode the emission units, processes, or emission release points, as applicable. In some cases, we found we needed to delete exact duplicate pollutants, or delete the lowest of two duplicates (e.g., if there was an order

- of

magnitude difference in e missions such that the second duplicate didn’t add much). We noted the problem and corrective action in a separate spreadsheet (and often in t he “ RTI Notes ” or “ Delete

Comment ” i n the compiled database file ). For a few mills, we found that we had to sum up emissions after contacting the respondent.

Hexachloroethane emissions from pulp storage tanks

. We noted that some pulp storage

tanks had hexachloroethane emission s estimates. During our QA of a prior preliminary risk modeling file, we learned that Nation al Council for Air and Stream Improvement ( NCASI )

-- t he leading source of environmental data affecting th e pulp and paper industry

-- had eliminated th e emission factor for hexachloroethane for unbleached pulp mills. Upon review, we decided to keep the hexach loroethane emissions estimates as is because most were for bleached pulp mills

, where hexachloroethane might be expected

.

Routine maximum hourly emisisons

. This database field was structured as a text field.

We added a numeric

- double field called “ RoutineEmMaxHourly_lb/hr ” so we could use the

values in calculations.

We compared the maximum pound per hour ( lb/hr ) values with the actual tpy values and found wide discrepancies for many emission units (e.g., maximum lb/hr values resulting in less

than the routine tpy; lb/hr and tpy values differing by more than a factor of 1000 ). Therefore, we concluded that extreme caution should be exercised when using the maximum hourly emissions

field , and w e do not recommend using the maximum hourly emissions field for acute risk

### 11 modeling. Rather, we recommend consider ing this information in the development of acute multipliers, where out

- of

- range values can be discounted , as needed. (For further information, see the section on acute multipliers later in this memora ndum.)

Startup and s hutdown emissions

. Very little data were provided by survey respondents for startup and shutdown. Less than 2 percent of respondents supplied startup and shutdown emission rates, and

, i n most cases

, the startup and shutdown emission ra tes matched the maximum lb/hr emission rates for routine operation. These data were considered in development of acute multipliers, but ultimately were not useful.

Missing e missions

. For several mills, HAP emissions data were not provided for their subpart S (1626

- 1) sources

. In some cases, the volatile organic compound ( VOC ) emissions data that were provided were multiplied by HAP/VOC ratios to estimate the HAP emissions (where HAP emissions were expected)

. The HAP/VOC ratios were based o n HAP and VOC emission factors in NCASI Technical Bulletin 973, which is a compilation of the latest HAP emission factors for the pulp and paper industry. We developed HAP estimates for both routine annual

emissions and maximum hourly emissions , where VOC were available for both

. Where no VOC data were provided, we estimated the HAP emissions using the HAP emission factors from the NCASI bulletin and the production information from the mills’ Part I survey responses.

TRS

. The NEI data submitted with Part I I contain ed TRS in various forms:

• I ndividual speciated TRS compounds (e.g., hydrogen sulfide [H 2 

### S], methyl mercaptan)

• Total TRS as sulfur (S)

• T otal TRS as H 2 

### S

• T otal TRS (on an unspecified basis)

W hen standardizing pollutants in the NEI data file, we were careful to retain whether

total TRS was labeled “as S” or “as H 2 

### S.” The individual speciated TRS compounds are not HAP, although there is a HAP listing petition for H 2 

### S. There are several TRS compounds. These compounds are easily identifiable in the compil ed NEI data file because they have a general HAP category name of “ H 2 

### S ” or “ TRS .” However, the NSPS regulatory definition of TRS

includes four compounds: H 2 

### S, methyl mercaptan, dimethyl disulfide and dimethyl sulfide

. For mills supplying only total TRS data (e.g., TRS, TRS as S, or TRS as H 2 

### S), it was not possible to tell whether the total TRS were limited to the four TRS included in the regulatory definition or a larger number of TRS compounds.

D

. Lat itudes / L ong itude s

We reviewed the latitudes and longit udes for individual stack and fugitive release points in the compiled file. Where we found gaps in latitude/longitude data, we populated the gaps with data (where available) from a prior draft residual risk modeling effort. Often

, coordinates for the

cente r of the mill were used. Once we had filled all of the data gaps, we exported the latitude/longitude data into a spreadsheet file and sent the file to EPA, where the data were reviewed using Google Earth

. Any latitudes and longitudes that were off

- property were brought to the center of the property (unless the location of the emission release point was obvious, in

### 12 which case the lat itudes and longitudes were moved to the emission release point). As discusse d further below, EPA also used Google Earth to QA fugitive parameters, as ne eded. After EPA had completed its QA of the latitude/longitude data, we re

- imported the data back into the database

file

.

W e checked the latitudes and longitudes by using the Rel ease_point_combo concatenated codes (State County FIPS

-- NEI ID

-- Emission Release Point ID )

. We found n umerous duplicates where the same emission release point had multiple coordinates , which we corrected ( typically by creating new emission release point ID s for the duplicate records )

.

E

. Stack P arameters

Stack parameters for those records with an e mission r elease p oint code of “01” for fugitives were set at the national fugitive defaults: 10 ft stack height, 72°F exit gas temperature, 0.003 ft stack diameter, 0.0003 ft/sec exit gas velocity, and 0 ft 3 

### /sec exit gas flow rate. The reported fugitive release height and temperature (if different from the 10 ft and 72 ° F defaults)

were retained.

Stack parameters for all other e mission release p oint codes of “02” through “06” ( i.e., stacks) were reviewed. Where possible, information supplied was used to populate missing fields (e.g., if diameter and flow rate were provided, this information was used to back

- calculate velocity). Except for paper machines (SCC 307004 01), u nresolved blanks were populated with the 2002 NEI default parameters for each SCC, MACT code, and SIC. 1 

### The hierarchy applied for assigning the stack defaults was SCC > MACT code > SIC

.

Paper Machines

. For paper machines, a specific set of stack parameters was applied, consistent with guidance from industry (se e Appendix B for documentation)

. We applied the following default stack parameters for paper mach ine SCC 30700401:

• Stack height: 70 feet (ft)

• Stac k diameter: 4.6 ft

• Exit gas velocity: 30 feet per second (ft/sec)

• Exit gas flow rate: 499 cubic feet per second ( acfs )

Note: Industry’s guidance document on paper machine default stack parameters mentions applying these parameters to two SCCs: 30700401 an d 30700405. SCC 30700405 is no longer in use for the pulp and paper industry and was replaced in the compiled file with SCC 30700401

.

The default parameter we used for exit gas temperature varied, depending on whether the paper machine emission points wer e indicated in the NEI emission process description to be from the wet or dry end of the paper machine, or were not indicated:

• Wet end: 104°F

• Dry end: 149°F

• Not indicated: 125°F

1 See EPA website http://www.epa.gov/ttn/chief/net/2002inventory.html and click on “Stack parameter defaults” to download an Access database containing default stack parameters by SCC, MACT code, and SIC

.

### 13 For paper machine emission release point types identified as stack (codes “ 0 2 ” through

“ 0 6 ” ), we kept the stack parameters determined to be actual data and replaced those determined

to be NEI defaults for any facilities where NEI defaults had not already been resolved through the Part II survey process

.

For those paper machine em ission release point types identified as fugitive (code “ 01 ” ), we looked to see whether they had fugitive parameters (length and width). If they did, we left those parameters in place. If they did not, we revised the emission release point type code to

ind icate stack emissions (code “ 02 ” ) and then replaced the NEI national default stack parameters (10 ft height, 72°F temperature, 0.003 ft diameter, and 0.0003 ft/s velocity) with the industry

supplied default stack parameters noted above.

Other NEI stack pa rameter checks . We performed certain stack parameter checks that ar e typically done for NEI data. Flow rates were checked based on the aforementioned calculation using the stack exit diameter and velocity. Any flow rates varying by more than 10 percent fro m the calculated value were set to the calculated value.

The stack parameters were also checked against the Release_point_combo concatenated codes (State County FIPS

-- NEI ID

-- Emission Release Point ID) to re solve any duplicate or differing information (e.g., by adding new emission release point IDs, correcting stack parameters)

.

The stack parameters were also checked to ensure that the stack diameter was not greater than the stack height. Where this occurred, we reviewed each case individually to reso lve the

situation (e.g., replaced the stack height and/or diameter with correct information from the mill’s NEI update spreadsheet, replaced the stack diameter with a default value , back

- calculated stack diameter based on exit gas velocity and flow rate)

. We also checked to determine if the emission release point type was consistent with the type of equipment (SCC) and type of release parameters provided.

F

. Fugitive P arameters

After determining which emission release p oint t ypes in the database were fugitive “01,”

we reviewed the fugitive length, width, and angle. EPA plotted and measured several fugitive

emission sources (e.g., wastewater, liquor ponds, some paper machine buildings coded as fugitive) to verify length and width and to check fugitive angle, particularly when no angle was provided. Numerous fugitive parameters were blank or zero. In some cases, EPA populated the blank fugitive dimensions with values measured using Google Earth where such measurements were possible

. EPA also used Google Earth t o resolve fugitive angles that were negative or greater than 180 degrees.

Non

- wastewater fugitive parameters

. W ith the exception of wastewater, w e populated the remaining blanks for fugitive length and width with SCC

- specific fugitive dimension defaults w e created based on QA of the actual fugitive defaults provided for each SCC and engineering judgment. To be conservative, w e erred on the side of underestimatin g the dimensions, while

### 14 improving on the representativeness of the values (i.e., replacing the z eroes). The fugitive angle was considered to be zero. A table of the SCCs with affected fugitive emissions is provided in Appendix C.

Wastewater fugitive parameters

. The following default fugitive parameters were supplied by industry representatives for w astewater (see Appendix D f or industry documentation):

• Primary clarifiers: fugitive length and width = 177 ft; fugitive angle assumed to be zero

• Aeration stabilization basins (ASBs): fugitive length = 1500 ft; fugitive width = 1000 ft; fugitive angle assum ed to be zero

• Activated sludge treatment (AST) systems: fugitive length = 829 ft; fugitive width = 166 ft; fugitive angle assumed to be zero Note: Length and width for AST systems were calculated based on the midpoint (27,500 ft 2 

### ) of the range of AST areas (20,000 to 35,000 ft 2 

### ) provided by industry, using the midpoint (5) of the length/width ratio provided by industry (2 to 8).

The information we received from industry does not speak to release height, but the NEI defaults (e.g., 1 ft, 10 ft) seem reasonable for these types of sources (since some clarifiers or concrete basins are elevated).

For those wastewater emission release point types identified as fugitive (code “ 01 ” ), we added the industry

- supplied fugitive parameters where site

- specific fug itive parameters were not already available (e.g., through the Part II survey response or from a Google Earth measurement). We defaulted the release height to 10 ft for those records, if they had a higher release height. If the release height was 0 ft, we defaulted to 10 ft for clarifiers and 1 ft for ASBs and AST systems.

For those wastewater emission release point types identified as stack (codes “ 02 ” through

“ 0 6 ” ), where there were clearly NEI default stack parameters that carried through the Part II

survey process , we changed the emission release point type to fugitive and added the industry

supplied fugitive parameters and default release height specified above. Where the stack parameters could not be identified as default, we left the emission relea se point type an d stack parameters as reported

.

IV

. Pollutant Speciation and Apportionment

A

. Chromium Speciation

Chromium compounds are a significant contributor to increased cancer risk, but the level of risk largely depends on the oxidation state (species) of the compounds. The two most common chromium species are hexavalent chromium (Cr +6 

### ) and trivalent chromium (Cr +3 

### ). EPA has

classified Cr +6 

### and its compounds as known human carcinogens, while Cr +3 

### is not classified as to its human carcinogenicity. Consequently, determining the percentage of total chromium that is

Cr +6 

### vs. Cr +3 

### is a major factor in estimating the level of risk from chromium exposure.

Table 3 at the end of this memorandum presents t he default chromium speciation profile s that w ere used for the October 2011 risk modeling to generate estimates of Cr +6 

### (pollutant code

### 15 18540299) and Cr +3 

### (pollutant code 16065831)

. S peciation profile s are documented f or each SCC applicable to the pulp and paper industry (and included in the October 2011 risk modeling ). The chromium speciation profile s w ere applied where only total chromium estimates were provided ( for pollutant code 7440473 or 136 )

. S ome mills provided estimates for both total

chromium and Cr +6 

### for a particular sou rce

. In those cases , we subtracted the Cr +6 

### from the total

chromium to calculate Cr +3 

### and then deleted the total chromium estimate

.

B

. Mercury S peciation

Like chromium, the different oxidation states of mercury compounds vary in tox icity, but also in exposure pathway (e.g., inhalation, ingestion). The most common mercury species are divalent mercury (Hg +2 

### ) (including both particulate and gaseous forms) and elemental gaseous mercury (Hg 0 

### ). We recommend speciating mercury compounds (pollutant codes 7439976 and 199) using the NEI default multipliers of 0.2 for particulate divalent mercury (pollutant code 202) , 0.3 for gaseous divalent mercury (pollutant code 201) , and 0.5 for elemental gaseous

mercury (pol lutant code 200) for all sources in the compiled database file

. (EPA 2006a ) It should

be noted that there are a few records in the compiled file that are a lready speciated as elemental

mercury (pollutant code 200), and no further speciation is required for these records.

C

. POM S peciation

Polycyclic organic matter (POM) is comprised of a large number of individual compounds (POM species) , each with their own toxicity levels and exposure pathways. Within

the pulp and paper production category (MACT code 1626

- 1 ), there were several listings for POM in the compiled file that were unspeciated (pollutant code 246). Most facilities that reported POM speciated the data into individual compounds. Unspeciated (total) POMs were reported for some paper machines and direct

- fired paper machine dryers (SCC 30700401 ). Since many mills provided speciated POM compounds , POM speciation profile s were developed from

those mills to speciate total POM for mills with unspeciated POM data

. Table 4 at the end of this memorandum presents the POM speciation profile s used to replace unspeciated POM for paper machines and paper machine dryers (SCC 30700401 ).

D

. Dioxin /Furan Speciation and Apportionment

The predominant sources of dioxin/furan emissions at pulp and paper mills are the power boilers used to provide steam and electricity for the mill and the chemical recovery combustion sources (i.e., recovery furnaces and lime kilns) at the mill. Most mills reported dioxin/furan emissions for specific SCCs and MACT codes. However, some d ioxin /furan apportionment was needed for mill processes with an SCC of 39999999 (Misc Manuf/Indus Processes/ Other Not Classified) and a MACT code of 1626

- 3 ( Pulp a nd Paper Production

- N on

- MACT Facilities ).

One mill (NEI ID NEI47077) had d ioxin /furan emissions data listed for SCC 39999999

and MACT code 1626

- 3

. The dioxin/furan data were a lready speciated (i.e., had TEQ

congeners ). Since the mill had both boilers an d chemical recovery combustion sources, w e apportioned the dioxin/furan data to the 0107 MACT code (boilers at the facility) and 1626

- 2

### 16 MACT code ( chemical recovery combustion sources) using the following methodology

-- 5 5
percent to boilers and 45 percent t o chemical recovery com bustion sources

.

Two other mills (NEI IDs NEI33135 and NEI41252) had dioxin/furan emissions data

listed for SCC 39999999 and MACT code 1626

- 2

, but the data were unspeciated (i.e., reported as total dioxin, pollutant code 155), so we developed a congener profile for th e se sources

. Because most dioxin/furan emissions from MACT code 1626

- 2 are expected to come from the recovery furnace, we used the dioxin/furan congener profile for recovery furnaces in Table 5

- 13

of EPA ’s dioxin/furan i nventory report (EPA 2006 b ) to estimate the congener emissions

. Table 5 at the end of this memorandum presents the dioxin/furan congener profile and toxic equivalency factors (TEFs) used to replace the unspeciated dioxin/furan estimates for these 1626

- 2 sources with individual congener estimates ( expressed as 2,3,7,8

- TCDD TEQ). The toxic equivalency

factors are b ased on the latest EPA guidance

.

The EPA plans to QA the entire dioxin/furan emissions database and do further evaluations during the RTR process planned for the s ubpart MM category ( MACT code 1626

- 2) and anticipates further refinements in dioxin/furan emission s estimates when the Boiler MACT

rule is finali zed ( s ubpart DDDDD). For these reasons and because dioxin/furan emissions are not part of the s ubpart S category

, EPA did not model these emissions at this time.

E

. Glycol Ether Speciation

There are some listings of total glycol ethers in the database for M ACT codes 1626

- 1,

1626

- 2, and a few other MACT codes. We coded all total glycol ether records (identified as pollutant code 171) as 1,2

- d imethoxyethane (pollutant code 110714). The pollutant 1,2

- dimethoxyethane is the most commonly emitted glycol ether for pulp and paper. Consequently, we recommend using the risk benchmarks for 1,2

- dimethoxyethane when performing risk modeling for these records.

V

. Emission Process Group Assignments

Descriptive emission process groups were assigned to each SCC to group simila r emission units and facilitate analysis of the risk results. Each SCC is affiliated with only one

emission process group (but one emission process group can apply for multiple SCCs). Table 6 A

at the end of this memorandu m provides a listing of the SCCs co ntained in the October 2011 risk modeling file and the emission process groups assigned. Through the use of emission process

groups, we can focus our analyses of risk results and emissions on 82 consolidated emission

process groups rather than on 225 SCCs

. Some of the processes listed in Table 6 A do not emit HAP or TRS and do not appear in the risk modeling file. T o aid in analysis of the risk results, t he

e mission p rocess g roups were developed to be more detailed for SCCs within the 1626

- 1 risk modeling c ategory, but less detailed for emission units outside the category

. (For example, we combined all boilers into one emission process group.) Allowable and acute multipliers for the pulp and paper subpart S category (MACT code 1626

- 1) are affiliated with the emission process

groups

. The basis for these multipliers is discussed in the sections below.

### 17 VI

. Actual vs. Allowabl e Emissions

A

. Background

In addition to evaluating the residual risks associated with actual emissions, EPA

evaluates the risk associated with the emissions that would be allowed under the NESHAP, i.e., “allowable emissions,” since they reflect the maximum level that sources could emit and still comply with the national standards. Actual emissions are sometimes less than allowable

emissions due t o a compliance cushion, a more stringent state or local rule, or over

- control due to the use of control technologies, equipment, or work practices that are significantly better than that required by MACT. Any over

- control from pulp and paper processes, e.g

. , for mills using the subpart S clean condensate alternative or an equivalency

- by

- permit compliance option,

would be site

- specific and not estimable. The remainder of this section documents how multipliers were estimated to calculate allowable emissions.

B

. Allowable Multipliers for October 2011 Risk Modeling

Appendix E at the end of this memorandum lists the standards in subpart S to which pulp and paper production sources are subject. The sources include:

• Kraft pulping vent gases

• S oda or semichemical pulpi ng vent gases

• Sulfite pulping vent gases

• New and existing bleaching vent gases

• Kraft pulping process condensates

Under subpart S, these sources were given a series of compliance options to choose from, including equipment standards, work practice standards, numeric emission limits, and a clean

condensate alternative. Appendix E i dentifies the standard format for each of these compliance options. Based on industry responses to the Part I survey, we looked at the most commonly chosen subpart S compli ance options for each emission process group in determining how to estimate allowable multipliers for pulp and paper production sources.

Equipment or work practice standards

. For equipment standards and work practice standards, it is generally assumed tha t allowable emissions equal actual emissions (because emissions typically are not measured when equipment or work practices are in effect). Based on the survey data we have received, we have determined that mills generally are not using equipment or work p ractices superior to that required by MACT. Therefore, we are assuming actual and allowable emissions are equivalent under the equipment and work practice standards, resulting in an allowable multiplier of 1.

Numeric emission limits

. For numeric emission limits, certain information is needed to estimate allowable multipliers, which varies depending on the type of limit. The subpart S compliance options include three types of numeric emission limits, including performance limits (percent reduction), concent ration limits (parts per million by volume [ppmv] or weight [ppmw]), and production

- based emission limits (pounds per ton of oven

- dried pulp [lb/ton

### 18 ODP]). Appendix E i dentifies the types of information that is needed to calculate allowable multipliers.

T o calculate allowable multipliers based on performance limits (percent reduction), we

would need to know the actual performance (percent reduction) level achieved, which is available from the survey responses for subpart S sources. To calculate allowable m ultipliers based on concentration limits (ppmv and ppmw), we would need to know the molecular weight of the pollutant, stack gas temperature, and stack gas flow rate. The numeric emission limits in subpart S use surrogate pollutants for total HAP, specific ally methanol for pulping process vent gases and condensates and chlorine for bleaching processes. The molecular weights of methanol

and chlorine could be used in a llowable emissions calculations.

B ased on our review of the survey responses for subpart S sources, most kraft mills have chosen to meet the equipment standards rather than the concentration limit s for kraft pulping
vent gases and kraft pulping process condensates. Also, c alculatin g allowa ble multipliers based

on concentration limits would be very site

- specific and subject to considerable variability, depending on the stack gas temperature and flow rate data used in the calculations. Consequently, we have estimated allowable multipliers for kraft pulping vent gases and kraft pulping process condensates based on performance limits rather than concentration limits.

To calculate allowable multipliers for sulfite mills based on their production

- based emission limits (lb/ton ODP emitted ), we would need information on actual production levels (e.g., ton ODP per year), which is available from the survey responses for subpart S sources. Based on our review of the survey responses for subpart S sources, m ost sulfite mills have

chosen to meet eithe r the 0.89 lb/ton ODP limit (for Ca

- and Na

- based sulfite mills) or 2.2 lb/ton ODP limit (for NH 3 

### - based sulfite mills) . Although we have sufficient information from these mills’ Part I survey responses to calculate their allowable emissions, we do not have sufficient information from the NEI on the actual pulping emissions for these mills to enable us to develop an allowable multiplier. Therefore, we instead used the equivalent 92 percent performance limit

for Ca

- and Na

- based sulfite mills and 87 percent p erformance limit for NH 3 

### - based sulfite mills to calculate the allowable multipliers

. (Note that there are no longer any Mg

- based sulfite mills in operation that would be subject to subpart S standards.)

To calculate allowable multipliers for kraft pulping process condensates based on their production

- based “removal” emission limits (lb/ton ODP removed ), we would need information on actual production levels (e.g., ton ODP per year) and uncontrolled emissions (from which the limits would be subtracted) . Howe ver, we do not have uncontrolled emissions data for kraft pulping process condensates. Therefore, we instead used the equivalent 92 percent performance

limit to calculate the allowable multiplier for kraft pulping process condensates.

Clean condensate alt ernative (CCA)

. Subpart S provides a clean condensate alternative, which is an emissions averaging approach to offset emissions from certain existing kraft pulping sources (e.g., high volume low concentration [HVLC] sources). Emissions reductions achieved under this compliance alternative are calculated on a site

- specific basis and must be at least as great that those achieved through the kraft pulping HVLC system standards. Although the subpart S survey responses showed a number of mills using the CCA opti on, we are not

### 19 evaluating this option for allowable emissions for the October 2011 risk modeling due to the site

specific nature of the emissions calculations.

Uncontrolled emission units

. Actual and allowable emissions are equivalent for

uncontrolled emi ssion sources, resulting in an allowable multiplier of 1. Based on our analysis of the survey data, most emission sources within the s ubpart S source category that were not subject

to s ubpart S standards a re uncontrolled.

Emission units controlled under o ther emission standards

. Permit limits requested in the pulp and paper survey were used to evaluate whether there are emission units in the pulp and paper industry with emission limitations more stringent than the pulp and paper standards (in

which case al lowable emissions would be lower than the “MACT allowable” emissions). We

found no directly comparable information showing any HAP emission limitations more stringent

than MACT are in place for subpart S sources

.

Allowable m ultipliers

. For the October 2011 risk modeling, analysis of actual vs. allowable emissions is focused on the subpart S performance (percent reduction) limits and equipment or work practice standards. This analysis relies on actual emissions reductions presented in the Part I survey r esults (including actual emissions data and specific compliance options used).

A summary of the allowable multipliers for each emission source type is provided in

Table 7 at the end of this memorandum

, and the allowable multipliers assigned to each emissi on

process group for residual risk modeling are provided in Table 6 B

.

VII

. Acute Exposure Estimation Approach

A

. Background

In addition to the chronic, long

- term exposures addressed under cancer risk, EPA also considers acute, short

- term exposures in its risk

- based decision

- making. In the absence of short

term emissions data, EPA estimates peak, short

- term emissions using available annual emissions

data in the NEI. In previous RTR rulemakings, EPA has assumed that a facility’s peak, 1

- hour

emissi on rate co uld exceed its annual average hourly emission rate by as much as a factor of 10,

under worst

- case meteorological conditions and the presence of a human receptor at the facility boundary. (EPA 2010) In meetings with pulp and paper industry representatives, we were told that a default peak

- to

- mean ratio of 10 was unrepresentative of some pulp and paper processes. The pulp and paper industry initiated a study of peak

- to

- mean ratios for two pulp and paper

emission sources

— papermaking and wastewater

— for EPA’s co nsideration

.

In order to refine the default

- 10 assumption, peak hourly emission rates (lb/hr) (referred

to in Part II of the pulp and paper survey as “routine emissions maximum hourly rate”) were collected in the Part II survey ( the results for which were received on June 6, 2011). These peak hourly emission rates were reviewed as part of the Part II data review

. Under ideal circumstances, these data would be used directly to evaluate acute, short

- term exposures. However, the data provided by respondents had considerable inconsistencies. When compared to

### 20 the annual emissions (tpy) reported in the Part II survey (assuming 8,760 hours per year [ hr/yr ] ) the primary outliers identified were:

• Underestimate of peak hourly emission rates

– The peak h ourly emission rate scaled to a peak annual emission rate did not exceed actual annual emissions.

• Overestimate of peak hourly emission rates

– The peak hourly emission rate scaled to a peak annual emission rate excessively exceeded actual annual emissions

.

• Zero emission rates

– These emission rates w ere discarded from the analysis

.

Various reasons are expected for these outliers, including lack of understanding of the data request, decimal place errors, typos, etc. Most of the discrepancies appeared to be independent of annual operating hours (e.g., the discrepancies remained discrepancies even when tested at annual operating hours other than 8,760 hr/yr). Given the number of outliers at both the high and low end, we recommend using the P art II survey data to calculate acute multipliers for broad groupings of equipment as opposed to directly modeling of the peak hourly emission rates provided in the Part II data set. Such acute multipliers would also be needed to fill data gaps where peak hourly rates were not provided. Acute multipliers are often referred to as peak

- to

mean ratios. Acute multipliers can be developed by various methods. A summary of the methodology used to develop the acute multipliers for the October 2011 modeling is provided

below. Table 8 presents the acute multipliers.

B

. Acute Multipliers for October 2011 Risk Modeling

Papermaking and w astewater

. P ulp and paper industry representatives provided the following peak

- to

- mean ratios (acute multipliers):

• Paper machines

-- 1.6

• Wastewater

-- 2

Analys es from the industry to support these ratios are provided in Appendices F and G at
the end of this memorandum

. We have reviewed the papers and

, through our own independe nt analysis of survey data

, found the rationale acceptable. We recommend using these ratios for the

October 2011 risk modeling.

The paper machine peak

- to

- mean ratio of 1.6 was developed considering peak

- to

- mean paper production rates. E missions from all equipment in the paper mill are expected to be

uncontrolled and have emissions somewha t related (either directly or indirectly) to paper machine production rate. Therefore, for purposes of the October 2011 modeling, we recommend using the paper machine peak

- to

- mean ratio of 1.6 for all equipment in the paper mill that is related to papermak ing (e.g., stock preparation, repulping, dryers, etc.).

The wastewater peak

- to

- mean factor of 2 was developed considering wastewater from primary clarifiers and aeration stabilization basins (ASBs) at kraft mills, but, for purposes of the

October 2011 mo deling, we recommend applying it to all wastewater treatment units (not just primary clarifiers and ASBs at kraft mills).

Other p rocesses

. Part II of the pulp and paper survey ( received June 6, 2011) requested information on annual emission rates (referred to in Part II as “routine emissions”) and peak

### 21 hourly emission rates (discussed above). Peak

- to

- mean (acute) ratios were derived from the Part II survey data as follows:

• Mean = Average annual lb/hr = Routine emissions (tpy) / (8760 hr/yr) x (2000 lb/ton)

• Peak = Routine emissi ons maximum hourly rate (lb/hr)

• Peak/Mean = [Routine emissions maximum hourly rate (lb/hr)] / (Average annual lb/hr)

As detailed above, the peak hourly emission ra tes provided by industry had outliers in the

data set. Although these values were precluded from direct input into the short

- term risk model, they can be used to develop more realistic acute multipliers, as industry has indicated that a default peak

- to

- mea n ratio of 10 is unrepresentative. The following approach was used.

All 1626

- 1 HAP emissions data from the Part II survey (57,281 records ) w ere compiled. A peak

- to

- mea n ratio was calculated for each HAP or TRS compound from each emission source
type. Zero emission rates and all peak

- to

- mean ratios less than one were removed from the data

set. A peak

- to

- mean ratio less than one indicates that the peak value provided is incorrect (does not exceed the average hourly emission rate and is

, therefore

, not a peak). The median peak

- to

mean ratio for each general equipment type was then determined. Removing peak

- to

- mean values less than one and using the median value reduce d the e ffects of excessively low and unusually high outliers.

It should be noted that we considered the startup and shutdown hourly rates collected in

P art II in this analysis. However, the startup and shutdown data were sparse and, in all cases, the startup and shutdown hourly rates were the same as the rates provided for peak hourly emissio n

rate. Therefore, these data ultimately were not useful for analysis of peak

- to

- mean ratios.

Acute multipliers

. A summary of median peak

- to

- mean ratios (acute multipliers) for each

emission source type is provided in Table 8 at the end of this memorandu m
, and t he acute multipliers assigned to each emission process group for residual risk modeling are provided in

Table 6 B

.

VIII

. Acrolein Data

Appendix H provides EPA ’s conclusions regarding use of the acrolein data provided in the Part II survey responses.

IX

. References

EPA 2006 a U.S. Environmental Protection Agency. 2005 National Emissions Inventory Data & Documentation, Inventory Documentation, Mercury Speciation . Web site: http://www.epa.gov/ttn/chief/net/2005inventory.html

. December 19, 2006

.

EPA 2006 b U.S. Environmental Protection Agency. An Inventory of Sources and Environmental Releases of Dioxin

- Like Compounds in the United States for the Years 1987, 1995, and 2000

. EPA/600/P

- 03/002F. November 2006.

### 22 EPA 2010 U.S. Environmental Protection Agency. Draft Residual Risk Assessment for the Chromic Acid Anodizing, Decorative Chromium Electroplating, and Hard Chromium Electroplating Source Categories

. Appendix 4: Analysis of data on

short

- term emission rates relative to long

- term emission rates. July 2010.

### 23 Table 1. MACT C odes Used for the October 2011 Pulp and Paper Risk Modeling

MACT

code MACT source category

0105

- 1 Stationary Reciprocating Internal Combustion Engines

– Natural Gas

0105

- 2 Stationary Reciprocating Internal Combustion Engines

– Oil

0107

- 1 Industrial/Commercial/ Institutional Boilers & Process Heaters

– coal

0107

- 2 Industrial/Commercial/ Institutional Boilers & Process Heaters

– gas 0107

- 3 Industrial/Commercial/ Institutional Boilers & Process Heaters

– oil

0107

- 4 Industrial/Commercial/ Institutional Boilers & Process Heaters

– wood or waste
0108

- 1 Stationary Combustion Turbines

– Natural Gas

0108

- 2 Stationary Combustion Turbines

– Oil

0601 Gasoline Distribution (Stage I)

0602 Organic Liquids Distribution (Non

- Gasoline)

0711 Paper & Other Webs (Surface Coating)

0714 Printing/Publishing (Surface Coating)

1626

- 1 Pulp & Paper Production

– Pulping and Bleaching Systems at Kraft, Soda, Sulfite, and Semichemical Pulping Mills (Subpart S)

1626

- 2 Pulp & Paper Production

– Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite,

and Stand

- alone Semichemical Pulping Mills (Subpart MM)

1626

- 3 Pulp and Paper Production

– NonMACT Faciliti es

### 24 Table 2. New Pollutants Added to NEI Pollutant List

Pollutant code Description Pollutant type a Pollutant Category Name

10049044 Chlorine Dioxide Chlorine Dioxide

100516 Benzyl Alcohol Benzyl Alcohol

100527 Benzaldehyde Benzaldehyde

107039 n

- Propyl Mercaptan TRS

108601 Bis(2

- Chloroisopropyl) ether Bis(2

- Chloroisopropyl) ether

108941 Cyclohexanone Cyclohexanone

109795 n

- Butyl Mercaptan TRS

110009 Furan Furan

110010 Tetrahydro

- Thiophene Tetrahydro

- Thiophene

110021 Thiophene Thiophene

110623 Valeraldehyde Valeraldehyde

110816 Diethyl Disulfide TRS

117840 Di

- n

- octyl phthalate Di

- n

- octyl phthalate

120832 2,4

- Dichlorophenol 2,4

- Dichlorophenol

123728 Butyraldehyde/n

- Butyraldehyde Butyraldehyde/n

- Butyraldehyde

124481 dibromochloromethane dibromochloromethane

127913 Beta

- Pinene Beta

- Pinene

1334787 m,p

- Tolualdehyde m,p

- Tolualdehyde

13466789 3

- Carene 3

- Carene

156592 1,2

- Dichloroethylene 1,2

- Dichloroethylene

27323188 Monochlorobiphenyl Monochlorobiphenyl

352932 Diethyl Sulfide TRS

37680685 Trichlorobiphenyl Polychlorinated Biphenyls

513440 Isobutyl Mercaptan TRS

529204 o

- Tolualdehyde o

- Tolualdehyde

540498 1,2

- Dibromoethene 1,2

- Dibromoethene

540590 1,2

- Dichloroethylene 1,2

- Dichloroethylene

5779942 2,5

- Dimethyl Benzaldehyde 2,5

- Dimethyl Benzaldehyde

590863 Isovaleraldehyde Isovaleraldehyde

5989275 Limonene Limonene

616444 Methyl Thiophene Methyl Thiophene

624895 Ethyl Methyl Sulfide TRS

624920 Dimethyl Disulfide TRS

638028 2,5

- Dimethyl thiophene 2,5

- Dimethyl thiophene

64175 Ethanol Ethanol

65850 Benzoic Acid Benzoic Acid

66251 Hexaldehyde Hexaldehyde

67630 Isopropanol [Isopropyl Alcohol] Isopropanol [Isopropyl Alcohol]

67641 Acetone Acetone

7429905 Aluminum Aluminum

7439896 Iron Iron

7439932 Lithium Lithium

### 25 Pollutant code Description Pollutant type a Pollutant Category Name

7439954 Magnesium Magnesium

7439987 Molybdenum Molybdenum Compounds

7440097 Potassium Potassium

7440213 Silicon Silicon

7440224 Silver Silver Compounds

7440235 Sodium Sodium

7440246 Strontium Strontium Compounds

7440280 thallium Thallium Compounds

7440315 Tin Tin Compounds

7440326 Titanium Titanium Compounds

7440393 Barium Barium Compounds

7440428 Boron Boron

7440508 Copper Copper Compounds

7440622 Vanadium Vanadium Compounds

7440655 Yttrium Yttrium Compounds

7440666 Zinc Zinc Compounds

7440699 Bismuth Bismuth

7440702 Calcium Calcium

74840 Ethane Ethane

74931 Methyl Mercaptan TRS

74953 Dibromomethane [methylene bromide] Dibromomethane [methylene bromide]

75081 Ethyl Mercaptan TRS

75183 Dimethyl Sulfide TRS

75274 Bromodichloromethane Bromodichloromethane

75332 Isopropyl Mercaptan TRS

75661 Tert

- Butyl Mercaptan TRS

75694 Trichlorofluoromethane Trichlorofluoromethane (CFC

- 11)

76222 Camphor Camphor

7664939 Sulfuric Acid Sulfuric Acid

7782414 Fluorine Fluorine

78842 Isobutyraldehyde Isobutyraldehyde

79925 Camphene Camphene

80568 Alpha

- Pinene Alpha

- Pinene

84662 Diethyl Phthalate Diethyl Phthalate

85687 Butyl Benzyl Phthalate Butyl Benzyl Phthalate

872559 2

- Ethyl Thiophene 2

- Ethyl Thiophene

88755 2

- Nitrophenol 2

- Nitrophenol

95578 Chlorophenol [2

- Chlorophenol] Chlorophenol [2

- Chlorophenol]

95636 1,2,4

- Trimethylbenzene 1,2,4

- Trimethylbenzene

98555 Alpha

- Terpineol Alpha

- Terpineol

99854 gamma

- Terpinene gamma

- Terpinene

99876 p

- Cymene p

- Cymene

### 26 Pollutant code Description Pollutant type a Pollutant Category Name

CFC Chlorofluorocarbons CFC

Nitrate Nitrate Compounds Nitrate Compounds

TRS Total Reduced Sulfur OTH TRS

TRS (H2S) Total Reduced Sulfur (as H2S) OTH TRS

TRS as S Total Reduced Sulfur (as S) OTH TRS

a. All are non

- HAP pollutants.

### 27 Table 3 . Chromium Speciation Approach for October 2011 Pulp and Paper Risk Modeling

SCCs included in October 2011 modeling Cr +6

m ultiplier for

October 2011

m odeling 2 Comment on u se of Cr +6 m ultiplier for October 2011

m odeling SCC Short n ame 1 Process

MACT

c ode

10200201 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized

Coal: Wet Bottom 0107

- 1 0.12

10200202 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized Coal: Dry Bottom 0107

- 1 0.12

10200203 Ext Comb /Industrial /Bitum/Subbit Coal /Cyclone

Furnace 0107

- 1 0.12

10200204 Ext Comb /Industrial /Bitum/Subbit Coal /Spreader

Stoker 0107

- 1 0.12

10200212 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized Coal: Dry Bottom (Tangential) 0107

- 1 0.12

10200218 Ext Comb /Industrial /Bituminous Coal /Atmospheric Fluidized Bed Combustion: Circulating Bed 0107

- 1 0.12

10200219 Ext Comb /Industrial /Bituminous Coal /Cogeneration 0107

- 1 0.12

10200222 Ext Comb /Industrial /Subbituminous Coal /Pulverized Coal: Dry Bottom 0107

- 1 0.12

10200224 Ext Comb /Industrial /Subbituminous Coal /Spreader

Stoker 0107

- 1 0.12

10200401 Ext Comb /Industrial /Residual Oil /Grade 6 Oil 0107

- 3 0.18

10200501 Ext Comb /Industrial /Distillate Oil /Grades 1 and 2 Oil 0107

- 3 0.18

10200502 Ext Comb /Industrial /Distillate Oil /10

- 100 Million

Btu/hr ** 0107

- 3 0.18

10200601 Ext Comb /Industrial /Natural Gas /> 100 Million

Btu/hr 0107

- 2 0.04

10200602 Ext Comb /Industrial /Natural Gas /10

- 100 Million

Btu/hr 0107

- 2 0.04

10200603 Ext Comb /Industrial /Natural Gas /< 10 Million Btu/hr 0107

- 2 0.04

10200604 Ext Comb /Industrial /Natural Gas /Cogeneration 0107

- 2 0.04

10200799 Ext Comb /Industrial /Process Gas /Other: Specify in

Comments 0107

- 2 0.04

10200804 Ext Comb /Industrial /Petroleum Coke /Cogeneration 0107

- 1 0.12

10200901 Ext Comb /Industrial /Bark

- fired Boiler 0107

- 4 0.56

### 28 SCCs included in October 2011 modeling Cr +6

m ultiplier for

October 2011

m odeling 2 Comment on u se of Cr +6 m ultiplier for October 2011

m odeling SCC Short n ame 1 Process

MACT

c ode

10200902 Ext Comb /Industrial /Wood/Bark

- fired Boiler 0107

- 4 0.56

10200903 Ext Comb /Industrial /Wood

- fired Boiler

- Wet Wood (:=20% moisture) 0107

- 4 0.56

10200907 Ext Comb /Industrial /Wood

- fired Boiler

- Wet Wood (:=20% moisture) 0107

- 4 0.56

10200911 Ext Comb /Industrial /Wood/Bark Waste /Stoker boilers

** 0107

- 4 0.56

10200912 Ext Comb /Industrial /Wood/Bark Waste /Fluidized bed

combustion boiler 0107

- 4 0.56

10201002 Ext Comb /Industrial /LPG /Propane 0107

- 2 0.04

10201201 Ext Comb /Industrial /Solid Waste /Specify Waste

Material in Comments 0107

- 4 0.56

10201202 Ext Comb /Industrial /Solid Waste /Refuse Derived Fuel 0107

- 4 0.56

10500106 Ext Comb /Space Heater /Industrial /Natural Gas 0107

- 2 0.04

20200102 Int Comb /Industrial /Distillate Oil (Diesel) /Reciprocating 0105

- 2 0.18

20200203 Int Comb /Industrial /Natural Gas /Turbine: Cogeneration 0105

- 1 0.04

20200401 Int Comb /Industrial /Large Bore Engine /Diesel 0105

- 2 0.18

20201702 Int Comb /Industrial /Gasoline /Reciprocating Engine 0105

- 2 0.18 Cr +6 multiplier assumed to be same as for fuel oil.

20300101 Int Comb /Comm

- Inst /Distillate Oil (Diesel) /Reciprocating 0105

- 2 0.18

30700104 Sulfate (Kraft) Pulping /Recovery Furnace/Direct Contact Evaporator 1626

- 2 0.171 NCASI TB 973 (Table 4.22) contains Cr +6 and total Cr emissions test data for one DCE recovery furnace.

Total Cr emissions were non

- detect (3.5E

- 05 lb/ton BLS). Using 1/2 of the detection limit for total Cr, Cr +6
was approximately 17.1% of the total Cr.

30700105 Sulfa te (Kraft) Pulping /Smelt Dissolving Tank 1626

- 2 0.148 NCASI TB 973 (Table 4.29) contains Cr +6 and total Cr

emissions test data for one SDT. Total Cr emissions

were 2.3E

- 05 lb/ton BLS, and Cr+6 emissions were

3.40E

- 06 lb/ton BLS, yielding a Cr +6 factor of 14.8%.

### 29 SCCs included in October 2011 modeling Cr +6

m ultiplier for

October 2011

m odeling 2 Comment on u se of Cr +6 m ultiplier for October 2011

m odeling SCC Short n ame 1 Process

MACT

c ode

30700106 Sulfate (Kraft) Pulping /Lime Kiln 1626

- 2 0.032 NCASI TB 973 (Table 4.27) contains Cr +6 and total Cr

emissions test data for three lime kilns with wet

scrubbers. The data were unable to be interpreted for

two of the kilns because the Cr +6 data were non

- detect, with detection limits higher than the corresponding

detect data for the total Cr tests. A Cr +6 to total Cr ratio

of 3.2% was observed for the third kiln.

30700110 Sulfate (Kraft) Pulping /Recovery Furnace/Indirect

Co ntact Evaporator 1626

- 2 0.229 NCASI TB 973 (Table 4.24) contains Cr +6 and total Cr emissions test data for three NDCE recovery furnaces. The average Cr +6 to total Cr ratio was 22.9% (ranging from 1.5% to 50.0%).

30700127 Sulfate (Kraft) Pulping / Non

- condensible Gases

Incinerator 1626

- 1 0.04 NCGs are process gases. Most Cr +6 factors for process gas are 0.04, including for SCC 30790014 (Industrial Processes, Pulp and Paper and Wood Products, Fuel Fired Equipment, Process Gas: Incinerators). Only 6

records affected. Use Cr +6 = 0.04, same as "priority 2"

default for SCC 30790014.

30700222 Sulfite Pulping /Recovery System: NH 3 1626

- 2 0.34

30700353 Soda / lime kiln 1626

- 2 0.032 Assume same multiplier as kraft lime kiln.

30700401 Paper and Paperboard Manufacture / Paper Machine / Pulp Dryer 1626

- 1 0.04 This SCC represents paper machines (like SCC 30700405). Chromium from paper machines is likely attributed to combustion of natural gas in direct

- fired dryers on the machine. Therefore, the Cr +6 factor

should be 0.04 if we follow the convention for combustion of natural gas.

30900500 Fabricated Metal /Welding /General 1626

- 3 1 Cr +6 multiplier based on multiplier for SIC 2631 (priority 3)

. 3 1 record. MACT code questionable.

40201301 Paper Coating /Coating Operation 0711 0 Chromium is not expected from this process (not a combustion process). Only 1 record (coater)

- likely anomaly. Use 0 for Cr +6 factor.

1 The marker “**” is part of the SCC description and indicates notes related to SCC assignment (not relevant for this table).

2 The balance is considered Chromium III (Cr +3 ). For example, if the Cr +6 multiplier is 0.04, then 4% of total chromium is considered to be Chromium VI, and

96% is considered to be Chromium III. Unless otherwise sp ecified in the comments column, the Cr +6 multiplier is derived from EPA’s priority 1 list of NEI

default Cr + 6 multipliers. 3

### 30 3 NEI Chromium p rofile priorities:

Priority Hierarchy

1 Use MACT code speciation profiles. NOTE: For pulp and paper (MACT codes 1626

- 1, 1626

- 2, 1626

- 3), use MACT code and SCC.

2 Use SCC speciation profiles if MACT code speciation profiles are unavailable. NOTE: Nonroad SCCs are truncated in table.

3 Use SIC code speciation profiles if MACT code and SCC speciation profiles are unavailable.

4 Use default speciation multiplier of 0.34 if MACT code, SCC, and SIC code speciation profiles are unavailable.

### 31 Table 4 . POM Speciation Approach for October 2011 Pulp and Paper Risk Modeling Equipment Pollutant code POM species POM multipliers Paper machines 85018 Phenanthrene 0.612

86737 Fluorene 0.101

129000 Pyrene 0.18

206440 Fluoranthene 0.108

Gas

- fired paper machine dryers 85018 Phenanthrene 0.328

86737 Fluorene 0.054

91576 2

- Methylnaphthalene 0.463

129000 Pyrene 0.097

206440 Fluoranthene 0.058

Oil

- fired paper machine dryers 91576 2

- Methylnaphthalene 1

### 32 Table 5 . CDD/CDF Speciation Approach

Congener CDD/CDF mean emission factors for

recovery furnaces (ng/kg feed) Congener profile TEF Annual emissions, tpy

NEI33135

-- 1

-- 1

-- 1 NEI33135

-- 1

-- 2

-- 2 NEI41252

-- 1

-- 2

— 2

Total CDD/CDF from file 1.27339E

- 07 1.15774E

- 06 7.99E

- 07

2,3,7,8

- TCDD 0 0.00% 1 0 0 0

1,2,3,7,8

- PeCDD 0 0.00% 1 0 0 0

1,2,3,4,7,8

- HxCDD 0.001 0.03% 0.1 3.75963E

- 12 3.41817E

- 11 2.35902E

- 11

1,2,3,6,7,8

- HxCDD 0.003 0.09% 0.1 1.13E

- 11 1.03E

- 10 7.07706E

- 11

1,2,3,7,8,9

- HxCDD 0.006 0.18% 0.1 2.26E

- 11 2.05E

- 10 1.41541E

- 10

1,2,3,4,6,7,8

- HpCDD 0.108 3.19% 0.01 4.06E

- 11 3.69E

- 10 2.54774E

- 10

OCDD 1.033 30.50% 0.0003 1.17E

- 11 1.06E

- 10 7.3106E

- 11

2,3,7,8

- TCDF 0.04 1.18% 0.1 1.50E

- 10 1.37E

- 09 9.43608E

- 10

1,2,3,7,8

- PeCDF 0.03 0.89% 0.03 3.38367E

- 11 3.07636E

- 10 2.12312E

- 10

2,3,4,7,8

- PeCDF 0.033 0.97% 0.3 3.72204E

- 10 3.38399E

- 09 2.33543E

- 09

1,2,3,4,7,8

- HxCDF 0.007 0.21% 0.1 2.63174E

- 11 2.39272E

- 10 1.65131E

- 10

1,2,3,6,7,8

- HxCDF 0.012 0.35% 0.1 4.51156E

- 11 4.10181E

- 10 2.83082E

- 10

1,2,3,7,8,9

- HxCDF 0.005 0.15% 0.1 1.87982E

- 11 1.70909E

- 10 1.17951E

- 10

2,3,4,6,7,8

- HxCDF 0.01 0.30% 0.1 3.75963E

- 11 3.41817E

- 10 2.35902E

- 10

1,2,3,4,6,7,8

- HpCDF 0.024 0.71% 0.01 9.02E

- 12 8.20E

- 11 5.66165E

- 11

1,2,3,4,7,8,9

- HpCDF 0 0.00% 0.01 0.00E+00 0.00E+00 0

OCDF 0.113 3.34% 0.0003 1.27E

- 12 1.16E

- 11 7.99708E

- 12

Total TEQ 7.84E

- 10 7.13E

- 09 4.92E

- 09

Other TCDD 0.106 3.13%

Other PeCDD 0.013 0.38%

Other HxCDD 0.094 2.78%
Other HpCDD 0.144 4.25%

Other TCDF 1.23 36.32%

Other PeCDF 0.307 9.06%

### 33 Congener CDD/CDF mean emission factors for

recovery furnaces (ng/kg feed) Congener profile TEF Annual emissions, tpy

NEI33135

-- 1

-- 1

-- 1 NEI33135

-- 1

-- 2

-- 2 NEI41252

-- 1

-- 2

— 2

Other HxCDF 0.068 2.01%
Other HpCDF 0 0.00%

Total CDD/CDF 3.39 100.00%

Source : U.S. Environmental Protection Agency. An Inventory of Sources and Environmental Releases of Dioxin

- like Compounds in the United States for the Years 1987, 1995, and 2000

. EPA/600/P

- 03/002F. November 2006. Page 5

- 44. Table 5

- 13: CDD/CDF mean emission factors (ng/kg feed) for black liquor recovery boilers; Column 4: NCASI (1995) (6 facilities); Nondetect set to zero.

### 34 Table 6 A. Emission Process Groups Assigned for Each SCC in the October 2011 Risk Modeling

SCC SCC Short Name SCC EI Sector Emission Process Group

10200201 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized Coal:

Wet Bottom Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200202 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized Coal: Dry Bottom Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200203 Ext Comb /Industrial /Bitum/Subbit Coal /Cyclone Furnace Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200204 Ext Comb /Industrial /Bitum/Subbit Coal /Spreader Stoker Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200205 Ext Comb /Industrial /Bitum/Subbit Coal /Overfeed Stoker Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200206 Ext Comb /Industrial /Bitum/Subbit Coal /Underfeed Stoker Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200212 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized Coal: Dry Bottom (Tangential) Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200218 E xt Comb /Industrial /Bituminous Coal /Atmospheric Fluidized Bed Combustion: Circulating Bed Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200219 Ext Comb /Industrial /Bituminous Coal /Cogeneration Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200222 Ext Comb /Industrial /Subbituminous Coal /Pulverized Coal: Dry Bottom Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200224 Ext Comb /Industrial /Subbituminous Coal /Spreader Stoker Fuel Comb

- Industrial Boilers, ICEs

- Coal ICI Boiler/PH

10200401 Ext Comb /Industrial /Residual Oil /Grade 6 Oil Fuel Comb

- Industrial Boilers, ICEs

- Oil ICI Boiler/PH

10200402 Ext Comb /Industrial /Residual Oil /10

- 100 Million Btu/hr ** Fuel Comb

- Industrial Boilers, ICEs

- Oil ICI Boiler/PH

10200404 Ext Comb /Industrial /Residual Oil /Grade 5 Oil Fuel Comb

- Industrial Boilers, ICEs

- Oil ICI Boiler/PH

10200405 Ext Comb /Industrial /Residual Oil /Cogeneration Fuel Comb

- Industrial Boilers, ICEs

- Oil ICI Boiler/PH

10200501 Ext Comb /Industrial /Distillate Oil /Grades 1 and 2 Oil Fuel Comb

- Industrial Boilers, ICEs

- Oil ICI Boiler/PH

10200502 Ext Comb /Industrial /Distillate Oil /10

- 100 Million Btu/hr ** Fuel Comb

- Industrial Boilers, ICEs

- Oil ICI Boiler/PH

10200503 Ext Comb /Industrial /Distillate Oil /< 10 Million Btu/hr ** Fuel Comb

- Industrial Boilers, ICEs

- Oil ICI Boiler/PH

10200601 Ext Comb /Industrial /Natural Gas /> 100 Million Btu/hr Fuel Comb

- Industrial Boilers, ICEs

- Natural

Gas ICI Boiler/PH

10200602 E xt Comb /Industrial /Natural Gas /10

- 100 Million Btu/hr Fuel Comb

- Industrial Boilers, ICEs

- Natural

Gas ICI Boiler/PH

10200603 Ext Comb /Industrial /Natural Gas /< 10 Million Btu/hr Fuel Comb

- Industrial Boilers, ICEs

- Natural

Gas ICI Boiler/PH

10200604 Ext Comb /Industrial /Natural Gas /Cogeneration Fuel Comb

- Industrial Boilers, ICEs

- Natural

Gas ICI Boiler/PH

### 35 SCC SCC Short Name SCC EI Sector Emission Process Group

10200799 Ext Comb /Industrial /Process Gas /Other: Specify in

Comments Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

10200802 Ext Comb /Industrial /Petroleum Coke /All Boiler Sizes Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

10200804 Ext Comb /Industrial /Petroleum Coke /Cogeneration Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

10200901 Ext Comb /Industrial /Bark

- fired Boiler Fuel Comb

- Industrial Boilers, ICEs

- Biomass ICI Boiler/PH

10200902 Ext Comb /Industrial /Wood/Bark

- fired Boiler Fuel Comb

- Industrial Boilers, ICEs

- Biomass ICI Boiler/PH

10200903 Ext Comb /Industrial /Wood

- fired Boiler

- Wet Wood (:=20% moisture) Fuel Comb

- Industrial Boilers, ICEs

- Biomass ICI Boiler/PH

10200904 Ext Comb /Industrial /Bark

- fired Boiler (< 50,000 Lb Steam)

** Fuel Comb

- Industrial Boilers, ICEs

- Biomass ICI Boiler/PH

10200905 Ext Comb /Industrial /Wood/Bark

- fired Boiler (< 50,000 Lb Steam) ** Fuel Comb

- Industrial Boilers, ICEs

- Biomass ICI Boiler/PH

10200907 Ext Comb /Industrial /Wood/Bark Waste /Wood Cogeneration Fuel Comb

- Industrial Boilers, ICEs

- Biomass ICI Boiler/PH

1020091 1 Ext Comb /Industrial /Wood/Bark Waste /Stoker boilers ** Fuel Comb

- Industrial Boilers, ICEs

- Biomass ICI Boiler/PH

10200912 Ext Comb /Industrial /Wood/Bark Waste /Fluidized bed

combustion boiler Fuel Comb

- Industrial Boilers, ICEs

- Biomass ICI Boiler/PH

10201002 Ext Comb /Industrial /LPG /Propane Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

10201201 Ext Comb /Industrial /Solid Waste /Specify Waste Material in

Comments Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

10201202 Ext Comb /Industrial /Solid Waste /Refuse Derived Fuel Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

10201301 Ext Comb /Industrial /Liquid Waste /Specify Waste Material

in Comments Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

10201302 Ext Comb /Industrial /Liquid Waste /Waste Oil Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

10201401 Ext Comb /Industrial /CO Boiler /Natural Gas Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

10500106 Ext Comb /Space Heater /Industrial /Natural Gas Fuel Comb

- Industrial Boilers, ICEs

- Natural

Gas ICI Boiler/PH

10500110 Ext Comb /Space Heater /Industrial /Liquified Petroleum Gas (LPG) Fuel Comb

- Industrial Boilers, ICEs

- Other ICI Boiler/PH

20200101 Int Comb /Industrial /Distillate Oil (Diesel) /Turbine Fuel Comb

- Industrial Boilers, ICEs

- Oil Turbine

20200102 Int Comb /Industrial /Distillate Oil (Diesel) /Reciprocating Fuel Comb

- Industrial Boilers, ICEs

- Oil RICE

20200201 Int Comb /Industrial /Natural Gas /Turbine Fuel Comb

- Industrial Boilers, ICEs

- Natural

Gas Turbine

20200202 Int Comb /Industrial /Natural Gas /Reciprocating Fuel Comb

- Industrial Boilers, ICEs

- Natural

Gas RICE

### 36 SCC SCC Short Name SCC EI Sector Emission Process Group

20200203 Int Comb /Industrial /Natural Gas /Turbine: Cogeneration Fuel Comb

- Industrial Boilers, ICEs

- Natural

Gas Turbine

20200209 Int Comb /Industrial /Natural Gas /Turbine: Exhaust Fuel Comb

- Industrial Boilers, ICEs

- Natural

Gas Turbine

20200301 Int Comb /Industrial /Gasoline /Reciprocating Engine Fuel Comb

- Industrial Boilers, ICEs

- Other RICE

20200401 Int Comb /Industrial /Large Bore Engine /Diesel Fuel Comb

- Industrial Boilers, ICEs

- Oil RICE

20201001 Int Comb /Industrial /Liquified Petroleum Gas /Propane: Reciprocating Fuel Comb

- Industrial Boilers, ICEs

- Other RICE

20201702 Int Comb /Industrial /Gasoline /Reciprocating Engine Fuel Comb

- Industrial Boilers, ICEs

- Other RICE

20300101 Int Comb /Comm

- Inst /Distillate Oil (Diesel) /Reciprocating Fuel Comb

- Comm/Institutional

- Oil RICE

30101814 Chem Manuf /Plastics Production /Extruder Industrial Processes

- Chemical Manuf Chem Manuf

30101815 Chem Manuf /Plastics Production /Pellet Silo Industrial Processes

- Storage and Transfer Chem Manuf

30187009 Chem Manuf /Inorganic Chem Stor (Fixed Roof Tanks) /Sulfuric Acid: Breathing Loss Industrial Processes

- Storage and Transfer Chem Manuf

30187097 Chem Manuf /Inorganic Chem Stor (Fixed Roof Tanks) /Specify Liquid: Breathing Loss Industrial Processes

- Storage and Transfer Chem Manuf

30190099 Chem Manuf /Fuel Fired Equipment /Specify in Comments

Field Industrial Processes

- Chemical Manuf Chem Manuf

30501009 Coal Mining, Cleaning & Material Handling /Raw Coal Storage Industrial Processes

- Mining Coal Handling

30501010 Coal Mining, Cleaning & Material Handling /Crushing Industrial Processes

- Mining Coal Handling

30501011 Coal Mining, Cleaning & Material Handling /Coal Transfer Industrial Processes

- Mining Coal Handling

30501015 Coal Mining, Cleaning & Material Handling /L oading Industrial Processes

- Mining Coal Handling

30501031 Coal Mining, Cleaning & Material Handling /Scrapers: Travel

Mode Industrial Processes

- Mining Coal Handling

30501040 Coal Mining, Cleaning & Material Handling /Truck Unloading: End Dump

- Coal Industrial Processes

- Mining Coal Handling

30501043 Coal Mining, Cleaning & Material Handling /Open Storage

Pile: Coal Industrial Processes

- Mining Coal Handling

30501049 Coal Mining, Cleaning & Material Handling /Wind Erosion: Exposed Areas Industrial Processes

- Mining Coal Handling

30501099 Coal Mining, Cleaning & Material Handling /Other Not

Classified Industrial Processes

- Mining Coal Handling

30502099 Stone Quarrying & Processing /Not Classified ** Industrial Processes

- NEC Mineral Handling

### 37 SCC SCC Short Name SCC EI Sector Emission Process Group

30510199 Mineral Prods /Bulk Materials Conveyors /Other Not

Classified Industrial Processes

- Storage and Transfer Mineral Handling

30510203 Mineral Prods /Bulk Materials Storage Bins /Coal Industrial Processes

- Storage and Transfer Mineral Handling

30510204 Mineral Prods /Bulk Materials Storage Bins /Coke Industrial Processes

- Storage and Transfer Mineral Handling

30510205 Mineral Prods /Bulk Materials Storage Bins /Limestone Industrial Processes

- Storage and Transfer Mineral Handling

30510298 Mineral Prods /Bulk Materials Storage Bins /Mineral: Specify

in Comments Industrial Processes

- Storage and Transfer Mineral Handling

30510299 Mineral Prods /Bulk Materials Storage Bins /Other Not

Classified Industrial Processes

- Storage and Transfer Mineral Handling

30510303 Mineral Prods /Bulk Materials Open Stockpiles /Coal Industrial Processes

- Storage and Transfer Mineral Handling

30510499 Mineral Prods /Bulk Materials Unloading Op /Other Not

Classified Industrial Processes

- Storage and Transf er Mineral Handling

30531008 Coal Mining, Cleaning & Material Handling /Unloading Industrial Processes

- Mining Coal Handling

30700101 Sulfate (Kraft) Pulping /Digester System

- Continuous or

Batch Industrial Processes

- Pulp & Paper Kraft Pulping: Digester LVHC

30700102 Sulfate (Kraft) Pulping /Brown Stock Washing System Industrial Processes

- Pulp & Paper Kraft Pulping: Washing

30700103 Sulfate (Kraft) Pulping /Multi

- effect Evaporators and

Concentrators Industrial Processes

- Pulp & Paper Kraft Pulping: Evaporator LVHC

30700104 Sulfate (Kraft) Pulping /Recovery Furnace/Direct Contact Evaporator Industrial Processes

- Pulp & Paper DCE

30700105 Sulfate (Kraft) Pulping /Smelt Dissolving Tank Industrial Processes

- Pulp & Paper SDT (Kraft)

30700106 Sulfate (Kraft) Pulping /Lime Kiln Industrial Processes

- Pulp & Paper Lime Kiln

30700107 Sulfate (Kraft) Pulping /Turpentine Condenser Industrial Processes

- Pulp & Paper Kraft Pulping: Turpentine LVHC

30700108 Sulfate (Kraft) Pulping /Fluid Bed Calciner Industrial Processes

- Pulp & Paper Calciner

30700109 Sulfate (Kraft) Pulping /Black Liquor Oxidation System Industrial Processes

- Pulp & Paper BLO

30700110 Sulfate (Kraft) Pulping /Recovery Furnace/Indirect Contact Evaporator Industrial Processes

- Pulp & Paper NDCE

30700112 Sulfate (Kraft) Pulping /Lime Mud Washers Industrial Processes

- Pulp & Paper Causticizing: Lime Mud

30700113 Sulfate (Kraft) Pulping /Lime Mud Filter System Industrial Processes

- Pulp & Paper Causticizing: Lime Mud

30700114 Sulfate (Kraft) Pulping /Bleach Plant Industrial Processes

- Pulp & Paper Bleaching: Kraft

30700115 Sulfate (Kraft) Pulping /Chlorine Dioxide Generator Industrial Processes

- Pulp & Paper Bleaching: ClO2 Generator

30700116 Sulfate (Kraft) Pulping /Turpentine Loading Facilities Industrial Processes

- Pulp & Paper Kraft Pulping: Turpentine LVHC

### 38 SCC SCC Short Name SCC EI Sector Emission Process Group

30700117 Sulfate (Kraft) Pulping /Venting of condensate stripper off

gases Industrial Processes

- Pulp & Paper Condensate Stripper

30700119 Sulfate (Kraft) Pulping /Salt Cake Mix Tank (Boiler Ash Handling) Industrial Processes

- Pulp & Paper Salt Cake Tank

30700120 Sulfate (Kraft) Pulping /Stock Washing/Screening Industrial Processes

- Pulp & Paper Kraft Stock Washing

30700121 Sulfate (Kraft) Pulping /Wastewater: General Industrial Processes

- Pulp & Paper Wastewater (Kraft)

30700122 Sulfate (Kraft) Pulping /Causticizing: Miscellaneous Industrial Processes

- Pulp & Paper Causticizing: Misc

30700123 Sulfate (Kraft) Pulping / Lime Slaker Vent Industrial Processes

- Pulp & Paper Causticizing: Slaker

30700124 Sulfate (Kraft) Pulping / Black Liquor Storage Tanks Industrial Processes

- Pulp & Paper Kraft Pulping: BL Tanks HVLC

30700125 Sulfate (Kraft) Pulping / Low Volume High Concentration Syste m Venting of Non

- condensible Gases Industrial Processes

- Pulp & Paper Kraft Pulping: LVHC

30700126 Sulfate (Kraft) Pulping / High Volume Low Concentration System Venting of Non

- condensible Gases Industrial Processes

- Pulp & Paper Kraft Pulping: HVLC

30700127 Sulfate (Kraft) Pulping / Non

- condensible Gases Incinerator Industrial Processes

- Pulp & Paper Kraft Pulping: Incinerator

30700128 Sulfate (Kraft) Pulping / Total Reduced Sulfur Thermal

Oxidizer Industrial Processes

- Pulp & Paper Kraft Pulping: Incinerator

30700129 Sulfate (Kraft) Pulping / Enclosed secondary wastewater
treatment system vents Industrial Processes

- Pulp & Paper Wastewater (Kraft)

30700130 Sulfate (Kraft) Pulping / Decker system Industrial Processes

- Pulp & Paper Kraft Pulping: Decker

30700131 Sulfate (Kraft) Pulping / Knotter / Deknotter System Industrial Processes

- Pulp & Paper Kraft Pulping: Knotter

30700132 Sulfate (Kraft) Pulping / Green Liquor Processing Industrial Processes

- Pulp & Paper Causticizing: Green Li quor

30700133 Sulfate (Kraft) Pulping / White Liquor Processing Industrial Processes

- Pulp & Paper Causticizing: White Liquor

30700134 Sulfate (Kraft) Pulping / Oxygen delignification system Industrial Processes

- Pulp & Paper Kraft Pulping: O2 Delig HVLC

30700135 Sulfate (Kraft) Pulping / Pulp Storage

- Bleached and

Unbleached Industrial Processes

- Pulp & Paper Kraft Pulp Storage

30700136 Sulfate (Kraft) Pulping / Tall Oil System Industrial Processes

- Pulp & Paper Tall Oil

30700199 Sulfate (Kraft) Pulping /Other Not Classified Industrial Processes

- Pulp & Paper Kraft Misc

30700211 Sulfite Pulping /Digester/Blow Pit/Dump Tank: Calcium Industrial Processes

- Pulp & Paper Sulfite Pulping (Ca)

30700214 Sulfite Pulping /Digester/Blow Pit/Dump Tank: NH3 with Process Change Industrial Processes

- Pulp & Paper Sulfite Pulping (NH3)

30700216 Sulfite Pulping / Bleach Plant Industrial Processes

- Pulp & Paper Bleaching: Sulfite

30700222 Sulfite Pulping /Recovery System: NH3 Industrial Processes

- Pulp & Paper Sulfite Recovery

### 39 SCC SCC Short Name SCC EI Sector Emission Process Group

30700224 Sulfite Pulping /Wastewater: General Industrial Processes

- Pulp & Paper Wastewater (Sulfite)

30700231 Sulfite Pulping /Acid Plant: NH3 Industrial Processes

- Pulp & Paper Sulfite Pulping (NH3)

30700233 Sulfite Pulping /Acid Plant: Ca Industrial Processes

- Pulp & Paper Sulfite Pulping (Ca)

30700234 Sulfite Pulping /Knotters/Washers/Screens/etc. Industrial Processes

- Pulp & Paper Sulfite Pulping

30700299 Sulfite Pulping /See Comment ** Industrial Processes

- Pulp & Paper Sulfite Pulping

30700301 Neutral Sulfite Semichemical Pulping /Digester/Blow Pit/Dump Tank Industrial Processes

- Pulp & Paper NSSC Pulping

30700305 Neutral Sulfite Semichemical Pulping / Liquor Combustion Industrial Processes

- Pulp & Paper NSSC Recovery

30700306 Neutral Sulfite Semichemical Pulping /Wastewater: General Industrial Processes

- Pulp & Paper Wastewater (NSSC)

30700307 Neutral Sulfite Semichemical Pulping / Pulp washing system Industrial Processes

- Pulp & Paper NSSC Pulping

30700308 Neutral Sulfite Semichemical Pulping / Pulp storage

tanks/stock chests Industrial Processes

- Pulp & Paper NSSC Pulping

30700309 Neutral Sulfite Semichemical Pulping / Liquor storage tanks Industrial Processes

- Pulp & Paper NSSC Misc

30700320 Semi

- chemical (non

- sulfur) / Pulp washing system Industrial Processes

- Pulp & Paper Semichem Pulping

30700321 Semi

- chemical (non

- sulfur) / Pulp storage tanks/stock chests Industrial Processes

- Pulp & Paper Semichem Pulping

30700322 Semi

- chemical (non

- sulfur) / Liquor making system Industrial Processes

- Pulp & Paper Semichem Pulping

30700323 Semi

- chemical (non

- sulfur) / Liquor evaporator system Industrial Processes

- Pulp & Paper Semichem Pulping

30700324 Semi

- chemical (non

- sulfur) / Liquor combustion Industrial Processes

- Pulp & Paper Semichem Recovery

30700325 Semi

- chemical (non

- sulfur) / Liquor storage tanks Industrial Processes

- Pulp & Paper Semichem Pulping

30700326 Semi

- chemical (non

- sulfur) / Digesters/refiners/blow

tanks/blow heat recovery system Industrial Processes

- Pulp & Paper Semichem Pulping

30700327 Semi

- chemical (non

- sulfur) / Smelt tank Industrial Processes

- Pulp & Paper SDT (Semichem)

30700328 Semi

- chemical (non

- sulfur) /Wastewater: General Industrial Processes

- Pulp & Paper Wastewater (Semichem)

30700329 Semi

- chemical (non

- sulfur) /Other Not Classified Industrial Processes

- Pulp & Paper Semichem Misc

30700351 Soda / recovery furnace Industrial Processes

- Pulp & Paper Soda Recovery

30700352 Soda / smelt tank Industrial Processes

- Pulp & Paper SDT (Soda)

30700353 Soda / lime kiln Industrial Processes

- Pulp & Paper Lime Kiln

30700354 Soda /Other Not Classified Industrial Processes

- Pulp & Paper Soda Misc

30700399 Neutral Sulfite Semichemical Pulping /Other Not Classified Industrial Processes

- Pulp & Paper NSSC Misc

### 40 SCC SCC Short Name SCC EI Sector Emission Process Group

30700401 Paper and Paperboard Manufacture / Paper Machine / Pulp Dryer Industrial Processes

- Pulp & Paper Papermaking

30700403 Pulpboard Manuf /Raw Material Storage and Handling Industrial Processes

- Storage and Transfer Paper Misc

30700404 Secondary Fiber Pulping /Stock Preparation and Repulper Industrial Processes

- Pulp & Paper Paper Stock Prep

30700407 Paper and Paperboard Manufacture /Coating Operations: On

Machine Industrial Processes

- Pulp & Paper Coating: On Machine

30700408 Secondary Fiber Pulping / Deinking operations Industrial Processes

- Pulp & Paper Paper Stock Prep

30700409 Paper and Paperboard Manufacture / Coating Operations: Off

Machine Industrial Processes

- Pu lp & Paper Coating: Off Machine

30700410 Secondary Fiber Pulping / Bleaching / Brightening / Decoloring Industrial Processes

- Pulp & Paper Bleaching: Sec Fiber

30700499 Paper and Paperboard Manuf /See Comment ** Industrial Processes

- Pulp & Paper Paper Misc

30700501 Wood Pressure Treating /Creosote Industrial Processes

- Pulp & Paper Wood Handling

30700801 Sawmill Operations /Log Debarking Industrial Processes

- Pulp & Paper Wood Handling

30700820 Sawmill Operations /Chipping and Screening Industrial Processes

- Pulp & Paper Wood Handling

30701199 Paper Coating & Glazing /Extrusion Coating Line with

Solvent Free Resin/Wax Industrial Processes

- Pulp & Paper Paper Coating

30701201 Misc Paper Processes /Cyclones Industrial Processes

- Pulp & Paper Paper Misc

30701202 Miscellaneous Paper Processes /Wastewater: General Industrial Processes

- Pulp & Paper Wastewater (General)

30701220 Mechanical Pulping Ops / Thermomechanical Process and

Chemi

- thermomechanical Pulping Industrial Processes

- Pulp & Paper Mechanical Pulping

30701221 Mechanical Pulping Ops / Pressurized Groundwood / Stone

Groundwood Industrial Processes

- Pulp & Paper Mechanical Pulping

30701222 Mechanical Pulping Ops/Bleaching / Brightening Industrial Processes

- Pulp & Paper Bleaching: Mechanical

30701223 Mechanical and Recycle Paper Processes /Wastewater:

General Industrial Processes

- Pulp & Paper Wastewater (Mechanical)

30701224 Mechanical Pulping Ops / Refiner Pulping Industrial Processes

- Pulp & Paper Mechanical Pulping

30701399 Misc Paper Products /Other Not Classified Industrial Processes

- Pulp & Paper Paper Misc

30704001 Pulp&Paper&Wood /Bulk Handling&Stor: Wood

- Bark /Storage Bins Industrial Processes

- Storage and Transfer Wood Handling

30704002 Pulp&Paper &Wood /Bulk Handling&Stor: Wood

- Bark /Stockpiles Industrial Processes

- Storage and Transfer Wood Handling

30704003 Pulp&Paper&Wood /Bulk Handling&Stor: Wood

- Bark /Unloading Industrial Processes

- Storage and Transfer Wood Handling

### 41 SCC SCC Short Name SCC EI Sector Emission Process Group

30704004 Pulp&Paper& Wood /Bulk Handling&Stor: Wood

- Bark /Loading Industrial Processes

- Storage and Transfer Wood Handling

30704005 Pulp&Paper&Wood /Bulk Handling&Stor: Wood

- Bark /Conveyors Industrial Processes

- Storage and Transfer Wood Handling

30788801 Pulp&Paper&Wood /Fugitive Emissions /Specify in

Comments Field Industrial Processes

- Pulp & Paper Fugitive Emissions

- Misc

30799998 Pulp&Paper&Wood /Other Not Classified Industrial Processes

- Pulp & Paper Paper Misc

30900500 Fabricated Metal /Welding /General Industrial Processes

- NEC Welding

31299999 Misc Machinery Manuf /Other Not Classified Industrial Processes

- NEC Misc Machinery Manuf

38500101 Industrial Process Cooling Tower /Mechanical Draft Industrial Processes

- NEC Cooling Tower

38500110 Industrial Process Cooling Tower /Other Not Specified Industrial Processes

- NEC Cooling Tower

39090003 Fuel Storage

- Fixed Roof Tanks /Distillate Oil (No. 2): Breathing Loss Industrial Processes

- Storage and Transfer Petrol Storage

- Transfer

39999999 Misc Manuf / Indus Processes /Other Not Classified Industrial Processes

- NEC Manuf Misc

40100251 Degreasing : Stoddard (Petroleum Solvent): General Degreasing Units Solvent

- Degreasing Solvent Use

40100299 Degreasing : Other Not Classified: Open

- top Va por Degreasing Solvent

- Degreasing Solvent Use

40100301 Solvent Evap /Cold Solvent Cleaning/Stripping /Methanol Solvent

- Degreasing Solvent Use

40100303 Solvent Evap /Cold Solvent Cleaning/Stripping /Stoddard (Petroleum Solvent) Solvent

- Degreasing Solvent Use

40100307 Solvent Evap /Cold Solvent Cleaning/Stripping /Isopropyl

Alcohol Solvent

- Degreasing Solvent Use

40100399 Solvent Evap /Cold Solvent Cleaning/Stripping /Other Not

Classified Solvent

- Degreasing Solvent Use

40188898 Solvent Evap /Fugitive Emissions /Specify in Comments Field Solvent

- Degreasing Solvent Use

40200101 Surface Coating Application

- General /Paint: Solvent

- base Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

40200601 Surface Coating Application

- General /Primer Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

40200701 Surface Coating Application

- General /Adhesive Application Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

40200710 Surface Coating Application

- General /Adhesive: General Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

### 42 SCC SCC Short Name SCC EI Sector Emission Process Group

40200801 Surface Coating Oven

- General /General Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

40200901 Surface Coating /Thinning Solvents

- General /General: Specify in Comments Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

40201001 Surface Coating Oven Heater /Natural Gas Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

40201301 Paper Coating /Coating Operation Solvent

- Industrial Surface Coating & Solvent

Use Paper Coating

40201303 Paper Coating /Coating Mixing Solvent

- Industrial Surface Coating & Solvent

Use Paper Coating

40201304 Paper Coating /Coating Storage Industrial Processes

- Storage and Transfer Paper Coating

40201305 Paper Coating /Equipment Cleanup Solvent

- Industrial Surface Coating & Solvent

Use Paper Coating

40201399 Paper Coating /Other Not Classified Solvent

- Industrial Surface Coating & Solvent

Use Paper Coating

40202605 Surface Coating /Steel Drums /Equipment Cleanup Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

40204435 Fabric Coating, Transfer Coating /Lamination: Laminating

Device Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

40288824 Surface Coating /Fugitive Emissions /Clean

- up Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

40299998 Surface Coating /Miscellaneous /Specify in Comments Field Solvent

- Industrial Surface Coating & Solvent

Use Coating Misc

4040 0102 Petrol Prod Stor

- Bulk Terminals /Gasoline RVP 10: Breathing Loss (67000 BBL)

- Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage

- Transfer

40400104 Petrol Prod Stor

- Bulk Terminals /Gasoline RVP 13: Breathing Loss (250000 BBL)

- Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage

- Transfer

40400107 Petrol Prod Stor

- Bulk Terminals /Gasoline RVP 13: Working Loss (Diam Independent)

- Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage

- Transfer

40400108 Petrol Prod Stor

- Bulk Terminals /Gasoline RVP 10: Working Loss (Diam Independent)

- Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage

- Transfer

40400121 Petrol Prod Stor

- Bulk Terminals /Diesel Fuel: Standing Loss (Diam Independent)

- Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage

- Tran sfer

40400199 Petrol Prod Stor

- Bulk Terminals /See Comment ** Bulk Gasoline Terminals Petrol Storage

- Transfer

40400316 Oil&Gas Field Stor&Workg Tanks /Fixed Roof Tank, Diesel, working+breathing+flashing losses Industrial Processes

- Storage and Transfer Petrol Storage

- Transfer

### 43 SCC SCC Short Name SCC EI Sector Emission Process Group

40400403 Petrol Prod Stor

- Underground Tanks /Gasoline RVP 10: Breathing Loss Bulk Gasoline Terminals Petrol Storage

- Transfer

40400404 Petrol Prod Stor

- Underground Tanks /Gasoline RVP 10: Working Loss Bulk Gasoline Terminals Petrol Storage

- Transfer

40400413 Petrol Prod Stor

- Underground Tanks /Distillate Fuel #2: Breathing Loss Bulk Gasoline Terminals Petrol Storage

- Transfer

40500201 Print

- Publish /General /Letter Press: 2751 Solvent

- Graphic Arts Print

- Publish

40500215 Print

- Publish /General /Letterpress: Cleaning Solution Solvent

- Graphic Arts Print

- Publish

40500301 Print

- Publish /General /Printing: Flexographic Solvent

- Graphic Arts Print

- Publish

40600401 Petrol Trans & Marketg /Filling Vehicle Gas Tanks

- Stage II /Vapor Loss w/o Controls Gas Stations Petrol Storage

- Transfer

40688801 Petrol Trans & Marketg /Fugitive Emissions /Specify in

Comments Field Industrial Processes

- Storage and Transfer Petrol Storage

- Transfer

40700814 Organic Chem Storage

- Fixed Roof Tanks

- Isopropyl Alcohol: Working Loss Industrial Processes

- Storage and Transfer Storage Tanks

- Alcohol

40700815 Organic Chem Storage

- Fixed Roof Tanks

- Methyl Alcohol: Breathing Loss Industrial Processes

- Storage and Transfer Storage Tanks

- Metha nol

40700816 Organic Chem Storage

- Fixed Roof Tanks

- Methyl Alcohol: Working Loss Industrial Processes

- Storage and Transfer Storage Tanks

- Methanol

40701698 Organic Chem Storage

- Fixed Roof Tanks

- Specify Alkane: Working Loss Industrial Processes

- Storage and Transfer Storage Tanks

- Organic

40708098 Organic Chem Storage

- Fixed Roof Tanks

- Specify Nitro Compound in Comments: Working Loss Industrial Processes

- Storage and Transfer Storage Tanks

- Organic

40799997 Organic Chem Storage

- Miscellaneous /Specify in Comments Industrial Processes

- Storage and Transfer Storage Tanks

- Organic

49099998 Solvent Evap /Misc Volatile Organic Evaporation /Identify the

Process and Solvent in Comments Solvent

- Industrial Surface Coating & Solvent

Us e Solvent Use

50300101 Waste Disp

- Indus /Incineration /Multiple Chamber Waste Disposal Waste Disposal

- Incineration

50300602 Waste Disp

- Indus /Landfill Dump /Liquid Waste Disposal Waste Disposal Landfill

50300801 Waste Disp

- Indus /Treatment, Storage, Disp /Surface Impoundment: Fugitive Emissions Waste Disposal Waste Disposal

- Fugitive

Emissions

50300810 Waste Disp

- Indus /Treatment, Storage, Disp /Waste Piles: Fugitive Emissions Waste Disposal Waste Disposal

- Fugitive

Emissions

50300899 Waste Disp

- I ndus /Treatment, Storage, Disp /General: Fugitive Emissions Waste Disposal Landfill

50390006 Waste Disp

- Indus /Auxillary Fuel

- No Emissions /Natural Gas Waste Disposal Waste Disposal

- Incineration

### 44 Table 6 B

. Allowable and Acute Multipliers for Emission Process Groups for the October

2011 Pulp and Paper Risk Modeling

Emission process group Process MACT

code Allowable multiplier Acute multiplier Bleaching: ClO 2 

### Generator 1626

- 1 1.4 for chlorinated HAP; 1 for

chloroform or non

- chlorinated HAP 1.4

Bleaching: Kraft 1626

- 1 1.4 for chlorinated HAP; 1 for

chloroform or non

- chlorinated HAP 1.4

Bleaching: Mechanical 1626

- 1 1.4 for chlorinated HAP; 1 for

chloroform or non

- chlorinated HAP 1.4

Bleaching: Sec Fiber 1626

- 1 1.4 for chlorinated HAP; 1 for

chloroform or non

- chlorinated HAP 1.4

Bleaching: Sulfite 1626

- 1 1.4 for chlorinated HAP; 1 for

chloroform or non

- chlorinated HAP 1.4

BLO 1626

- 2

Calciner 1626

- 2
Causticizing: Green Liquor 1626

- 1 1 1.5
Causticizing: Lime Mud 1626

- 1 1 1.5
Causticizing: Misc 1626

- 1 1 1.5
Causticizing: Slaker 1626

- 1 1 1.5
Causticizing: White Liquor 1626

- 1 1 1.5

Chem Manuf 1 

### 1626

- 1

, - 3
Coal Handling 1626

- 3
Coating Misc 0711
Coating: Off Machine 0711
Coating: On Machine 0711
Condensate Stripper 1626

- 1 1.6 1.2
Cooling Tower 1626

- 3

DCE 1626

- 2
Fugitive Emissions

- Misc 1626

- 3

ICI Boiler/PH 0107

- 1,

- 2,

- 3,

- 4

Kraft Misc 1626

- 1 1 1.2
Kraft Pulp Storage 1626

- 1 1 1.2
Kraft Pulping: BL Tanks

HVLC 1626

- 1 1 1.2

Kraft Pulping: Decker 1626

- 1 1 1.2
Kraft Pulping: Digester

LVHC 1626

- 1 1 1.2

Kraft Pulping: Evaporator

LVHC 1626

- 1 1 1.2

Kraft Pulping: HVLC 1626

- 1 1 1.2
Kraft Pulping: Incinerator 1626

- 1 1 1.2

### 45 Emission process group Process MACT

code Allowable multiplier Acute multiplier Kraft Pulping: Knotter 1626

- 1 1 1.2

Kraft Pulping: LVHC 1626

- 1 1 1.2
Kraft Pulping: O 2 

### Delig

HVLC 1626

- 1 1 1.2

Kraft Pulping: Turpentine

LVHC 1626

- 1 1 1.2

Kraft Pulping: Washing 1626

- 1 1 1.2
Kraft Stock Washing 1626

- 1 1 1.2

Landfill 1626

- 3

Lime Kiln 1626

- 2

Manuf Misc 2 

### 1626

- 1,

- 3

, 0107

- 4 1 1.4

Mechanical Pulping 1626

- 1 1 3.1
Mineral Handling 1626

- 3
Misc Machinery Manuf 1626

- 3

NDCE 1626

- 2

NSSC Misc 1626

- 1 1 1
NSSC Pulping 1626

- 1 1 1
NSSC Recovery 1626

- 2
Paper Coating 0711
Paper Misc 2 

### 1626

- 1

, - 3 1 1.6
Paper Stock Prep 1626

- 1 1 1.6
Papermaking 1626

- 1 1 1.6
Petrol Storage

- Transfer 0601, 0602

Print

- Publish 0714

RICE 0105

- 1,

- 2

Salt Cake Tank 1626

- 2

SDT (Kraft) 1626

- 2

SDT (Semichem) 1626

- 2

SDT (Soda) 1626

- 2

Semichem Misc 1626

- 1 1 1

Semichem Pulping 1626

- 1 1 1
Semichem Recovery 1626

- 2

Soda Misc 1626

- 1 1 1.2
Soda Recovery 1626

- 2

Solvent Use 1 

### 1626

- 1

, - 3
Storage Tanks

- Alcohol 1626

- 1 1 1.6
Storage Tanks

- Methanol 1626

- 1 1 1.6
Storage Tanks

– Organic 1 

### 0602, 1626

- 1

Sulfite Pulping 1626

- 1 2.7 1.6

### 46 Emission process group Process MACT

code Allowable multiplier Acute multiplier Sulfite Pulping (Ca) 1626

- 1 2.7 1.6
Sulfite Pulping (NH 3 

### ) 1626

- 1 1.6 1.6
Sulfite Recovery 1626

- 2

Tall Oil 1626

- 1 1 1.2

Turbine 0108

- 1,

- 2
Waste Disposal

- Fugitive

Emissions 1626

- 3

Waste Disposal

– Incineration 1626

- 3

Wastewater (General) 1626

- 1 1 2

Wastewater (Kraft) 1626

- 1 1.6 2

Wastewater (Mechanical) 1626

- 1 1 2

Wastewater (NSSC) 1626

- 1 1 2

Wastewater (Semichem) 1626

- 1 1 2

Wastewater (Sulfite) 1626

- 1 1 2
Welding 1626

- 3
Wood Handling 1626

- 3

1 

### No multipliers needed for these 1626

- 1 sources ; only criteria air pollutant emissi ons

. 2 

### Multipliers apply to 1626

- 1 sources only.

### 47 Table 7

. Allowable Multipliers by Emission Source Type for Risk Modeling for Subpart S (MACT Code 1626

- 1)

Emission source type Subpart S performance level (percent reduction) Reported actual performance level (percent reduction) 1 

### October 2011

a llowable multiplier 2


### Bleaching

Chlorinated HAP 99% 99. 3 % 1.4

Chloroform work practice NA 1

Non

- chlorinated HAP NA NA 1 Kraft pulping

Performance limit 98% 99% 2 Equipment standards NA NA 1 3


### Kraft pulping process condensates 4 

### 92% 95% 1.6

Soda or semichemical pulping

Performance limit 98% 99% 2 Equipment standards NA NA 1 3


### Sulfite pulping

Ca or Na sulfite 92% 9 7 % 2.7

NH 3 

### or Mg sulfite 87% 92 % 1.6

Uncontrolled emission units 5 

### NA NA 1

1 These reported values for percent reduction are based on survey data received.

2 The allowable multiplier is calculated as follows (using kraft pulpin g vent gases as an example and canceling out uncontrolled tpy): Allowable multiplier = Allowable = (1

– subpart S limit % reduction) = (1

– 0.9 8 ) = 0.02 = 2

Actual (1

– actual % red uction ) (1

– 0.99) 0.01

3 The multiplier for equipment standards is recommended for use in the October 2011 risk modeling because most kraft, soda, and semichemical mills are demonstrating compliance with s ubpart S by meeting one of the three equipment st andards for kraft, soda, and semichemical pulping

. 4 The allowable multiplier would apply for emissions from kraft pulping process condensates

, which would typically either be treated by steam stripping or biological treatment (i.e., wastewater treatment). This value is recommended for application to kraft pulping wastewater for the October 2011 risk modeling

. 5 For example, causticizing, mechanical pulping, papermaking, storage tanks, non

- kraft wastewater , and miscellaneous manufacturing.

### 48 Table 8

. A cute Multipliers by Emission Source Type for Risk Modeling for Subpart S (MACT Code 1626

- 1)

Emission source type Median peak

- to

- mean ratio (acute multiplier) Notes Bleaching 1.4 Causticizing 1.5 Kraft p ulping 1.2 Mechanical pulping 3.1 Miscellaneous manufacturing 1.4 No data; assigned based on median of other values Neutral sulfite semichemical p ulping 1.0

Non

- sulfur s emichem ical p ulping 1.0 Papermaking 1.6 Industry value used ; data confirmed by our analysis Soda p ulping 1.2 Storage t anks 1.6 Sulfite p ulping 1.6

Wastewater 2.0 Industry value used; data confirmed by our analysis

### Appendix A

Checklist to R eview NEI Update S preadsheets

### A

- 1 Checklist to Review NEI Update Spreadsheets

Name of reviewer

_______ Date of review

_______ NEI ID

_______ RTI ID (in tracking spreadsheet)

_______ Mill type (in tracking spreadsheet; check all that apply) □ kraf t □ sod a □ sulfit e □ semi

chemica l □ mechanical (TMP, RMP,

SGW, PGW ) □ non

woo d □ secondary fiber (incl

. de

inking) □ NA (paper only ) Is Facility Name consistent between Facility tab and Inventory tab? □ ye s □ n o

________________________________________________________________ Is there any information in the wrong column? □ ye s □ n o

________________________________________________________________ Are the equipment (SCCs) what we expect to see for this mill type? □ ye s □ n o

________________________________________________________________
Kraft: 30700101

- 199, and 401

________________________________________________________________ Soda: 30700101

- 199, 351

- 354, and 401

Sulfite: 30700214

- 299, and 401

________________________________________________________________ Semichemical: 30700301

- 329, and 401

Mechanical: 30701220

- 224, and 401

________________________________________________________________ Secondary fiber: 30700401

- 410 and 30701202 Paper only: 30700401

- 410, and 30701202 Are the pollutants what we expect to see? □ ye s □ n o

________________________________________________________________ E.g., acetaldehyde, cresols, formaldehyde, methanol, phenol, styrene, toluene, xylenes,

TRS, VOC ________________________________________________________________

Are there any missing stack or fugitive parameters? □ ye s □ n o

________________________________________________________________ Are there any missing latitude/longitude data? □ y e s □ n o

________________________________________________________________ Any other observations? Any recommended changes?

________________________________________________________________

________________________________________________________________

### A

- 2 List of Subpart S Equipment to Check in Review of NEI Update Spreadsheets 1



### Pulping process Subpart S e quipment SCC

Kraft Bleaching system 30700114, 30700115 Causticizing system 30700112, 30700113, 30700122, 30700123, 30700132, 30700133 Decker system 30700130 Digester system 30700101
Evaporator system 30700103 HVLC system 30700126
Knotter system 30700131 LVHC system 30700125

Incinerator/thermal oxidizer 30700127, 30700128 Oxygen delignification system 30700134 Papermaking system 30700401

Process wastewater treatment system 30700121 Pulp washing system 30700102 Screen system 30700120 Tall oil reactor system 30700136 Turpentine recovery system 30700107, 30700116 Weak liquor storage tank 30700124

Soda Bleaching system 30700114, 30700115, 30700354 LVHC system 30700125, 30700354 Papermaking system 30700401, 30700354

Process wastewater treatment system 30700121, 30700354 Pulp washing system 30700102, 30700354
Semichemical (NSSC) LVHC system 30700301, 30700302 Papermaking system 30700401

Process wastewater treatment system 30700306 Pulp washing system 30700307

### A

- 3 Pulping process Subpart S e quipment SCC Semichemical (non

- sulfur) LVHC system 30700323, 30700326 Papermaking system 30700401

Process wastewater treatment system 30700328 Pulp washing system 30700320

Sulfite Acid condensate storage tank 30700231 Bleaching system 30700216 Digester system 30700214
Evaporator system 30700222 Papermaking system 30700401

Process wastewater treatment system 30700224 Pulp washing system 30700234 Strong liquor storage tank 30700234 Weak liquor storage tank 30700234

Mechanical Bleaching system 30701222 Papermaking system 30700401

Process wastewater treatment system 30701223 Pulping system 30701220, 30701221, 30701224 Secondary fiber Bleaching system 30700410 Papermaking system 30700401

Process wastewater treatment system 30701202 Repulping system 30700404 None (paper production only) Bleaching system 30700410 Papermaking system 30700401

Process wastewater treatment system 30701202

1 

### HVLC = high

- volume, low

- concentration; LVHC = low

- volume, high

- concentration; NSSC = neutral sulfite semichemical.

### Appendix B

Parameters for Modeling of Paper Machine Emissions

### B

- 1 

# ncasi

P.O. Box 13318, Research Triangle Park, NC 27709

- 3318 919

- 941

- 6400



# MEMORANDUM

DATE: January 18, 2011

TO: Bill Schrock, EPA

FROM: John Pinkerton

SUBJECT: Parameters for Modeling of Paper Machine Emissions

During the January 13 working session, there was some discussion of how paper machine emissions were being

modeled. Apparently if a paper machine source is coded in the NEI as a fugitive source, the default parameters for a fugitive source are assigned unless building dimensions (height, length, width, orientation) have been entered. The default par ameters are a height of 10 feet, temperature of 72°F, exit velocity of 0.0003 ft/sec, and a diameter of

0.003 ft. These fugitive default parameters are not reflective of paper machine emission sources.

Where paper machine sources are coded as stack emissi on points, the EPA default parameters for SCC 30700401 (paper machine/pulp dryer), 30700405 (paper/board forming), and 30700407 (coating operations: on

- machine) are

as follows:

SCC Type Height Temperature Exit Velocity Flow Rate

30700401 Stack 56 ft 50oC 19.4 ft/sec 13,560 acfm

30700405 Stack 62 ft 60oC 34.3 ft/sec 32,220 acfm

30700407 Stack 45 ft 78oC 33.7 ft/sec 233,000 acfm

Paper machines are typically located in a long, rectangular building with a flat roof. There are multiple roof vents

above the paper machine, many of which have fans to exhaust the building air. The number and type of vents, and vent gas characteristics (flow rate, exit velocity, gas temperature, moisture level), vary considerably from machine to

machine. The total amount of air e xhausted from a paper machine building is not necessarily related to the production capacity of the paper machine. Thus it is difficult to develop a ‘default’ set of parameters representing a ‘typical’ paper machine.

NCASI has performed sampling at a numb er of paper machines over the last 20 years. The following averages are based on information contained in various NCASI reports and company

- provided permitting materials. Obviously values for any given paper machine could depart significantly from these av erages. Number of vents on wet end (with bulk of exhaust gas)

– 6 Number of vents on dry end (with bulk of exhaust gas)

– 6 Vent height

– 70 ft above grade Average vent gas exit velocity

– 30 ft/sec Average vent gas flow rate

– 30,000 dscfm Wet end vent gas parameters

– 40oC, 5% moisture (33650 acfm/vent) Dry end vent gas parameters

– 65oC, 12% moisture (36470 acfm/vent) 50% of emissions of gaseous organic hazardous air pollutants are from wet end, 50% from dry end Building length

– 200 m

Bui lding width

– 30 m

### B

- 2 These averages for dry end sources do not include vents associated with on

- machine coaters that have direct

- fired dryers, nor do they include vents for direct

- fired Yankee dryers (both of which have relatively high flow rates and
tempera tures).

Where detailed paper machine source characteristics are not contained in the NEI files, the above average values represent reasonable choices for dispersion modeling purposes. It is suggested that EPA replace any NEI default parameters for SCCs 3 0700401 and 30700405 with these averages, and model them as stack sources.

Further, in Part I of the upcoming survey, we suggest the instructions indicate that the above values will be used for
all paper machines in future EPA modeling and risk assessment s unless the mill is able to provide more detailed site

specific parameters.

### Appendix C

Engineering Estimates for Fugitive Length and Width Parameters for Pulp and Paper
Fugitive Emission Sources

### C

- 1 Engineering Estimates for Fugitive Length and Width Parameters for Pulp and Paper Fugitive Emission Sources

SCC Short Name Notes 1 Fugitive Length

(ft) Fugitive

Width

(ft) Fugitive Angle (deg)

10200503 Ext Comb /Industrial /Distillate Oil /< 10 Million Btu/hr ** Based on parameters for similar SCCs. 20 20 0

20200301 Int Comb /Industrial /Gasoline /Reciprocating Engine Based on parameters for similar SCCs. 20 20 0

30187009 Chem Manuf /Inorganic Chem Stor (Fixed Roof Tanks) /Sulfuric Acid: Breathing Loss Assumed. 8 8 0

30187097 Chem Manuf /Inorganic Chem Stor (Fixed Roof Tanks) /Specify Liquid: Breathing Loss Assumed. 8 8 0

30700101 Sulfate (Kraft) Pulping /Digester System

- Continuous or Batch Digesters are generally the same size regardless of pulping operations. Capacity is generally increased by adding an additional digester, not expanding one's size. 20 20 0

30700102 Sulfate (Kraft) Pulping /Brown Stock Washing System Brownstock washers are usually about the same size. Brownstock washing capacity is generally increased with the addition of a new washer(s). Washing capacity is relative to the bleaching capacity (via simple mass balance). Some backup pulp is stored before bleaching to prevent downtime. These estimates are per washer. 8 18 0

30700103 Sulfate (Kraft) Pulping /Multi

- effect Evaporators and Concentrators 110 110 0

30700106 Sulfate (Kraft) Pulping /Lime Kiln 300 20 0

30700107 Sulfate (Kraft) Pulping /Turpentine Condenser Basic reaction vessel. These are per vessel. 5 5 0

30700110 Sulfate (Kraft) Pulping /Recovery Furnace/Indirect Contact Evaporator 50 50 0

30700111 Sulfate (Kraft) Pulping /Filtrate Tanks These are smaller stationary storage tanks. These are per tank. 8 8 0

30700112 Sulfate (Kraft) Pulping /Lime Mud Washers These are almost the same as a lime mud filter in capacity and design. These are per washer. 10 10 0

30700113 Sulfate (Kraft) Pulping /Lime Mud Filter System Lime mud filters are relative to the size of the recovery operation. These are usually similar in size to a washer. These estimates are per filter. 10 18 0

30700114 Sulfate (Kraft) Pulping /Bleach Plant Modern bleach plants could be confined to roughly a 2

- acre footprint. This includes all additional equipment. 300 300 0

30700115 Sulfate (Kraft) Pulping /Chlorine Dioxide Generator This estimate is based on one reaction vessel, not the entire processing

site. 15 25 0

30700116 Sulfate (Kraft) Pulping /Turpentine Loading Facilities This is a covered pad or building for trucks or tankers to receive turpentine byproducts. 8 40 0

30700117 Sulfate (Kraft) Pulping /Venting of condensate stripper off

- gases This is a smaller a stack. These are per stack. 2 2 0

30700118 Sulfate (Kraft) Pulping /Liquor Clarifiers Liquor clarifiers are relative to the size of the pulping operation. These are usually similar to a tank/holding vessel. These estimates are per

clarifier. 25 25 0

30700119 Sulfate (Kraft) Pulping /Salt Cake Mix Tank (Boiler Ash Handling) 25 25 0

30700120 Sulfate (Kraft) Pulping /Stock Washing/Screening Same basic idea as brownstock washers. Washers are generally the same in a pulping operation. 8 18 0

30700121 Sulfate (Kraft) Pulping /Wastewater: General Used the fugitive parameters from section III of this memo. 829 166 0

30700122 Sulfate (Kraft) Pulping /Causticizing: Miscellaneous Assumptions were made based on the size of one causticizing vessel. These estimates are per causticizer. 20 20 0

30700123 Sulfate (Kraft) Pulping / Lime Slaker Vent 2 2 0

### C

- 2 SCC Short Name Notes 1 Fugitive Length

(ft) Fugitive

Width

(ft) Fugitive Angle (deg)

30700124 Sulfate (Kraft) Pulping / Black Liquor Storage Tanks These are usually large holding tanks. I would estimate that smaller units are typically 100k

- 250k gallons. Most tanks today are 1 million gallon capacity. These estimates are per tank. 35 35 0

30700125 Sulfate (Kraft) Pulping / Low Volume High Concentration System Venting of Non

- condensible Gases These are similar to pressure relief valves. These are on a per vent basis (multiple vents are likely). 1 1 0

30700126 Sulfate (Kraft) Pulping / High Volume Low Concentration System Venting of Non

- condensible Gases These are similar to pressure relief valves. These are on a per vent basis (multiple vents are likely). 1 1 0

30700127 Sulfate (Kraft) Pulping / Non

- condensible Gases Incinerator These are a basic incinerator vessel with a stack. These are per stack. 3 3 0

30700130 Sulfate (Kraft) Pulping / Decker system Same basic idea as brownstock washers. Washers are generally the same in a pulping operation. The only difference

-- instead of letting gravity separate the pulp and liquid, the pulp is pressed for dewatering. These are per decker. 8 18 0

30700131 Sulfate (Kraft) Pulping / Knotter / Deknotter System 3 3 0

30700132 Sulfate (Kraft) Pulping / Green Liquor Processing Green liquor processing is similar to liquor clarifiers and lime mud

washers. 10 10 0

30700133 Sulfate (Kraft) Pulping / White Liquor Processing Based on descriptions from the SCC descriptions tab, these items appear

to be individual units, not an entire white liquor processing site. This is why the values may appear small. These estimates are per unit. 10 20 0

30700134 Sulfate (Kraft) Pulping / Oxygen delignification system These are pulping reaction vessels before the bleaching operations. These are tall cylinders. These are per O 2 delig vessel. 20 20 0

30700135 Sulfate (Kraft) Pulping / Pulp Storage

- Bleached and Unbleached These are just large storage tanks. These are per storage tank. 30 30 0

30700136 Sulfate (Kraft) Pulping / Tall Oil System Large holding vessel. Usually just a tall tank sitting on its end. These are per vessel. 10 10 0

30700199 Sulfate (Kraft) Pulping /Other Not Classified No indications were available to aid in developing length and width

estimates. Used assumed values. 20 20 0

30700211 Sulfite Pulping /Digester/Blow Pit/Dump Tank: Calcium The one SCC record without length and width values was listed as a

drain. 1 1 0

30700212 Sulfite Pulping /Digester/Blow Pit/Dump Tank: MgO with Recovery System Blow tanks must have the capacity to contain the pulp and the black liquor leaving the digester. These are per blow tank/digester. 20 20 0

30700224 Sulfite Pulping /Wastewater: General Used the fugitive parameters from section III of this memo. 829 166 0

30700299 Sulfite Pulping /See Comment ** These are usually drainage systems that may be found in the floor. These

are based on a 10

- ft section of drainage grate. 10 1 0

30700301 Neutral Sulfite Semichemical Pulping /Digester/Blow Pit/Dump

Tank Blow tanks must have the capacity to contain the pulp and the black liquor leaving the digester. These are per blow tank/digester. 20 20 0

30700306 Neutral Sulfite Semichemical Pulping /Wastewater: General This was assumed to be floor grates. 10 1 0

30700307 Neutral Sulfite Semichemical Pulping / Pulp washing system Same basic idea as brownstock washers. Washers are generally the same in a pulping operation. 8 18 0

30700308 Neutral Sulfite Semichemical Pulping / Pulp storage tanks/stock

chests These are just large storage tanks. These are per storage tank. 30 30 0

30700309 Neutral Sulfite Semichemical Pulping / Liquor storage tanks These are usually large holding tanks. I would estimate that smaller units are typically 100k

- 250k gallons. Most tanks today are 1 million gallon capacity. These estimates are per tank. 35 35 0

30700320 Semi

- chemical (non

- sulfur) / Pulp washing system Same basic idea as brownstock washers. Washers are generally the same in a pulping operation. These are per washer. 8 18 0

30700321 Semi

- chemical (non

- sulfur) / Pulp storage tanks/stock chests 15 15 0

30700322 Semi

- chemical (non

- sulfur) / Liquor making system 10 10 0

### C

- 3 SCC Short Name Notes 1 Fugitive Length

(ft) Fugitive

Width

(ft) Fugitive Angle (deg)

30700325 Semi

- chemical (non

- sulfur) / Liquor storage tanks These are just large storage tanks. These are per storage tank. 30 30 0

30700326 Semi

- chemical (non

- sulfur) / Digesters/refiners/blow tanks/blow heat recovery system Blow tanks must have the capacity to contain the pulp and the black liquor leaving the digester. These are per blow tank/digester. 20 20 0

30700328 Semi

- chemical (non

- sulfur) /Wastewater: General This was assumed to be floor grates. 10 1 0

30700401 Paper and Paperboard Manufacture / Paper Machine / Pulp Dryer 150 60 0

30700403 Pulpboard Manuf /Raw Material Storage and Handling These appear to be tanks. The same parameters as the SCC 407 tanks

were used. 12 20 0

30700404 Secondary Fiber Pulping /Stock Preparation and Repulper Repulpers are generally one size. Again, capacity is increased by adding an additional repulper, not expanding one's size. These are per repulper. 10 10 0

30700407 Paper and Paperboard Manufacture /Coating Operations: On

Machine These are the same width as a paper machine. Lengths vary slightly. 3 20 0

30700408 Secondary Fiber Pulping / Deinking operations Deinking operations are generally one size. Again, capacity is increased by adding an additional deinking vessel, not expanding one's size. These are per vessel. 30 30 0

30700499 Paper and Paperboard Manuf /See Comment ** 35 36 0

30700801 Sawmill Operations /Log Debarking 80 12 0

30700820 Sawmill Operations /Chipping and Screening 20 20 0

30701199 Paper Coating & Glazing /Extrusion Coating Line with Solvent

Free Resin/Wax This was assumed to be an extruder. 8 8 0

30701201 Misc Paper Processes /Cyclones This was assumed to be a set of cyclones. 10 2 0

30701202 Miscellaneous Paper Processes /Wastewater: General Used the fugitive parameters from section III of this memo. 1000 1500 0

30701221 Mechanical Pulping Ops / Pressurized Groundwood / Stone

Groundwood These are heavy

- duty refiners, without dilute pulp slurry, that physically separate fiber. 5 5 0

30701223 Mechanical and Recycle Paper Processes /Wastewater: General This was assumed to be floor grates. 10 1 0

30701224 Mechanical Pulping Ops / Refiner Pulping This was assumed to be a typical refiner foot print. 10 10 0

30701399 Misc Paper Products /Other Not Classified Using the descriptions provided, an estimate was made. This process would occur within some type of building. 50 50 0

30704001 Pulp&Paper&Wood /Bulk Handling&Stor: Wood

- Bark /Storage

Bins 100 100 0

30704002 Pulp&Paper&Wood /Bulk Handling&Stor: Wood

- Bark /Stockpiles 200 200 0

30704003 Pulp&Paper&Wood /Bulk Handling& Stor: Wood

- Bark /Unloading This was assumed to be truck or rail car size. 50 10 0

30704004 Pulp&Paper&Wood /Bulk Handling&Stor: Wood

- Bark /Loading This was assumed to be truck or rail car size. 50 10 0

30704005 Pulp&Paper&Wood /Bulk Handling&Stor: Wood

- Bark /Conveyors This assumption was based on belt style conveyors. 250 5 0

30788801 Pulp&Paper&Wood /Fugitive Emissions /Specify in Comments

Field No indications were available to aid in developing length and width

estimates. Used assumed values. 200 200 0

30799999 Pulp&Paper&Wood /Other Not Classified /See Comment ** Descriptions indicated these were deinking operations. The same values

as SCC 30700408 were used. 10 10 0

39999999 Misc Manuf / Indus Processes /Other Not Classified No indications were available to aid in developing length and width

estimates. Used assumed values. 20 20 0

40700814 Organic Chem Storage

- Fixed Roof Tanks

- Isopropyl Alcohol: Working Loss The averages of actual lengths and widths were used. 12 20 0

40700815 Organic Chem Storage

- Fixed Roof Tanks

- Methyl Alcohol: Breathing Loss These are usually just large polyethylene tanks. These are per tank. 5 5 0

40700816 Organic Chem Storage

- Fixed Roof Tanks

- Methyl Alcohol: Working Loss These are usually just large polyethylene tanks. These are per tank. 5 5 0

40708098 Organic Chem Storage

- Fixed Roof Tanks

- Specify Nitro The averages of actual lengths and widths were used. 12 20 0

### C

- 4 SCC Short Name Notes 1 Fugitive Length

(ft) Fugitive

Width

(ft) Fugitive Angle (deg) Compound in Comments: Working Loss

40799997 Organic Chem Storage

- Miscellaneous /Specify in Comments The averages of actual lengths and widths were used. 12 20 0

49099998 Solvent Evap /Misc Volatile Organic Evaporation /Identify the

Process and Solvent in Comments Used the averages from the other 407 SCC codes. 12 20 0

1 Items were based on a per unit basis. All sizes are based on 1 piece of that type of equipment.

2 For modeling purposes, fugitive parameter s had to be rounded to whole numbers, so for any values less than 0.5 ft (e.g., 0.25 ft), we round ed them up to 1 ft.

### Appendix D

Wastewater Treatment Plant (WWTP) Emissions Variability and Default Areas

### D

- 1 From: Pinkerton, John [mailto:JPinkerton@NCASI.org]

Sent: Thursday, February 17, 2011 4:13 PM

To: Schrock.Bill@epamail.epa.gov

Cc: Bradfield.John@epamail.epa.gov ; Hanks, Katie P.; hirtz.james@epamail.epa.gov ; palma.ted@epamail.epa.gov ; Hunt, Tim; Jain, Ashok (SRC); Emerson, Zack (SRC); Crapo, Ann (SRC); Palumbo, James (Gmail) Subject : Wastewater Treatment Plant (WWTP) Emissions Variability and Default Areas



### Bill,

Attached is a write

- up on variability of WWTP emissions. We believe the effluent loading data and WATER9 sensitivity analysis support a peak

- to

- mean ratio (maximum short

- te rm emission rate to annual average emission rate) of two or less.

We have also gathered some dimensional information for primary clarifiers and aerated stabilization basins (ASBs) for the purpose of setting defaults for dispersion modeling whenever the N EI does not contain values (length, width, orientation angle relative to north) for these wastewater fugitive emission sources. We are trying to get more information on the dimensions of activated sludge treatment systems, since we only have information on three of these at present.

1

. Primary clarifiers. The most common shape for a primary clarifier is circular. The average

diameter for clarifiers at 25 mills for which NCASI has information was 190 ft. In WATER9 modeling, NCASI uses a default value of 200 ft if a site

- specific diameter is not available.

Since HEM

- 3 does not accept circular area sources, Jim Hirtz suggested that the length and width for a circular source be set such that the area of a square source is equal to the area

of the circular source. A circle with a 200 ft diameter would have the same area as a square with sides of 177 ft. It isn’t clear what orientation angle should be specified for the square.

2

. ASBs. When performing WATER9 modeling to estimate emissions of volatile organic compounds f rom an ASB, the ASB is typically divided into zones. Emissions from a zone depend on many factors, but generally the first zone (where the effluent enters the basin and normally has the most surface aeration) has the highest emission rates. For 10 ASBs tha t have recently been modeled, the average size of the first zone is 13.4 acres (1.46 x 10 6 

### ft 2 

### ), and the first zone represented an average of 28% of the total ASB area. Although the first zone could have various shapes, a reasonable assumption would be a l ength to width ratio of 1.5, which would give a length of 1500 ft and width of 1000 ft for a zone with an area of

1.5 x 10 6 

### ft 2 

### . It could be conservatively assumed all ASB emissions come from the first zone if

site

- specific WATER9 modeling has not been con ducted.

3

. Activated sludge treatment (AST) systems. These are generally rectangular concrete basins. The size will depend on effluent flow rates, required treatment efficiency, and necessary retention time. For 3 such systems, the areas ranged from 20,000 to 35,000 ft 2 

### . Length

- to

width ratios ranged from 2 to 8.

It is expected the majority of emissions from most chemical pulp mill wastewater treatment operations will come from the secondary treatment basins (ASB or AST), with relatively little from primary clarifiers and post

- secondary treatment basins.

Give me a call if there are questions.

### D

- 2 Sincerely,

John

John Pinkerton

NCASI National Council for Air and Stream Improvement, Inc.

P.O. Box 13318 Research Triangle Park, NC 27709

- 3318 Telephone: 919

- 941

- 6406

Fax: 919

- 941

- 6401 Deliveries: 4815 Emperor Boulevard, Suite 110, Durham, NC 27703

Contact publications@ncasi.org if you do not want to receive future NCASI communications

### Appendix E

Information Needed t o Calculate Allowable Multipliers for Subpart S Risk Modeling (MACT Code 1626

- 1)

### E

- 1 Information Needed to Calculate Allowable Multipliers for Subpart S Risk Modeling (MACT Code 1626

- 1)

Source limit details Typical source control systems Gaseous organic HAP

standard Standard

format Allowable multiplier

calculation Needed to calculate allowable multiplier Kraft pulping vent

gases : Existing sources:

LVHC system 1 ; knotter or screen (above HAP cutoffs), pulp washing, decker (using contaminated water), and O 2 delignification.

New sources: Same as existing, except applies for all knotters, screens, and deckers plus weak liquor storage tanks. Route through a

c losed vent

collection
system to a
b oiler, lime k iln,

recovery f urnace, or

t hermal o xidizer (1) Reduce total HAP emissions by ≥98 wt%; or Numeric

emission limit (performance limit) Allowable multiplier = (1

- 98% reduction limit ) (1

- actual % reduction) Need actual % reduction from Part I response.

(2) Reduce total HAP

concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O 2 (dry basis); or Numeric

emission limit (concentration limit) Allowable multiplier = Allowable emissions

Actual emissions (NEI)

Allowable emissions = 20 ppmv * MW g/g

- mol * g

mol

- K/0.08206 l

- atm * 1 atm * 1/temp (C+273) * 1000 l

ug/g

- m 3 * 0.028316847 m 3 /ft 3
* g/10 6 ug * lb/453.59237 g *

cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, and flow from Part I response and act ual

emissions from NEI.

U se MW for surrogate pollutant (methanol ) in allowable

calculation.

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600 ° F

and ≥0.75 sec residence time; or Equipment

standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

(4) Use a boiler, LK, or RF in which the HAP gas

stream in introduced with the primary fuel into the flame zone; or Equipment

standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

(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. Equipment

standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

### E

- 2 Source limit details Typical source control systems Gaseous organic HAP

standard Standard

format Allowable multiplier

calculation Needed to calculate allowable multiplier

Soda or semichemical pulping vent gases : Existing sources: LVHC system 1

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

closed vent

collection
system to a
b oiler, lime k iln,

recovery furnace, or

t hermal o xidizer (1) Reduce total HAP emissions by ≥98 wt%; or Numeric

emission limit (performance limit) Allowable multiplier = (1

- 98% reduction limit ) (1

- actual % reduction) Need actual % reduction from Part I response.

(2) Reduce total HAP

concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O 2 (dry basis); or Numeric

emission limit (concentration limit) Allowable multiplier = Allowable emissions Actual emissions (NEI)

Allowable emissions = 20 ppmv * MW g/g

- mol * g

mol

- K/0.08206 l

- atm * 1 atm * 1/temp (C+273) * 1000 l

ug/g

- m 3 * 0.028316847 m 3 /ft 3
* g/10 6 ug * lb/453.59237 g *

cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, and flow from Part I response and actual

emissions from NEI.

U se MW for surrogate pollutant (methanol ) in allowable

calculation.

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

standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

(4) Use a boiler, LK, or RF in which the HAP gas

stream in introduced with the primary fuel into the flame zone; or Equipment

standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

(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. Equipment

standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

### E

- 3 Source limit details Typical source control systems Gaseous organic HAP

standard Standard

format Allowable multiplier

calculation Needed to calculate allowable multiplier Sulfite pulping vent

gases : 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

s crubber or other control

device (emission limits apply to

combined

emissions from vents, control

device wastewater, and

condensates ) (1a) Ca

- or Na

- based : Emit t otal HAP (a s methanol ) ≤0.89 lb/ton ODP, or Numeric

emission limit (production

based limit) Allowable multiplier = Allowable emissions Actual emissions (NEI)

Allowable emissions = 0.89 lb/ton ODP * ton ODP/yr Need actual ton ODP/yr from Part I response and actual emissions

from NEI.

(1b) Ca

- or Na

- based : Reduce total HAP (as methanol) by ≥ 92%; Numeric

emission limit (performance limit) Allowable multiplier = (1

- 92 % reduction limit ) (1

- actual % reduction) Need actual % reduction from Part I response.

(2a) NH 3 - or Mg

- based : Emit t otal HAP (as

methanol ) ≤ 2.2 lb/ton ODP,

or Numeric

emission limit (production

based limit) Allowable multiplier = Allowable emissions Actual emissions (NEI)

Allowable emissions =

2.2 lb/ton ODP * ton ODP/yr Need actual ton ODP/yr from Part I response and actual emissions

from NEI.

(2b) NH 3 - or Mg

- based : Reduce total HAP (as methanol) by ≥87%

. Numeric

emission limit (performance limit) Allowable multiplier = (1

- 87 % reduction limit ) (1

- actual % reduction) Need actual % reduction from Part I response.

New and e xisting bleaching vent gases : Chlorine bleaching
systems,
kraft/sulfite/soda bleaching with any

chlorinated compounds, and mechanical/secondary

fiber/non

- wood bleaching with ClO 2

. Route through a

closed vent

collection
system to a
caustic scrubber

or s imilar d evice (1) Reduce t otal chlorinated HAP (except chloroform)

limit: ≥ 99 wt%, or Numeric

emission limit (performance limit) Allowable multiplier = (1

- 99 % reduction limit ) (1

- actual % reduction) Need actual % reduction from Part I response.

(2) Meet ≤ 10 ppmv of t otal chlorinated HAP (except chloroform) at control

device outlet , or Numeric

emission limit (concentration limit) Allowable multiplier = Allowable emissions Actual emissions (NEI)

Allowable emissions =

1 0 ppmv * MW g/g

- mol * g

mol

- K/0.08206 l

- atm * 1 atm * 1/temp (C+273) * 1000 l

ug/g

- m 3 * 0.028316847 m 3 /ft 3
* g/10 6 ug * lb/453.59237 g *

cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, and flow from Part I response and actual

emissions from NEI.

U se MW for surrogate pollutant (chlorine ) in allowable

calculation.

### E

- 4 Source limit details Typical source control systems Gaseous organic HAP

standard Standard

format Allowable multiplier

calculation Needed to calculate allowable multiplier (3) Meet ≤ 0.002 lb t otal chlorinated HAP (except chloroform)/ton ODP at
control device outlet. Numeric

emission limit (production

based limit) Allowable multiplier = Allowable emissions Actual emissions (NEI)

Allowable emissions =

0.002 lb/ton ODP * ton ODP/yr Need actual ton ODP/yr from Part I response and actual emissions

from NEI.

(4) Work practice for

chloroform

- either meet effluent guidelines or use no hypochlorite or chlorine for bleaching. Work practice

standard As work practice standard,

actual = allowable , so allowable multiplier = 1 --

Kraft pulping process condensates (process liquids) from digester, turpentine
recovery, evaporator,
LV HC system 1 , and

H V L C system 2
(some exceptions) Route through a

c losed vent
collection
systems to pulping equipment (1) Reduce total HAP emissions by ≥98 wt%; or Numeric

emission limit (performance limit) Allowable multiplier = (1

- 98% reduction limit ) (1

- actual % reduction) Need actual % reduction from Part I response.

(2) Reduce total HAP

concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O 2 (dry basis); or Numeric

emission limit (concentration limit) Allowable multiplier = Allowable emissions Actual emissions (NEI)

Allowable emissions = 20 ppmv * MW g/g

- mol * g

mol

- K/0.08206 l

- atm * 1 atm * 1/temp (C+273) * 1000 l

ug/g

- m 3 * 0.028316847 m 3 /ft 3
* g/10 6 ug * lb/453.59237 g *

cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, and flow from Part I response and actual

emissions from NEI.

U se MW for surrogate pollutant (methanol ) in allowable

calculation.

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600 ° F

and ≥0.75 secs residence time; or Equipment

standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

(4) Use a boiler, LK, or RF in which the HAP gas

stream in introduced with the primary fuel into the flame zone; or Equipment

standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

### E

- 5 Source limit details Typical source control systems Gaseous organic HAP

standard Standard

format Allowable multiplier

calculation Needed to calculate allowable multiplier (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. Equipment

standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

Route to biological

treatment/ steam stripp er or other

control device (1) Reduce total HAP ≥ 92
wt%; or Numeric

emission limit (performance limit) Allowable multiplier = (1

- 9 2 % reduction limit ) (1

- actual % reduction) Need actual % reduction from Part I response.

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

emission limit (production

based removal limit) Allowable multiplier = Allowable emissions Actual emissions (NEI)

Allowable emissions =

Uncontrolled emissions (tpy)

– 6.6 lb/ton ODP * ton ODP/yr

* 1 ton/2000 lb Need uncontrolled emissions (not available) and actual emissions

from NEI.

(2b) For mills w ithout bleaching, meet ≤ 210 ppmw total HAP at control device outlet; or Numeric

emission limit (concentration limit) Allowable multiplier = Allowable emissions Actual emissions (NEI)

Allowable emissions = 210 ppmw * MW g/g

- mol * g

mol

- K/0.08206 l

- atm * 1 atm * 1/temp (C+273) * 1000 l

ug/g

- m 3 * 0.028316847 m 3 /ft 3
* g/10 6 ug * lb/453.59237 g *

cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, flow from Part I response and actual emissions

from NEI.

U se MW s for surrogate pollutant s ( acetaldehyde, methanol, MEK

, and propionaldehyde ) in

allowable calculation.

(3a) For mills w ith bleaching, remove ≥ 10.2 lb total HAP/ton ODP, or Numeric

emission limit (production

based removal limit) Allowable multiplier = Allowable emissions

Actual emissions (NEI)

Allowable emissions =

Uncontrolled emissions (tpy)

– Need uncontrolled emissions (not available) and actual emissions

from NEI.

### E

- 6 Source limit details Typical source control systems Gaseous organic HAP

standard Standard

format Allowable multiplier

calculation Needed to calculate allowable multiplier

10.2 lb/ton ODP * ton ODP/yr

* 1 ton/2000 lb (3b) For mills w ith bleaching, meet ≤ 330 ppmw total HAP at control

device outlet. Numeric

emission limit (concentration limit) Allowable multiplier = Allowable emissions Actual emissions (NEI)

Allowable emissions = 330 ppmw * MW g/g

- mol * g

mol

- K/0.08206 l

- atm * 1 atm * 1/temp (C+273) * 1000 l

ug/g

- m 3 * 0.028316847 m 3 /ft 3
* g/10 6 ug * lb/453.59237 g *

cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, flow from Part I response and actual emissions

from NEI.

U se MW s for surrogate pollutant s ( acetaldehyde, methanol, MEK

, and propionaldehyde ) in

allowable calculation.

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. Emissions reductions from
CCA ≥ emissions

reductions achieved through kraft pulping HVLC system standards Emission averaging limit Site

- specific approach N eed site

- specific data.

1 The LVHC system includes digester, turpentine recovery, evaporator, and steam strippers

. 2 The HVLC system includes pulp washing, knotter, screen, decker, O 2 delignification, weak liquor storage tanks

.

### Appendix F

Peak

- to

- Mean HAP Emissions Ratios for Paper Machine Sources

AECOM Technical Services February 15, 2011AECOM Peak-to-Mean Paper Machine HAP Emissions Ratios

Page 1 of 7 

# Peak-to-Mean HAP Emissions Ratios for Paper

Machine Sources

Prepared by David W. Heinold, CCM

AECOM Technical Services, Westford, Massachusetts

on behalf of the American Forest and Paper Association

February 15, 2011

In characterizing acute inhalation risk, the method outlined in EPA’s Risk Assessment and Modeling - Air Toxics Risk Assessment Refer ence Library: Volume 2 - Facility-Specific Assessment (EPA-453-K-04-001B, http://www.epa.gov/ttn/fera/risk_atra_vol2.html ) is to apply

HEM-3 to estimate maximum off-site concentrati ons due to a facility’s emissions. Because

emissions from some sources are more variabl e than others, EPA’s guidance indicates that to provide a conservative estimate of acute exposur e and risk, the upper-limit short-term emissions from all hazardous air pollutant (HAP) sources should be simultaneously modeled. The resultant
maximum 1-hour modeled off-site concentrations are then com pared to acute health effects

benchmarks. In the absence of direct estima tes of maximum hourly emissions EPA’s guidance provides a default peak-to-mean emissions ratio of 10 to all HAP sources at a facility. This means that the annual average emission rates which are used in HEM-3 to es timate cancer risks and chronic hazard indices are all multiplied by te n for the acute risk assessment along with the maximum modeled 1-hour average concentration. Espec ially for many sources at paper mills this is a highly conservative met hod of estimating acute risk because it implies that operating

conditions that result in a 10-fold increase in em issions occur simultaneously for all mill sources

and that these conditions are also coincident with worst-case dispersion meteorology. Given that modeling conducted by EPA has indicated that emissions from paper machines sources may substantially contribute to maximum 1-hour av erage HAP concentrations, an investigation has been undertaken by AF&PA to identify a peak-to-mean emission ratio that is more appropriate for paper machines than the generic factor of 10.

In the absence of direct measurements, it is standard practice for HAP emissions from paper machines sources to be computed by multiplying the air dried ton of finished product (ADTFP) by an emission factor, e.g. those developed by NCASI for various types of paper products. Using emission factors to estimate emissions, inherently assumes that emissions are proportional to the production rate, which is a reasonable assumption based on available sampling data. This implies hourly emission rates are determined by the production rate.

In addition to considering the variability in paper machine emission rates associated with production rate fluctuations, the possibility that emission rates of gaseous organic compounds may vary due to changes in process-related conditions has been considered. It would be desirable to have continuous emission monitoring data or repeated manual stack sampling data to address thisAECOM Peak-to-Mean Paper Machine HAP Emissions Ratios

Page 2 of 7 possibility, but obtaining such data is extremel y difficult because paper machines have multiple vents, and the concent rations of organic compounds of conc ern to acute risks (acetaldehyde, acrolein, formaldehyde) are typically near or below instrumental or manual me thod detection limits in the majority of these vents.

To help evaluate the degree to which paper-machine emissions vary due production rate and other factors NCASI has provided data for a mill that it had in its possession in which methanol sampling was conducted on multiple days on a paper machine to support the mill’s Clean
Condensate Alternative demonstration. In the Cl uster Rule, methanol is considered to be the surrogate for all volatile organic hazardous air pollutants emitted from pulping, bleaching, papermaking and wastewater treatment operations (MACT I sources). Tests were conducted on five days for the 18 paper machine vents. Table 1 pr ovides the results of this testing on this paper

machine.

Table 1. Measurements of Paper Machine Methanol Emissions and Production

Date Production

(tons/hr) Methanol Emission

Rate

(lb/hr) Methanol Emission

Factor

(lb/ton)

09/06/08 35 28.3 0.81

09/10/08 43.5 28.1 0.65

09/12/08 49.9 31.5 0.63

09/18/08 54.8 30.8 0.56

09/20/08 34.8 18.4 0.53

Mean 43.6 27.4 0.64

Peak/Mean 1.26 1.15 1.26

The peak-to-mean production ratios for this machine for the five-day period were similar to those for other machines over much longer periods of time. For this set of measurements, the data indicate that the methanol emissions are highly co rrelated with production (correlation coefficient of 0.73) and the computed emission factors ar e slightly negatively correlated with production (correlation coefficient of -0.36). Thus, the peak-t o-mean ratio for methanol emission rate (1.15) is less than the peak-to-mean ratio for paper machine production rate, indicating that using paper machine production rate to evaluate variability of HAP emissions from paper machines is suitably

conservative.

In relation to production rate, other process-relat ed factors that might affect emission rates are relatively constant – roof vent exhaust gas flow rates, dryer temperatures, pulp characteristics, whitewater recirculation rates, as evidenced by wi th Table 1 which indicates that the variability ofAECOM Peak-to-Mean Paper Machine HAP Emissions Ratios

Page 3 of 7 the methanol emission rate is comparable and some what less than the variability in production rate. There is also no reason to suspect e mission rates from paper machines would be higher during startup or shutdown conditions, and paper ma chine malfunctions, which are extremely rare, require prompt shutdown. Typically, paper machine upsets correspond to lack of production (lowering average production value). Worst case scenario is pulp continues to go to machine, then back in a loop and no paper is being made. Since HAP emissions from paper machines are a function of the water carrying the pulp (HAPs ar e contained in solution), if there is no pulp (water) going to the paper machine, there are no corresponding paper machine emissions.

Paper machines are typically operated at the max imum production possible for that specific grade (unless limited by permit). Given that paper machines typically operate at a steady production rate for up to several days, the daily variability of production rate for a mill throughout a year is

considered a reliable measure of the variability of the hourly producti on rate. As it is common for mills to retain records of daily production, the peak-to-mean HAP emission ratio for each paper machine can be readily computed as the ratio of the maximum daily production rate for the paper machine to its annual production rate.

Several paper companies surveyed their produc tion records and computed the peak-to-mean production ratio for each paper machine for twenty mills over the past three years (2008, 2009 and 2010). The results of this survey are provided in Table 2. Figure 1 shows the variation of the data over the last three years and the distribution of peak-to-mean ratios among all paper machines is provided in Figure 2. The median peak-to-mean rati o is 1.3, the maximum ratio is 2.1 and the 95 th
percent of the ratio values is less than 1.6.

The consistency of these paper machine producti on data and the evidence provided by NCASI in Table 1 that the variability of HAP emissions from paper machines is comparable or less than the variability in the production rate, supports a generic application of a peak-to-mean ratio for paper

machines that is much less than EPA’s default fact or of 10. Based on the variability in daily production rate AF&PA recommends that EPA use a factor of 1.6 as it represents a highly conservative estimate for the peak to mean ra tio for the vast majority of paper machines.AECOM Peak-to-Mean Paper Machine HAP Emissions Ratios

Page 4 of 7 

### Table 2 Daily Peak to Annual Average Paper Machine Production Ratios

Mill Year PM1 PM2 PM3 PM4 PM5

1 2008 1.30 1.31

1 2009 1.39 1.61

1 2010 1.27 1.20

2 2008 1.30 1.28 1.39 2.11

2 2009 1.19 1.32 1.30 1.74

2 2010 1.34 1.26 1.30 1.76

3 2008 1.43 1.41

3 2009 1.55 1.43

3 2010 1.56 1.97

4 2008 1.25

4 2009 1.26

4 2010 1.26

5 2008 1.27

5 2009 1.24

5 2010 1.32

6 2008 1.44 1.31

6 2009 1.37 1.35

6 2010 1.35 1.30

7 2008

7 2009 1.31 1.39 1.49

7 2010 1.96 1.99

8 2008 1.38 1.33 1.28 1.21

8 2009 1.28 1.49 1.31 1.49

8 2010 1.31 1.48 1.30 1.24

9 2008 1.22 1.27

9 2009 1.19 1.29

9 2010 1.16 1.30

10 2008 1.36 1.35 1.42

10 2009 1.41 1.30 1.29AECOM Peak-to-Mean Paper Machine HAP Emissions Ratios

Page 5 of 7 

### Table 2 (cont'd) Daily Peak to Annual Average Paper Machine Production Ratios

10 2010 1.24 1.31 1.27

11 2008 1.29

11 2009 1.31

11 2010 1.24

12 2008 1.28 1.40

12 2009 1.35 1.46

12 2010 1.29 1.32

13 2008 1.16 1.43

13 2009 1.24 NA

13 2010 1.19 1.32

14 2008 1.34 1.28

14 2009 1.32 1.27

14 2010 1.27 1.31

15 2008 1.33 1.47

15 2009 1.21 1.30

15 2010 1.35 1.31

16 2008 NA 1.18 1.19

16 2009 1.21 1.24 1.28

16 2010 1.19 1.24 1.33

17 2008 1.25

17 2009 1.32

17 2010 1.32

18 2008 1.22 1.15

18 2009 1.30 1.23

18 2010 1.26 1.19

19 2008 1.20 1.22

19 2009 1.09 1.08

19 2010 NA NA

20 2008 1.48 1.41 1.28

20 2009 1.55 1.49 1.56

20 2010 1.56 1.40 1.34

Note: NA indicates data not availableAECOM Peak-to-Mean Paper Machine HAP Emissions Ratios

Page 6 of 7 

### Figure 1: Peak

‐ to

‐ Mean Production Ratios for Each YearAECOM Peak-to-Mean Paper Machine HAP Emissions Ratios

Page 7 of 7 

### Figure 2: Distribution of Peak

‐ to

‐ Mean Production Ratios

0.00 0.50 1.00 1.50 2.00 2.50

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

# Cumulative Distribution of Daily

Peak to Annual Average Ratios at 20 Mills

from 2008

‐ 2010

### Appendix G

Peak

- to

- Mean HAP Emissions Ratios for Waste Water Treatment Systems

NCASI February 17, 2011

### G

- 1 

## Peak

- to

- Mean HAP Emissions Ratios for
Waste Water Treatment Systems

NCASI February 17, 2011

EPA‘s most recent dispersion modeling results suggest acrolein, formaldehyde, chloroform and methanol released to the air from a few pulp and paper mill wastewater treatment systems may result in elevated a cute risks of concern. The acute modeling results discussed with industry representatives on January 13, 2011 indicate the mills with elevated acute risks due to wastewater emissions (identified by SCC 30700121, although some coded as ‘miscellaneous’ fugit ive sources may have included wastewater emissions) were kraft mills with aerated stabilization basins (ASBs) for secondary

treatment. It should be noted these ASBs were all modeled as point sources rather than

area sources. Modeling them as area sources w ould significantly lower predicted concentrations at most off

- site receptors.

The hourly emission rates used in the modeling were derived from the NEI emission inventory database, which contained a number for the total annual emissions. This

number was divided by 8760 and then multiplied by 10, a standard default factor used by EPA to estimate a peak hourly rate that might occur sometime during the year. EPA has acknowledged the factor of 10 may not be applicable in all situations, and indicated a

more realistic factor could be used if suitable documentation were provided to justify an

alternative.

Emissions of a volatile organic compound from an ASB depend upon the amount of the compound in the entering wastewater, wastewater chemical and physical pro perties, design and operating characteristics of the ASB, and ambient atmospheric conditions. Emissions are estimated with a model such as WATER9, which requires several input parameters including wastewater flow rate, wastewater temperature, compound

conc entration, basin area and depth, aeration rate, compound biorate, ambient temperature, and ambient wind speed.

To estimate the variability in emissions that might be expected from an ASB, one needs to first determine the variability in the amount of the organic compound entering the

ASB. This requires information on the wastewater flow rate and compound

concentration. Flow rates, when measured, are typically reported in gallons/day. Concentrations are most often obtained from daily grab samples, but most mills do not

make such measurements. The exception is kraft mills that use an ASB to satisfy the Cluster Rule condensate treatment requirement. These mills are required to conduct an annual performance test which involves collection of daily samples over a period that may range from one to 15 days, depending on the averaging time specified in the Title V permit. These samples are collected in the so

- called hard

- pipe, which transfers the collected condensates directly to the ASB. These condensates will conta in a significant portion of the organic hazardous air pollutants (methanol, acetaldehyde, propionaldehyde, formaldehyde, acrolein) being sent to the ASB. Thus, the hard

- pipe flow and concentration data should provide an indication of the variability in loa dings experienced over several days.

### G

- 2 Table 1 shows the peak

- to

- mean ratios for hard

- pipe loadings (lb/day; obtained from flow and concentration measurements) of methanol (6 mills) and acetaldehyde (3 mills). Daily samples were collected over periods rang ing from 12 to 16 days, once per year, with the exception of the 360 days of samples collected over a consecutive 13

- month period at

Mill A. Mill C had two annual tests, and Mill F had four annual tests. The peak

- to

- mean ratios range from 1.2 to 2.1, much less than the default factor of 10. Similar ratios would be expected for loadings of acrolein and formaldehyde, also present in condensates.

Table 1. Hard

- Pipe Loadings of Methanol and Acetaldehyde

Methanol Acetaldehyde

Mill A B C D E F B C F

Peak/Mean 1.7 1.5 1.3 1.2 1.5 1.3 1.6 1.3 1.5
Number of daily samples 360 16 15 16 12 16 16 15 16

Peak/Mean 1.4 1.6 2.1
Number of daily samples 26 16 16

Peak/Mean 1.3 1.9
Number of daily samples 16 16

Peak/Mean 1.1 1.9
Number of daily samples 16 16



### Repeated sampling for volatile organic hazardous air pollutants in raw wastewater

streams other than hard

- piped condensates is rare. Mill D also sampled the raw wastewater entering the primary clarifier (hard

- pipe condensates bypass the clarifier) for

the same 16

- day period as the hard piped condensates were sampled. The peak

- to

- mean ratio for methanol loadings (lb/day) was 1.3. Mill G collected random grab samples for methanol analysis from a primary cla rifier outlet (prior to entering an ASB) over a five year period. This mill has a steam stripper and does not hard

- pipe. Table 2 summarizes testing information from this mill. The peak

- to

- mean ratios for methanol concentrations ranged from 1.2 to 1.5, very similar to the ratios in methanol loadings observed for hard

piped condensates at other mills.

Table 2. Methanol Concentration Variability at a Primary Clarifier Outlet

Year 2010 2009 2008 2007 2006

Mean, mg/L 82 89 99 94 79
Peak, mg/L 97 110 148 130 95

Peak/Mean 1.2 1.2 1.5 1.4 1.2

### G

- 3 As mentioned earlier, emissions of a volatile organic compound from an ASB are estimated with a fate model that takes other factors into account besides compound loading. To examine the effect on emissions of certain parameters which may vary in time, a sensitivity analysis using EPA’s WATER9 model was performed. Emission calculations were made for an ASB with a surface area of 44 acres and depth of eight

feet. The ASB was subdivided into 3 zones, two with areas of 11 acres each with 950 hp of surface aeration each, and a third zone of 22 acres with 450 hp of surface aeration. Flow to the ASB was assumed to be 34 million gallons per day, with a methanol

concentration of 80 mg/L, and acetaldehyde and formaldehyde concentrations of 0.15 mg/L. A “baseline” set of conditions was first used to predict emission rates, and then these conditions were varied to see the effect on the emission predictions. The conditions were chang ed in a direction that would lead to increased emission rates. Table 3 shows modeled emission rates for this typical basin are most sensitive to the assumed biological activity rate, although it should be noted a 50% reduction would be a catastrophic event unlikely to occur on an annual basis. None of the four factors increase emission rates over

a factor of two.

Considering the number of factors affecting the WATER9 emission estimates, and the inherent uncertainties in this simulation model, it seems rea sonable to conclude the peak

to

- mean ratio is no more than a factor of two for emissions of volatile organic hazardous air pollutants, which would include methanol, acetaldehyde, formaldehyde, acrolein and

chloroform.

Table 3. WATER9 Sensitivity Analysis

Baseline
emission rate for ASB, g/s Change from baseline emission rate

Lower basin temperatures by 10°C Increase wind speed from 5

to 10 mph Lower
ambient air temperature

by 10°C Lower biological activity rate by

50%

Methanol 7.28

- 3% +24% 0 +79%
Acetaldehyde 0.065 +5% +5% 0 +46%
Formaldehyde 0.00045 +9% +32% 0 +86%

### Appendix H

EPA’s Conclusions Regarding Use of the Part II Acrolein D ata

### H

- 1 MEMORANDUM

FROM: Project Team (EPA/OAR/OAQPS/SPPD/NRG)

TO: Docket EPA

- HQ

- OAR

- 2007

- 0544

DATE: November 30, 2011

SUBJECT: Acrolein Emissions from Paper Machines and Mechanical Pulping (Non

- Combustion Sources)

The production of paper involves the processing of raw wood into pulp, chemical recovery, bleaching, paper m aking, and waste water treatment; the kraft process is shown in Figure 1. The subpart S (MACT 1 and 3) standard from the Pulp and Paper NESHAP applies to major sources of HAP emissions from the pulp production areas at chemical, mechanical, secondary fibe r, and

non

- wood pulp mills, bleaching operations, and papermaking systems. These processes are shown in blue and green in Figure 1. A separate standard (MACT 2), subpart MM, applies to chemical recovery processes at kraft, soda, sulfite, and stand

- alone s emi

- chemical mills. These processes are shown in yellow in Figure 1. Boiler MACT and NSPS are also regulations applied to systems within an integrated pulp and paper mill, shown in figure as gray and red outline, respectively.

Acrolein emissions are comm only formed by combustion sources at pulp and paper facilities through the burning of organic materials. Emissions were reported in response to the ICR from power boilers, recovery furnaces, and lime kilns, all of which are combustion sources; emissions

we re also reported from paper machines and mechanical pulping, which are not combustion sources. The reported acrolein emissions for both types of sources were based on emission factors, developed by NCASI.

Acrolein emissions from non

- combustion sources, such as paper machines and mechanical pulping, are not completely understood. In the case of mechanical pulping, it is thought that acrolein is formed and released when the wood is heated during the pulping process. Wood chips or logs are processed by grinding against metal plates, generating heat and, in the case of thermo

mechanical pulping, steam is introduced to heat the wood as a pretreatment to reduce processing energy requirements. In papermaking, water is remo ved from the pulp on a machine utilizing gravity draining, vacuum filtration, pressing, and drying. One hypothesis is that the acrolein is formed and released when the pulp sheet is dried, as the majority of test detects occurred at the paper machine dryer . Neither of these processes, mechanical pulping or papermaking, are combustion sources, but acrolein appears to be emitted from them based on limited testing.

The formation of acrolein upon heating and drying of the wood products is unknown, as it is

no t an inherent compound found in wood. Acrolein is potentially formed by the breakdown of wood components (e.g., cellulose, hemicelluloses, or lignin) during the drying process; the chemical structure and quantity of the components vary between wood species , growing location, weather (including wind, sunlight, and rain), season harvested, and growing soil conditions. We do not currently understand the interplay of these parameters and specifically how the various

### H

- 2 factors impact the amount of acrolein genera ted during heating and drying of the pulp during paper making and mechanical pulping.

The emission factors for acrolein from paper machines and mechanical pulping were developed by NCASI using test data on a very limited number of machines with a set of specific operating conditions. Testing was performed using a test method developed by the trade association, as the EPA has not developed a test method for these sources; the EPA is currently evaluating the NCASI method as a reference test for acrolein. A crolein testing of paper machines and mechanical pulping using this method has issues such as difficulty in capturing and quantifying acrolein due to fugitive background sources and building venting (instead of stacks) at large volumes with high moisture c ontents and low acrolein concentrations. These difficulties are apparent in the data set used to develop the emission factors, as it contained a majority of test run results below the method detection limit (MDL). NCASI followed the 1997 EPA protocol for

t he emission factor development, which recommended non

- detect run data be reported as half of the method detection limit ( Procedures for Preparing Emission Factor Documents, EPA

- 454/R

95

- 015, U.S. Environmental Protection Agency, Research Triangle Park, NC, May 1997 )

. However, in the case of acrolein from Subpart S non

- combustion sources, this protocol results in emission factors based primarily on assumed 1/2

- MDL values from a majority of test runs where

acrolein was not detected which introduced a large nu mber of unknowns into the dataset, thereby multiplying the uncertainties outlined above to an unknown degree. The uncertainty in the initial data set is further magnified when the emission factors are applied across the industry, yielding a

resultant acrol ein emission inventory predicated primarily on assumed values and not actual emissions measurements. This magnified uncertainty is compounded with the additional uncertainty of acrolein emissions from different paper machine operating parameters and

differ ent wood species used in pulping, resulting in further exacerbation of the uncertainty.

In our judgment, we believe that the industry efforts to document and confirm acrolein emissions, though informative, highlight the current technological limits in t he ability to capture and quantify acrolein emissions that are specific to paper machines and mechanical pulping processes. Based on the forgoing issues, we did not use this test data. EPA is working with industry to help refine and improve the test meth ods to capture this compound from these

sources.

### H

- 3 Figure 1: The Pulp and Paper Making Process