Date: February 4, 2013

Subject: Emissions Inventory for Kraft Pulp Mills and Costs/Impacts of the 

Section 111(b) Review of the Kraft Pulp Mills NSPS 

EPA Contract No. EP-D-11-084; Work Assignment No. 1-08 

From: Thomas Holloway, Katie Hanks

To: Kelley Spence, Bill Schrock

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711

I. Introduction

Section 111(b)(1)(B) of the Clean Air Act (CAA) directs the U.S. Environmental 

Protection Agency (EPA) to review and, if appropriate, revise existing new source 

performance standards (NSPS) at least every 8 years. The NSPS for kraft pulp mills (40 CFR 

part 60, subpart BB) were promulgated in 1978, last reviewed in 1986, and are due for another 

review. On December 6, 2011, the Center for Biological Diversity, Greenpeace, and Port 

Townsend AirWatchers filed a complaint with the U.S. District Court for the Northern District 

of California to compel the EPA to review the kraft pulp mills NSPS as directed under CAA 

section 111(b)(1)(B). On September 14, 2012, a proposed consent decree was published in the 

Federal Register that included an NSPS review schedule, specifying proposal by May 15, 2013 

and promulgation by March 14, 2014. Revisions to the kraft pulp mills NSPS will be included 

in a new subpart—40 CFR part 60, subpart BBa. 

The NSPS regulates emissions of particulate matter (PM) from new, modified, and 

reconstructed recovery furnaces, smelt dissolving tanks (SDTs), and lime kilns at kraft pulp 

mills. The NSPS also regulates emissions of total reduced sulfur (TRS) compounds from new, 

modified, and reconstructed digesters, brown stock washers, multiple-effect evaporators, 

condensate strippers, recovery furnaces, SDTs, and lime kilns at kraft pulp mills. Total 

reduced sulfur compounds are defined under 40 CFR 60.281(c) of the kraft pulp mills NSPS to 

include the following four compounds: hydrogen sulfide (H2S), methyl mercaptan (CH4S), 

dimethyl sulfide ((CH3)2S), and dimethyl disulfide ((CH3)2S2). 

A separate memorandum projects the number of new, modified, and reconstructed 

emission units that may trigger NSPS in the 5-year period following the applicability date for 

the NSPS review. (RTI 2013a) The purpose of this memorandum is to present the inventory 

and calculations used to: (1) estimate current emissions of PM and TRS; (2) estimate

incremental emissions reductions and costs associated with the NSPS review based on the 

emission units projected for construction, modification, or reconstruction; and (3) estimate 

incremental environmental and energy impacts associated with the NSPS review.
2 

II. Emissions Inventory for the NSPS Review

A. Organization of the Inventory 

The first step was to set up an inventory of all U.S. kraft pulp mills, including those kraft 

mills co-located with other types of pulping processes (i.e., semichemical, sulfite, mechanical, or 

secondary pulping). Information on individual mills was pulled from a database containing the 

pulp and paper industry’s responses to Part III of a three-part information collection request 

(ICR) that EPA sent to the industry in 2011. A row was included in the inventory for every

recovery furnace, black liquor oxidation (BLO) unit, lime kiln, and SDT at each mill (i.e., the 

emission units for which multiple regulatory options were considered under the NSPS review). 

Digesters, brown stock washers, evaporators, and condensate strippers (the other emission units 

included in the kraft pulp mills NSPS) were not included in the inventory based on the 

conclusion that there are no new technologies to consider. (RTI 2013b) For each emission unit in 

the inventory, all relevant information were included from the Part III ICR database that could 

influence emissions estimates, rule applicability, or costs, including, but not limited to:

• Pulp processes—kraft, kraft/sulfite, kraft/semichemical, kraft/mechanical, 

kraft/secondary;

• Emission process group—recovery furnace, BLO unit, lime kiln, SDT; 

• Year installed;

• Operating hours; 

• Exhaust gas flow rate (actual cubic feet per minute [acfm]) and other stack parameters 

(exhaust gas temperature, moisture content); 

• Air pollution control device (APCD) type—electrostatic precipitator (ESP), wet scrubber, 

etc.;

• Whether the unit is subject to subpart BB; 

• Year subject to subpart BB; 

• Reason subject to subpart BB—new, modified, or reconstructed; 

• Recovery furnace type—straight vs. cross, direct contact evaporator (DCE) vs. non-direct 

contact evaporator (NDCE);

• Black liquor solids firing rate; 

• Lime production rate; and

• Primary/supplemental fuel—natural gas, fuel oil, petroleum coke, etc. 

In some cases, ICR respondents used two rows for a single emission unit with dual stacks

or combined multiple emission units venting through the same stack on a single row of their ICR 

response. Where there were two rows for a single emission unit in the ICR data (e.g., two vents 

on a single SDT), those rows were combined into a single row in the NSPS review inventory. 

Where there was a single row for multiple emission units in the ICR data (e.g., multiple lime 

kilns vented to a single stack), this configuration was retained but was noted in the “Emission 

Process Group” field in the NSPS review inventory (e.g., “Lime Kilns (2)”) to assist in any later 

equipment counts. Where an emission unit was missing, that emission unit was added to the 

NSPS review inventory, using data from the pulp and paper ICR databases. 
3 

To inform potential regulatory options for NSPS review, specific columns were added 

from the Controls table in the Part III ICR database, including APCD pressure drop, PM and 

TRS control efficiencies, electrostatic precipitator (ESP) specific collecting area (SCA), scrubber 

liquid-to-gas ratio, and scrubber water source (e.g., weak wash, fresh water). Data from the Part 

III Controls table were adapted to match the configuration of the inventory spreadsheet (i.e., one 

row per emission unit), since some emission units have multiple controls, and some controls are 

applied to multiple emission units. The APCD columns in the NSPS review inventory were also 

revised and standardized where necessary to ensure consistency across the inventory. 

B. Estimation of Current Emissions

The next step, after setting up the inventory, was to estimate the current emissions of PM 

and TRS for each type of emission unit included in the inventory (i.e., recovery furnace, BLO 

system, SDT and lime kiln). Four sources of emissions data for the NSPS emission units were

reviewed to determine whether they would be acceptable for estimating current emissions:

• PM and TRS emissions data from EPA’s National Emissions Inventory (NEI); 

• TRS continuous emissions monitoring system (CEMS) data for lime kilns and recovery 

furnaces;

• PM and TRS performance data from stack tests included with ICR responses; and

• PM and TRS emissions estimates calculated from emission factors from technical 

bulletins prepared by the National Council for Air and Stream Improvement (NCASI), 

which is a major source of environmental data affecting the pulp and paper industry. 

The NEI was not used as a source of PM and TRS emissions data for the NSPS review

for a variety of reasons: 

• The NEI PM and TRS data for recovery furnaces, BLO units, lime kilns, and SDTs were 

not always updated through the ICR (updates for these emission units were not 

mandatory); 

• Between the performance data and calculated estimates, there is a complete set of PM 

and TRS emissions data for all of the emission units of concern. There is not a complete 

set of PM and TRS emissions data in the NEI for all of the emission units of concern, and 

there are insufficient NEI data to fill the gaps in performance data;

• The PM data in the NEI are not always in the desired format (filterable PM), requiring 

the use of default factors from EPA’s NEI guidance to convert them to filterable PM data, 

which increases the level of uncertainty about the accuracy of the data;

• The TRS data in the NEI are presented in a variety of formats (TRS, TRS as H2S, TRS as 

sulfur); and

• Some TRS data in the NEI were only available as one or more component compounds 

(H2S, CH4S, (CH3)2S, and/or (CH3)2S2), which provides an incomplete picture of the 

overall TRS emissions for the emission unit.

The TRS CEMS data for lime kilns and recovery furnaces were not incorporated into the 

NSPS review inventory because the CEMS data contained 12-hour emission concentrations 

(ppm) that would require further manipulation to calculate mass emission rates.
4 

The PM performance data from all emission units and TRS performance data from SDTs 

were compiled from the stack test reports that were provided with ICR responses. Where there 

were multiple test reports for a single emission unit, the results from those reports were averaged 

to generate a single performance level for each emission unit. Performance levels were 

developed in units of: 

• Concentration—grains per dry standard cubic foot (gr/dscf) for PM, or parts per million 

(ppm) for TRS; 

• Emission rate—pounds per hour (lb/hr); and

• Emission factor—pounds per ton (lb/ton). 

Because these performance data are based on actual emissions measured directly from the 

emission units, they are preferred over the other sources of emissions data listed above. Thus, 

when available, the average of the lb/hr performance data for each emission unit was used to 

estimate current emissions. Emissions were calculated by multiplying the site-specific operating 

hours per year provided in each ICR response by the lb/hr performance and converting emissions 

to tons per year. 

To backfill any gaps where performance data were unavailable for a particular emission 

unit, PM and TRS emissions were calculated for recovery furnaces, BLO units, lime kilns, and 

SDTs using NCASI emission factors. (NCASI 2004, NCASI 2010) Those emission factors and 

the process data from ICR responses and other sources—tons of calcium oxide (CaO) per day for 

lime kilns and pounds of black liquor solids (BLS) per day for all other emission units—were 

used to calculate annual emissions (in tons per year [tpy]). 

To facilitate the calculation of BLO unit emissions using emission factors, which are in 

units of lb of pollutant per ton of BLS fired, a BLS firing rate column was added for BLO units, 

presented in units of million lbs of BLS per day (MM lb BLS/d). Because BLO units serve to 

oxidize the black liquor fired into the DCE recovery furnaces at the mill, the solids firing rates 

for the associated DCE recovery furnace(s) were assigned to the BLO unit(s) at the mill, 

summing where necessary. The BLS firing rates for BLO units and DCE recovery furnaces were 

reviewed and revised where necessary to ensure that the sum of the BLS firing rates for the BLO 

unit(s) at each mill was equal to the sum of the BLS firing rates for the associated DCE recovery 

furnace(s) at that mill.

To facilitate the calculation of recovery furnace, lime kiln, and SDT emissions using 

emission factors, the process rate columns for those emission units were reviewed and revised 

where necessary to fill data gaps, correct errors, and replace cells marked as confidential 

business information (CBI) with publicly available process rate data. Where necessary, revisions 

were made using recent data from RISI, process data from title V permits, and lime kiln heat 

input data from the ICR database converted to lime kiln process rate using a default conversion 

factor of 6 million British thermal units (MMBtu) per ton of CaO. (RISI 2012, SmurfitStone 

2008, RockTenn 2012, NCASI 2010) The BLS firing rates for recovery furnaces and SDTs were 

also reviewed and revised where necessary to ensure that the BLS firing rate assigned to each 

SDT at a particular mill was equal to the BLS firing rate for the corresponding recovery furnace 

at that mill and vice versa. 

The following equations were used to estimate current emissions based on NCASI 

emission factors: 
5 

Equation 1—Current emissions from recovery furnaces/BLO units/SDTs:

Annual emissions (tpy PM or TRS) = emission factor (lb PM or TRS/ton BLS) * (1 ton BLS/2000 lb BLS) * BLS 

firing rate (lb BLS/d) * annual operating hours (hr/yr) * (1 d/24 hr) * (1 ton PM or TRS/2000 lb PM or TRS)

Equation 2—Current emissions for lime kilns:

Annual emissions (tpy PM or TRS) = emission factor (lb PM or TRS/ton CaO) * lime production rate (ton CaO/d) * 

annual operating hours (hr/yr) * (1 d/24 hr) * (1 ton PM or TRS/2000 lb PM or TRS)

To determine the current nationwide emissions for each emission unit type, the emissions 

estimated based on performance data and emissions estimates based on emission factors were 

integrated into a single column for each pollutant, and the emissions data were summed for each

emission unit type. The current nationwide emissions are presented in Table 1 below. 

Table 1. Estimated Nationwide Emissions for Recovery Furnaces 

(and Associated BLO Units), SDTs, and Lime Kilns

Emission unit

Emissions, tpy

PM TRS

Recovery furnaces 12,916 2,328

 NDCE recovery furnaces 10,197 1,248

 DCE recovery furnaces 2,719 1,080

BLO units 32 411

SDTs 4,571 492

Lime kilns 4,107 535

Total nationwide 21,626 3,766

Note: Numbers may not add exactly due to rounding error. 

III. Regulatory Options for the NSPS Review

Table 2 summarizes the baseline NSPS requirements in subpart BB and the regulatory 

options under consideration for the NSPS review (which would be codified in a new subpart 

BBa). Separate memoranda document the data reviewed and technological basis for these 

regulatory options. (RTI 2013b, EPA 2013b) Table 2 also summarizes the basis for the costs 

estimated for each regulatory option which are described in the next section of this memo. In 

addition to subpart BB, the 40 CFR part 63 subpart MM MACT standard for chemical recovery 

combustion sources serves as the baseline federal standard for PM and opacity for new and 

reconstructed sources. 
6 

Table 2. Baseline Technologies, Regulatory Options, and Cost Basis for NSPS Review 

Emission 

unit

Baseline technology and NSPS 

subpart BB standard Regulatory option for NSPS review (subpart BBa) Incremental cost basis

Recovery 

furnace

ESP with collection efficiency of 

99.5% meeting 0.044 gr/dscf

RF PM 1: (1) Set NSPS for new/reconstructed units to MACT new limit of 

0.015 gr/dscf; (2) Maintain current NSPS limit of 0.044 gr/dscf for modified 

units.

$0. Costs already incurred under 

MACT. 

RF PM 2: Reduce PM limit for new, reconstructed, and modified units from 

to MACT new limit of 0.015 gr/dscf. 

Difference in ESP cost to control 

modified units from 0.044 gr/dscf to 

0.015 gr/dscf (i.e., ESP designed to 

meet 0.044 vs. 0.015)

NDCE recovery furnace with 

good combustion control or DCE 

recovery furnace with BLO 

meeting 5 ppm (25 ppm for cross 

recovery furnaces)

RF TRS: Maintain TRS limit at 5 ppm and restrict the 1 percent monitoring 

allowance to 45 ppm. 

$0. No change to ppm limit.3

35% opacity with 6% allowance RF Opac: Decrease opacity limit to 20% opacity and reduce the monitoring 

allowance to 2 percent of averaging periods. Add ESP parameter monitoring 

(voltage and current) to indicate compliance during the monitoring 

allowance.

$0. No new control or opacity 

monitoring cost. 3 Added cost for 

parameter monitoring for compliance 

purposes.

Lime kiln Venturi scrubber with 30 in. H2O 

pressure drop meeting 0.066 

gr/dscf for gas-fired kilns, 0.13 

gr/dscf for oil-fired kilns

LK PM 1: Set NSPS for new and reconstructed units to MACT new limit of 

0.010 gr/dscf and use MACT existing limit of 0.064 gr/dscf for modified 

units. 

$0. Costs already incurred under 

MACT.

LK PM 2: Reduce PM limit for new, reconstructed, and modified units to 

MACT new limit of 0.010 gr/dscf. 

Difference in ESP cost to control 

modified units from 0.064 gr/dscf 

existing source MACT limit to 0.010 

gr/dscf (i.e., ESP designed to meet 

0.064 vs. 0.010)

More efficient process controls 

and use of caustic solution in 

scrubber to meet 8 ppm

LK TRS: Maintain current limit of 8 ppm and add a 1 percent monitoring 

allowance restricted to an upper limit of 22 ppm. 

$0. No change to ppm limit.

3

No NSPS requirement; MACT 

limit of 20% opacity with 6% 

allowance

LK Opac: Add MACT limit of 20% opacity to NSPS with a 1 percent

monitoring allowance. Add ESP parameter monitoring (voltage and current) 

to indicate compliance during the monitoring allowance.

$0. Costs for opacity monitoring

already incurred under MACT.3 Added 

cost for parameter monitoring for 

compliance purposes.
7 

Emission 

unit

Baseline technology and NSPS 

subpart BB standard Regulatory option for NSPS review (subpart BBa) Incremental cost basis

Smelt 

dissolving 

tank

Wet scrubber or a combination 

demister/wet scrubber meeting 

0.2 lb/ton BLS

SDT PM 1: Set NSPS for new units to MACT new limit of 0.12 lb/ton BLS 

and maintain current NSPS limit of 0.2 lb/ton BLS for modified and 

reconstructed units.

4

$0. Costs already incurred under 

MACT. 

SDT PM 2: Reduce PM limit for new, reconstructed, and modified units to 

MACT new limit of 0.12 lb/ton BLS. 

Difference in scrubber cost to control 

modified units from 0.2 lb/ton BLS to 

0.12 lb/ton BLS (i.e., wet scrubber 

designed to meet 0.2 vs 0.12)

Using water not highly 

contaminated with dissolved 

sulfides for dissolving the smelt 

and scrubbing to meet 0.033 

lb/ton BLS as H2S

SDT TRS 1: Maintain current limit of 0.033 lb/ton BLS. $0. Same as NSPS baseline.

SDT TRS 2: Reduce limit to original 1976 NSPS limit of 0.0168 lb/ton BLS. Cost to control units from current 

NSPS limit of 0.033 to original 1976 

NSPS limit of 0.0168 lb/ton BLS (wet 

scrubber installation)5

1. Concentration limits for recovery furnaces are at 8 percent oxygen (O2), while concentration limits for lime kilns are at 10 percent O2. 

2. “MACT” refers to the subpart MM MACT standard. 

3. Incremental costs associated with adjustments to monitoring allowances include nominal costs for reprogramming data acquisition systems. These costs are 

included in the reporting and recordkeeping cost estimates developed as part of the Paperwork Reduction Act supporting statement as described in Section 

IV.A.4 below. ESP parameter costs are added costs described in Section IV.A.3 below.

4. According to the definitions under subpart MM, only new SDTs that are constructed in conjunction with a new or reconstructed recovery furnace are subject to 

the MACT new limit of 0.12 lb/ton BLS. 

5. Incremental cost impacts associated with reducing the SDT TRS limit under option SDT TRS 2 are based on the same incremental scrubber costs used for 

SDT PM 2 because no information is available to estimate the cost of process changes to use water not highly contaminated with dissolved sulfides for dissolving 

the smelt and scrubbing. However, it is acknowledged that process factors beyond control of the scrubber liquid source affect SDT TRS emissions.
8 

IV. Costs, Environmental and Energy Impacts of the NSPS Review Options

The costs associated with the NSPS review regulatory options are incremental costs (i.e., 

the additional cost associated with complying with a more stringent limit or additional 

requirement beyond that required under the current subpart BB NSPS or subpart MM MACT). 

Similarly, the emissions reductions and other environmental and energy impacts are estimated 

incrementally. The subpart BB NSPS and/or subpart MM MACT limits for existing sources 

represent the “baseline” scenario. The difference in the costs, environmental, and energy impacts 

attributable to the subpart BB “baseline” scenario and the impacts of the revised Subpart BBa 

NSPS review options represent the incremental impacts of the NSPS review. 

The impacts associated with NSPS review are customarily developed for a five-year 

period based on the projected number of new, modified, and reconstructed emission units that 

may trigger NSPS during the 5-year period following the applicability date for the NSPS review. 

The methodology used to project the number of emission units that would trigger NSPS and 

identify specific mills likely to have new, modified, or reconstructed sources is provided in a 

separate memorandum. (RTI 2013a) A total of 10 mills are projected to have emissions units 

impacted by the revised NSPS. (RTI 2013a) Two of the 10 mills are estimated to be small 

businesses. Appendix A at the end of this memorandum presents the mill-specific and 

nationwide costs and cost effectiveness for each of the regulatory options. 

A. Cost Impacts

1. Control Costs 

Costs were estimated for the baseline scenario (subpart BB and/or subpart MM) and each 

of the NSPS review regulatory options identified in Table 2. These costs were applied to each 

emission unit estimated to be impacted. Incremental costs were determined as the NSPS option 

cost minus the baseline cost, and the incremental costs for each affected emission unit were 

summed to determine nationwide costs. The cost estimates were developed in 2012 dollars. 

Model costs are presented in Appendix B. 

The incremental control costs for each new, modified, or reconstructed emission unit are 

based on the difference between the costs of installing a new control device designed to meet 

subpart BB (and/or subpart MM) and the costs of installing an identical, but better-performing 

control device designed to meet the subpart BBa regulatory option. New control devices (as 

opposed upgrades of existing control devices) were assumed to be the baseline control cost 

because most of the control devices on emission units projected to be impacted have exceeded 

their useful equipment life expectancy. The impact of this assumption on cost-effectiveness is 

explored further in Appendix C. 

Updates to BE&K control costs to reflect 2012 dollars. The regulatory option costs were 

developed based on 2001 base year emission control cost estimates prepared by BE&K 

Engineering for the American Forest and Paper Association (AF&PA). (BE&K 2001) The 

BE&K capital costs were updated from 2001 to 2012 dollars using a ratio of the Chemical 

Engineering Plant Cost Indices for those two years, specifically 577.4 for September 2012 (the 

latest index for the year 2012) and 394.3 for the year 2001. (CE 2012) 
9 

The maintenance and materials cost were recalculated as a factor of the updated capital 

cost, using the same cost factors as BE&K—3.5 percent for recovery furnace ESP installations, 

3 percent for lime kiln ESP installations, and 2 percent for SDT scrubber installations and 

recovery furnace ESP upgrades. (BE&K 2001) 

The labor costs were updated by ratioing the latest labor rate ($27.20/hr) from the U.S. 

Bureau of Labor Statistics against the labor rate ($25.04/hr) used by BE&K in its 2001 labor cost 

estimate. (BLS 2012, BE&K 2001) The latest labor rate (for May 2011) was taken from the 

National Industry-Specific Occupational Employment and Wage Estimates for Installation, 

Maintenance, and Repair personnel at NAICS code 322100 (Pulp, Paper, and Paperboard Mills). 

(BLS 2012) 

The electricity costs were updated by ratioing the latest electricity price ($0.0673/kWh) 

from the U.S. Energy Information Administration against the electricity price ($0.05/kWh) used 

by BE&K in its 2001 electricity cost estimate. (EIA 2012, BE&K 2001). The latest electricity 

price (for October 2012) was taken from the Average Retail Price of Electricity to Ultimate 

Customers by End-Use Sector in the latest issue of Electric Power Monthly. (EIA 2012) The 

“U.S. total” electricity price for the industrial sector was used.

Some additional annual costs were also added (based on guidance in EPA’s Control Cost 

Manual) that were not included in the BE&K cost estimate. (EPA 2002) These costs include: 

• Overhead (estimated at 60 percent of labor and materials);

• Property taxes, insurance, and administrative charges (estimated at 4 percent of total 

capital cost); and

• Capital recovery (estimated as the product of a capital recovery factor [CRF] and total 

capital cost).

The capital recovery factor was calculated as follows, assuming a 7 percent interest rate 

and 15-year equipment life (for the ESPs and wet scrubbers to be installed): 

Equation 3--Capital recovery factor:

CRF = [interest rate * (1 + interest rate)equipment life]/[(1 + interest rate)equipment life-1]

Scaling BE&K control costs for mill-specific equipment size. The costs from BE&K 

were prepared for model emission units, specifically a 3.7 million lb BLS/d NDCE recovery 

furnace and SDT, a 1.7 million lb BLS/d DCE recovery furnace, and a 240 ton CaO/d lime kiln. 

The model costs updated to 2012 dollars are presented in Appendix B. As shown in Appendix B, 

both baseline costs and NSPS control costs were developed for analysis of the NSPS review 

options. The six-tenths cost rule was used as follows to adapt the BE&K capital costs to apply to 

each emission unit affected under the NSPS review: 

Equation 4--Six-tenths cost rule:

C1/C2 = (Q1/Q2)0.6, where C is cost and Q is capacity parameter, such as black liquor solids firing rate (for recovery 

furnaces and SDTs) and lime production rate (for lime kilns)

Because electricity costs are a function of gas flow rate, and gas flow rate is proportional 

to capacity parameters such as black liquor solids firing rate and lime production rate, the 

electricity costs were adapted to apply to each emission unit by ratioing the capacity parameters. 

(Gas flow rate was not used to adapt the electricity costs since gas flow rate information was not 
10 

included in the BE&K cost estimates.) For lime kilns, the lime production rate of the affected 

lime kiln was ratioed to the 240 ton CaO/d used by BE&K in its cost estimate; for NDCE 

recovery furnaces and SDTs, the black liquor solids firing rate of the affected furnace or SDT 

was ratioed to the 3.7 million lb BLS/d used by BE&K in its cost estimate.

Cost-effectiveness calculation. Once the baseline and NSPS control costs were assigned 

to each affected emission unit, incremental costs were estimated for each unit by subtracting the 

NSPS control costs from the baseline costs. The cost effectiveness of the NSPS regulatory option 

for each affected emission unit was then estimated by dividing the incremental annual cost for 

that unit by its incremental emissions reduction. (The calculation of emissions reductions is 

discussed in Section B below.) The costs and cost effectiveness were estimated nationwide and 

by emission unit type. Appendix A summarizes the mill-specific and nationwide costs and cost 

effectiveness for each of the regulatory options, including control costs, and the additional 

testing and labor-related costs described below.

2. Repeat Emissions Testing Costs 

The proposed revisions to the kraft pulp mills NSPS would require repeat PM, 

condensable PM (CPM), and TRS testing for recovery furnaces, SDTs, and lime kilns every 60 

months (5 years). Repeat emissions testing costs represent incremental costs because repeat

testing is not required under subpart BB. The cost of each PM and TRS test was estimated using 

the test costs provided by the pulp and paper industry in their ICR responses. The median cost 

for a Method 5 PM test for recovery furnaces, SDTs, and lime kilns reported in the ICR 

responses was $6,000, and the median cost for a Method 16B TRS test for SDTs was $3,000. 

The cost of coupling a Method 202 CPM test with the Method 5 PM test was estimated to be 

$800. The testing costs were annualized over 5 years using Equation 6 above, based on a 7 

percent interest rate and 5-year payment period. 

3. ESP Parameter Monitoring Costs 

The proposed NSPS revisions would require monitoring of ESP secondary voltage and 

secondary current to indicate ongoing compliance at all times, including times when the opacity 

monitoring allowance is used. New ESPs would be expected to have monitors for secondary 

voltage and current, but additional incremental costs may be associated with using these 

monitors for compliance purposes. In the absence of information on incremental costs of ESP 

monitors for compliance (versus monitors for operational purposes only), the full capital cost for 

ESP parameter monitoring was estimated to be $31,000 based on information from another 

recent rulemaking. Annual costs associated with ESP parameter monitoring were estimated to be 

$7,560 for capital recovery (assuming a 15-year life and 7 percent interest rate) plus $4,200 for 

operation and maintenance of the monitor, which includes 3.5 percent of capital for maintenance 

and materials, 6 percent for overhead, and 4 percent for taxes, insurance, and administration. 

Thus, total annualized costs for ESP parameter monitors was estimated to be $11,760. 

4. Labor-related Costs 

Negligible design and operating labor costs are associated with the incremental 

improvements in control systems that would be used to meet the regulatory options because the 

same types of systems would be used (e.g., better performing ESPs or scrubbers). Incremental 
11 

reporting and recordkeeping (R&R) labor hours and costs were developed as part of the 

Paperwork Reduction Act supporting statement. Initial labor reporting and recordkeeping labor 

costs include costs associated with entering test data into the Electronic Reporting Tool (ERT) 

(once in the initial 5-year impact period), data acquisition system adjustments to include startup 

and shutdown periods, compliance with revised monitoring allowances, and ESP parameter 

monitoring. Annual R&R labor costs include costs associated with two instances of affirmative 

defense at $3,375 each, malfunction reports, and additional time for reviewing monitoring data 

with TRS upper limit caps and/or adjusted allowances. Details on these cost estimates, as well as 

an accounting for the labor hours involved, can be found in Table 3 of this memorandum and in 

the supporting statement for subpart BBa. (EPA 2013) 

Table 3. Incremental R&R Costs for Inclusion in the Cost Impact Analysis 

Labor cost item

Incremental 

R&R costs, 

$/mill

Incremental R&R 

labor hours per 

mill

Initial labor costs

ERT. Initial during 5-year impact period, and once every 5 years 

thereafter.

$540 5

Time to adjust existing data acquisition systems at modified sources to 

include startup and shutdown periods and comply with revised 

monitoring allowances

$4,500 40

TOTAL INCREMENTAL R&R COST PER MILL - Initial $ 5,040 45

Annual labor costs

Additional time for reviewing monitoring data with TRS upper limit caps 

and adjusted allowances 

$1,800 24

Affirmative defense cost $6,750 60

ESP parameter monitoring labor $10,264 91

Malfunction reports not previously required $2,700 84

TOTAL INCREMENTAL R&R COST PER MILL - Annual $ 21,514 199

Note: Totals may include some rounding error.

B. Baseline Emissions and Emissions Reductions 

As described in Section II.B, current emissions were estimated using actual performance 

levels from emissions test reports or NCASI emission factors (when actual performance levels 

were unavailable). Baseline emissions associated with implementation of subpart BB were 

estimated for the emission units projected to be impacted by NSPS in the 5-year impact period. 

The current emissions estimate was used as the subpart BB baseline emissions estimate 

for existing emission units projected to be modified. Current emissions reflect application of the 

existing source MACT standards. Because the existing source MACT standards are the same or 

more stringent that the current NSPS subpart BB standards, emission sources are already 

required to be compliant with the emission limits in subpart BB even if the emission unit has not 

triggered NSPS. For new units (which have no actual performance data), the emission limits 

associated with subpart BB or existing source MACT (whichever is more stringent) were used to 

calculate baseline emissions (e.g., 0.044 gr/dscf for recovery furnaces, 0.064 gr/dscf for lime 

kilns, or 0.2 lb/ton BLS for SDTs). 
12 

No emissions reductions would be obtained under each NSPS review control option 1 

because these options are the same as the current MACT limits for PM and equal baseline (for 

PM and TRS). To determine the emissions reductions that could be achieved under each NSPS 

review control option 2, the emissions allowed under option were estimated and subtracted from 

the baseline emissions. The emissions reduction associated with implementing option 2 was 

treated as zero if the baseline emissions were already below the emissions allowed under option 

2. Equations 5 and 6 were used in calculating the emissions under baseline (for new units) or 

under option 2 for each affected emission unit, based on the emission limit associated with each 

option and ICR data for gas flow rate (converted to dry standard cubic feet per minute [dscfm]), 

annual operating hours, and black liquor solids firing rate for each unit:

Equation 5—PM regulatory option emissions for recovery furnaces/lime kilns:

Regulatory option emissions (tpy PM) = emission limit (gr/dscf) * gas flow rate (dscfm) * (60 min/hr) * annual 

operating hours (hr/yr) * (1 lb PM/7000 gr PM) * (1 ton PM/2000 lb PM)

Equation 6—PM/TRS regulatory option emissions for SDTs:

Regulatory option emissions (tpy PM or TRS) = emission limit (lb/ton BLS) * BLS firing rate (lb BLS/d) * (1 ton 

BLS/2000 lb BLS) * annual operating hours (hr/yr) * (1 d/24 hr) * (1 ton PM or TRS/2000 lb PM or TRS) 

Gas flow rate values in the ICR database were converted from units of acfm to dscfm as 

follows, assuming pressure is at standard conditions and using ICR data for exhaust gas 

temperature and moisture content:

Equation 7—Dry standard gas flow rate: 

Gas flow rate (dscfm) = gas flow rate (acfm) * standard temperature °R (68°F + 460)/exhaust gas temperature °R 

(°F + 460) * moisture correction (100% H2O – exhaust gas moisture content (% H2O))/(100% H2O – 0% H2O) 

The incremental emissions reduction for each affected emission unit was calculated by 

subtracting the emissions estimate for the NSPS regulatory option from the baseline emissions 

estimate.

C. Energy and Other Environmental Impacts

1. Energy Impacts 

The incremental energy impacts of the NSPS regulatory options for each affected 

emission unit were estimated by dividing the incremental electricity cost of each option by the 

latest electricity price ($0.0673/kWh). (EIA 2012) The estimated incremental energy impacts (in 

kilowatt-hours per year [kWh/yr]) for each affected emission unit were converted to both 

megawatt-hours per year (MWh/yr) (based on 1 MWh/1,000 kWh) and MMBtu/yr (based on a 

conversion factor of 3,415 Btu/kWh). 

2. Secondary Air Emissions 

Once the incremental energy impacts were determined, the associated incremental 

secondary air emissions were estimated. Secondary emissions typically include the criteria air 

pollutant emissions—PM, carbon monoxide (CO), nitrogen oxides (NOX), and sulfur dioxide 

(SO2)—that result from the generation of electricity used to comply with regulatory options. For 

purposes of this analysis, the electricity was assumed to be purchased from offsite utilities, rather 
13 

than generated onsite. Secondary emissions estimates were also developed for the greenhouse 

gases carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) that are expected to be 

emitted from utilities. The incremental secondary emissions were estimated as follows, by 

multiplying emission factors for the pollutants by the incremental energy impacts, assuming a 

specific mix of fuels to generate the needed electricity.

Equation 8--Incremental secondary emissions (PM, CO, NOX, SO2):

Incremental secondary emissions (tpy PM, CO, NOX, or SO2) = incremental energy impacts (MMBtu/yr) * 

[emission factor for solid fuel (lb/MMBtu) * (% of generation for solid fuel) + emission factor for natural gas 

(lb/MMBtu) * (% of generation for oil/natural gas and other fuel)] * 1 ton/2000 lb

Equation 9--Incremental secondary emissions (CO2, CH4, N2O):

Incremental secondary emissions (tpy CO2, CH4, N2O) = incremental energy impacts (MMBtu/yr) * [emission factor 

for solid fuel (kg/MMBtu) * (% of generation for solid fuel) + emission factor for natural gas (kg/MMBtu) * (% of 

generation for oil/natural gas and other fuel)] * 2.204623 lb/kg * 1 ton/2000 lb

Global warming potentials of 1 for CO2, 21 for CH4, and 310 for N2O were used to estimate CO2

equivalent emissions (CO2eq). Appendix D of this memorandum provides the emission factors 

used in impact calculations. Additional details regarding the approach used to estimate the 

secondary emissions (e.g., the sources of the emission factors, the basis for the fuel mix) are 

provided in another memorandum. (RTI 2012) 

3. Solid Waste and Wastewater Impacts 

An evaluation was also conducted regarding whether the NSPS regulatory options would 

have any solid waste or wastewater impacts. Regulatory option RF PM 2 would require mills to 

increase PM control for recovery furnaces from the MACT existing limit of 0.044 gr/dscf to the 

MACT new limit of 0.015 gr/dscf by replacing the ESP on those furnaces with a more efficient 

ESP. As noted in the technical support document (TSD) for subpart MM (EPA 1996), the PM 

catch from the recovery furnace ESP is primarily Na2SO4 (i.e., saltcake) and Na2CO3. These 

chemicals are subsequently added to the concentrated black liquor in a mix tank (i.e., recycled 

back into the process) in order to conserve chemicals. (EPA 1996) The recovery process is 

assumed to have sufficient capacity to absorb the additional PM resulting from the ESP 

replacement. Thus, no solid waste disposal impacts are expected under option RF PM 2. 

Additional dry PM catch would be generated if a more efficient ESP is installed to 

improve PM control for lime kilns from 0.064 to 0.010 gr/dscf. As stated in the TSD for subpart 

MM (EPA 1996), existing lime kilns with ESPs return the PM catch directly to the lime kiln. The 

lime kiln is expected to have sufficient capacity to absorb the additional PM catch resulting from 

implementing the lime kiln PM control option. Thus, no solid waste disposal impacts are 

expected with option LK PM 2. 

Option SDT PM 2 would require mills to increase PM control for SDTs from the MACT 

existing limit of 0.2 lb/ton BLS to the MACT new limit of 0.12 lb/ton BLS by replacing the 

existing wet scrubber or mist eliminator with a more efficient wet scrubber. Option SDT TRS 2 

would require mills to control SDTs from the current NSPS TRS limit of 0.033 lb/ton BLS to a 

revised NSPS limit of 0.0168 lb/ton BLS. As with the costs, the impacts of option SDT TRS 2 

were estimated on the same basis as option SDT PM 2 (i.e., wet scrubber replacement) due to the 
14 

absence of information regarding any process changes that could reduce TRS emissions from 

SDTs. 

By increasing the amount of PM and TRS removed from the exhaust gases, the SDT 

regulatory option would increase the amount of PM and TRS in the blowdown from the 

scrubber. Blowdown rates would have to increase because of the greater amount of PM and TRS, 

thereby increasing the amount of wastewater generated. (EPA 1996) Because wastewater from 

SDT scrubbers and mist eliminators would typically be allowed to drain into the SDT to react 

with the smelt, the additional wastewater generated under the SDT regulatory options is expected 

to be reused. (EPA 1996) The SDT is assumed to have sufficient capacity to absorb the 

additional wastewater and PM/TRS resulting from implementing the regulatory option; 

therefore, no wastewater impacts are expected. 

V. Summary of Nationwide Incremental Costs and Impacts for the NSPS Review 

The nationwide incremental costs (in 2012 dollars) and impacts associated with the NSPS 

review are summarized in Tables 4 and 5 below. Mill-specific costs and impacts are presented in 

Appendix A. A total of 10 mills are projected to be impacted by the revised NSPS (Subpart BBa) 

during the 5-year period following the applicability date for the NSPS review for which impacts 

are considered. Two of the 10 mills projected to be impacted are small businesses. Appendix E 

presents the detailed unit-by-unit impact calculations discussed in this memorandum. 

As shown previously in Table 3, initial incremental labor impacts for the revised NSPS 

are estimated to be 45 hours per mill, for a total of 450 hours for the 10 mills. Annual labor 

impacts are estimated to be 199 hours per mill, for a total of 1990 hours for the 10 mills 

projected to be impacted. 

 
15 

Table 4. Nationwide Baseline Control Costs and Incremental Costs, Emissions Reductions, and Cost Effectiveness of the NSPS 

Review Regulatory Options (2012 dollars) 

Regulatory 

option

Mills 

affected

Baseline control costs

Incremental control costs for 

NSPS review option Incremental 

emissions 

reduction, 

tpy

Cost 

effectiveness, 

$/ton

Capital, 

$M

Annualized, 

$M Capital, $M Annualized, $M

Particulate matter1

RF PM1 8 $164 $33.7 $0 $0 none NA

RF PM2 2 new

6 mod

$0 new

$23.9 mod

$0 new

$5.69 mod

207

(93 PM2.5)

$27,500

LK PM1 2 $9.74 $2.02 $0 $0 none NA

LK PM2 1 new

2 mod3

$0 new

$1.87 mod

$0 new

$0.423 mod

26

(11 PM2.5)

$16,000

SDT PM1 8 $19.4 $4.03 $0 $0 none NA

SDT PM2 2 new

6 mod4

$0 new

$0.489 mod

$0 new

$0.188 mod

29

(24 PM2.5)

$6,610

Total reduced sulfur

SDT TRS1 8 $19.4 $4.03 $0 $0 none NA

SDT TRS2 8 $0.648 $0.250 6 $45,300

Other incremental costs

Repeat testing 10 NA NA $0.186 $0.0454 NA NA

Monitoring 10 NA NA $0.341 $0.129 NA NA

Reporting and 

recordkeeping

10 NA NA $0.050 $0.215 NA NA

Total nationwide costs and emissions reductions for options selected2

TOTAL2 $0.578 $0.390 PM: 0

TRS: 0

1. Fine PM (PM2.5) emissions reductions were estimated from the filterable PM emissions reductions presented in the table by applying the following percentages 

of PM2.5 to the filterable PM emissions: 45% for modified recovery furnaces (all NDCE furnaces), 40% for lime kilns (with ESPs installed), and 84% for SDTs.

2. Regulatory options selected for the NSPS review proposal appear in bold.

3. One mill is projected to install a new lime kiln and modify a separate lime kiln (for a total of 2 impacted kilns at that mill).

4. Similar cost effectiveness can be expected from SDTs that trigger the new source or reconstruction provisions under NSPS (independent of the recovery 

furnace) but do not meet the new source or reconstruction criteria under MACT (e.g., because the recovery furnace is included in the reconstruction capital cost 

calculation under subpart MM).
16 

Table 5. Nationwide Incremental Environmental and Energy Impacts of the NSPS Review Regulatory Options 

Regulatory 

option

Energy impacts Secondary air impacts, tpy

Electricity, 

MWh/yr PM CO NOx SO2 GHG as CO2eq

RF PM1 0 0 0 0 0 0

RF PM2 18,292 0.51 3.7 7.0 20 4,239

LK PM1 0 0 0 0 0 0

LK PM2 1,248 0.035 0.26 0.48 1.4 289

SDT PM1 0 0 0 0 0 0

SDT PM2 1,556 0.043 0.32 0.59 1.7 361

SDT TRS1 0 0 0 0 0 0

SDT TRS2 2,066 0.058 0.42 0.79 2.2 479

Total for 

options selected

0 0 0 0 0 0

Note: Regulatory options selected for the NSPS review proposal appear in bold. 
17 

VI. References

BLS 2012 U.S. Bureau of Labor Statistics. May 2011 National Industry-Specific 

Occupational Employment and Wage Estimates: NAICS 322100 - Pulp, 

Paper, and Paperboard Mills. Available at 

http://www.bls.gov/oes/current/naics4_322100.htm. Accessed December

21, 2012. 

CE 2012 Chemical Engineering. Plant Cost Index. December 2012. 

EIA 2012 U.S. Energy Information Administration. Electric Power Monthly: Data 

for October 2012. Release Date: December 21, 2012. Table 5.6.B. 

Average Retail Price of Electricity to Ultimate Customers by End-Use 

Sector, by State, Year-to-Date through October 2012 and 2011 (Cents per 

Kilowatt-hour). Available at 

http://www.eia.gov/electricity/monthly/epm_table_grapher.cfm?t=epmt_5

_06_b. Accessed December 21, 2012. 

EPA 1996 U.S. Environmental Protection Agency. Technical Support Document: 

Chemical Recovery Combustion Sources At Kraft And Soda Pulp Mills. 

Publication No. EPA-453/R-96-012. October 1996. 

EPA 2002 U.S. Environmental Protection Agency. EPA Air Pollution Control Cost 

Manual. Sixth Edition. Publication No. EPA/452/B-02-001. January 2002. 

EPA 2012 Bradfield, J. and Spence, K., U.S. Environmental Protection Agency. 

Meeting Notes for the December 13, 2012 Meeting with AF&PA and 

NCASI. December 18, 2012. 

EPA 2013 U.S. Environmental Protection Agency. Supporting Statement: NSPS 

Review for Kraft Pulp Mills (40 CFR Part 60, Subpart BBa). May 2013. 

EPA 2013b Spence, K., U.S. Environmental Protection Agency. Review of the 

Continuous Emission Monitoring and Continuous Opacity Monitoring 

Data from the Pulp and Paper Information Collection Request Responses 

Pertaining to Subpart BB Sources. April 5, 2013. 

Green 1992 Green, R. and Hough, G. (eds.) Chemical Recovery in the Alkaline 

Pulping Process. Third Edition. Prepared by the Alkaline Pulping 

Committee of the Pulp Manufacture Division. Atlanta, GA, TAPPI Press. 

1992. 

NCASI 2004 Someshwar, A., NCASI. Compilation of Criteria Air Pollutant Emissions 

Data for Sources at Pulp and Paper Mills Including Boilers. National 

Council for Air and Stream Improvement. Technical Bulletin No. 884. 

August 2004. 
18 

NCASI 2010 Someshwar, A., NCASI. Compilation of ‘Air Toxic’ and Total 

Hydrocarbon Emissions Data for Pulp and Paper Mill Sources–A Second 

Update. National Council for Air and Stream Improvement. Technical 

Bulletin No. 973. February 2010. 

RISI 2012 RISI. Mill Asset Database. Query of database conducted August 2012. 

RockTenn 2012 Title V Air Operation Permit Renewal: RockTenn CP, LLC--Fernandina 

Beach Mill. Permit No. 0890003-031-AV. October 12, 2012. 

RTI 2012 Holloway, T., Hanks, K., and Gooden, C., RTI International. Costs, 

Environmental, and Energy Impacts for the Promulgated Subpart S Risk 

and Technology Review. Memorandum to U.S. Environmental Protection 

Agency. May 15, 2012. 

RTI 2013a Hanks, K., Holloway, T., and Gooden, C., RTI International. Projections 

of the Number of New, Modified, and Reconstructed Emission Units for 

the Kraft Pulp Mill NSPS Review. Memorandum to U.S. Environmental 

Protection Agency. February 4, 2013. 

RTI 2013b Hanks, K. and Holloway, T., RTI International. Technology Review and 

Regulatory Options for the Kraft Pulp Mill NSPS. Memorandum to U.S. 

Environmental Protection Agency. March 29, 2013. 

SmurfitStone 2008 Federal Operating Permit: SmurfitStone Container Enterprises, Inc.–West 

Point. Permit No. PRO40126. September 4, 2008. 
Appendix A 

Mill-specific Costs for the Mills Projected to be Impacted by Subpart BBa 

 Within 5 Years of the Applicability Date
AppA_Econ_Mill_Summary A-1

Appendix A. Summary of Costs for Economic Analysis

Baseline NSPS (BB)

RTI Code NEI ID Operator PysAddress PysCity PysST PysZip Pulp Processes

Small 

business

Emission Unit Changes Projected to 

be Impacted Capital, $ Annualized, $

130 NEI18338 Georgia-Pacific Brewton LLC 32224 U.S. Highway 31 Brewton AL 36426 Kraft Replace 2 small DCEs and associated 

SDTs with a single larger NDCE. 

Remove BLO.

 $ 3,054,086 $ 639,467 

132 NEI8261 Smurfit-Stone Container 

Corporation

North 8th Street Fernandina Beach FL 32034 Kraft, Secondary Modify NDCE and SDT $ 33,953,594 $ 7,029,671 

139 NEI42357 PORT TOWNSEND PAPER CORP 100 Mill Road Port Townsend WA 98368 Kraft, Secondary Yes Modify NDCE and SDT $ 25,598,954 $ 5,226,749 

140 NEI13340 Cascade Pacific Pulp, LLC 30480 American Dr Halsey OR 97348 Kraft Modify NDCE and SDT $ 32,572,651 $ 6,728,437 

145 NEI33135 Luke Paper Company 300 Pratt Street Luke MD 21540 Kraft Replace DCE with NDCE. Replace SDT. 

Reduce BLO throughput because 

would only serve 1 remaining DCE.

 $ 1,708,353 $ 349,262 

146 NEI759 MeadWestvaco of Virginia, Inc 104 East Riverside Street Covington VA 24426 Kraft Modify lime kiln $ 5,142,534 $ 1,068,938 

157 NEI33104 Lincoln Paper and Tissue, LLC 50 Katahdin Avenue Lincoln ME 04457 Kraft Yes Modify NDCE and SDT $ 23,746,939 $ 4,833,643 

173 NEI35908 International Paper Company 568 Shore Airport Road Ticonderoga NY 12883 Kraft Modify NDCE and SDT $ 26,992,308 $ 5,524,112 

206 NEI40282 Blue Ridge Holding Company 175 Main Street Canton NC 28716 Kraft Replace one lime kiln, and modify 

another lime kiln.

 $ 4,598,487 $ 951,940 

240 NEI26526 Rayonier Performance Fibers, 

LLC

4470 SAVANNAH HIGHWAY JESUP GA 31545 Kraft Modify NDCE and SDT $ 35,704,906 $ 7,413,473 

TOTAL $ 193,072,811 $ 39,765,691

1. The costs for SDT TRS 2 are based on the same scrubber costs as for SDT PM2. However, additional process changes for which not cost information is available may be needed for some mills to meet SDT TRS 2.
AppA_Econ_Mill_Summary A-2

RTI Code

130

132

139

140

145

146

157

173

206

240

RF PM1, LK PM1, SDT PM1, and SDT TRS 1 RF PM 2 LK PM2

Capital, $ Annualized, $ Incremental Capital, $

Incremental 

Annualized, $

Incremental 

emission 

reduction, tpy

Cost effectiveness, 

$/ton

Incremental 

Capital, $

Incremental 

Annualized, $

Incremental 

emission 

reduction, tpy

Cost effectiveness, 

$/ton

No impact No impact $ - $ - 0 

No impact No impact $ 4,535,955 $ 1,100,097 0 

No impact No impact $ 3,419,835 $ 796,752 99 $ 8,015 

No impact No impact $ 4,351,471 $ 1,048,745 0 

No impact No impact $ - $ - 0 

No impact No impact $ 985,274 $ 224,800 0.53 $ 427,642 

No impact No impact $ 3,172,419 $ 731,970 108 $ 6,809 

No impact No impact $ 3,605,977 $ 846,096 0 

No impact No impact $ 881,038 $ 198,071 26 $ 7,645 

No impact No impact $ 4,769,918 $ 1,165,887 0 

No impact No impact $ 23,855,575 $ 5,689,547 207 $ 27,497 $ 1,866,312 $ 422,871 $ 26 $ 15,997
AppA_Econ_Mill_Summary A-3

RTI Code

130

132

139

140

145

146

157

173

206

240

SDT PM2 SDT TRS21

Incremental 

Capital, $

Incremental 

Annualized, $

Incremental 

emission 

reduction, tpy

Cost effectiveness, 

$/ton

Incremental 

Capital, $

Incremental 

Annualized, $

Incremental 

emission 

reduction, tpy

Cost effectiveness, 

$/ton

 $ - $ - 0 $ 101,731 $ 42,308 4.2 $ 10,143 

 $ 93,019 $ 37,365 0 $ 93,019 $ 37,365 0 

 $ 70,131 $ 25,394 13 $ 1,908 $ 70,131 $ 25,394 0.7 $ 37,247 

 $ 89,236 $ 35,284 0 $ 89,236 $ 35,284 0 

 $ - $ - 0 $ 56,905 $ 19,191 0.05 $ 368,755 

 

 $ 65,057 $ 22,950 0 $ 65,057 $ 22,950 0.61 $ 37,520 

 $ 73,948 $ 27,285 15 $ 1,795 $ 73,948 $ 27,285 0 

 

 $ 97,817 $ 40,062 0 $ 97,817 $ 40,062 0 

$ 489,209 $ 188,341 29 $ 6,605 $ 647,845 $ 249,840 6 $ 45,289
AppA_Econ_Mill_Summary A-4

RTI Code

130

132

139

140

145

146

157

173

206

240

Repeat testing and monitoring costs Total Incremental Costs for Options Selected

Testing Capital, $

Testing 

Annualized, $

Monitoring 

Capital, $

Monitoring 

Annualized, $

Reporting and 

recordkeeping costs, 

capital $

Reporting and 

recordkeeping costs, 

annual $ Capital, $ Annualized, $

 $ 19,600 $ 4,780 $ 31,000 $ 11,760 $ 5,040 $ 21,514 $ 55,640 $ 38,054 

 $ 19,600 $ 4,780 $ 31,000 $ 11,760 $ 5,040 $ 21,514 $ 55,640 $ 38,054 

 $ 19,600 $ 4,780 $ 31,000 $ 11,760 $ 5,040 $ 21,514 $ 55,640 $ 38,054 

 $ 19,600 $ 4,780 $ 31,000 $ 11,760 $ 5,040 $ 21,514 $ 55,640 $ 38,054 

 $ 19,600 $ 4,780 $ 31,000 $ 11,760 $ 5,040 $ 21,514 $ 55,640 $ 38,054 

 $ 9,800 $ 2,390 $ 31,000 $ 11,760 $ 5,040 $ 21,514 $ 45,840 $ 35,664 

 $ 19,600 $ 4,780 $ 31,000 $ 11,760 $ 5,040 $ 21,514 $ 55,640 $ 38,054 

 $ 19,600 $ 4,780 $ 31,000 $ 11,760 $ 5,040 $ 21,514 $ 55,640 $ 38,054 

 $ 19,600 $ 4,780 $ 62,000 $ 23,520 $ 5,040 $ 21,514 $ 86,640 $ 49,814 

 $ 19,600 $ 4,780 $ 31,000 $ 11,760 $ 5,040 $ 21,514 $ 55,640 $ 38,054 

$ 186,200 $ 45,412 $ 341,000 $ 129,360 $ 50,400 $ 215,140 $ 577,600 $ 389,912
Appendix B 

Model Control Costs 
Appendix B. Model Baseline and NSPS Control Costs for NSPS Regulatory Options (2012 Dollars) 

Equipment Design size Baseline/ NSPS control

Total 

capital cost 

Annual cost, $/yr

Labor

Maintenance & 

materials Electricity

Equipment 

testing Overhead

Admin., 

taxes, ins.

Capital 

recovery Total

NDCE 

recovery 

furnace

3.7 MM lb 

BLS/d

Baseline: ESP designed 

to meet 0.044 gr/dscf

$37,462,787 $28,966 $1,311,198 $800,378 $5,000 $804,099 $1,498,511 $4,113,213 $8,562,367

NSPS option: ESP 

designed to meet 0.015 

gr/dscf

$42,916,055 $28,966 $1,502,062 $1,143,398 $5,000 $918,618 $1,716,642 $4,711,952 $10,027,640

SDT 3.7 MM lb 

BLS/d

Baseline: Scrubber 

designed to meet 0.2 lb 

PM/ton BLS and 0.033 

lb TRS/ton BLS

$3,357,299 $14,483 $67,146 $113,438 $5,000 $48,978 $134,292 $368,613 $752,952

NSPS option: Scrubber 

designed to meet 0.12 lb 

PM/ton BLS and 0.0168 

lb TRS/ton BLS1

$3,469,129 $14,483 $69,383 $142,608 $5,000 $50,320 $138,765 $380,892 $802,452

Lime 

kiln

240 ton 

CaO/d

Baseline: ESP designed 

to meet 0.064 gr/dscf

$4,121,983 $21,725 $123,660 $74,043 $5,000 $87,231 $164,879 $452,572 $930,110

NSPS option: ESP 

designed to meet 0.010 

gr/dscf

$4,911,727 $21,725 $147,352 $105,775 $5,000 $101,447 $196,469 $539,281 $1,118,050

1. In some site-specific circumstances process changes may be required in addition to wet scrubbing to reduce TRS emissions to 0.0168 lb/ton BLS. No cost 

information is available for process changes that could reduce TRS emissions from SDTs, so the costs of reducing the SDT TRS limit were estimated on the 

same basis as for reducing the SDT PM limit (i.e., wet scrubber replacement).
Appendix C 

Exploration of Additional Cost-Effectiveness Scenarios for

Recovery Furnaces, SDTs and Lime Kilns and Trigger NSPS through Modification 
Appendix C

Exploration of Additional Cost-Effectiveness Scenarios for

Recovery Furnaces, SDTs and Lime Kilns and Trigger NSPS through Modification 

The baseline costs presented in the body of this memorandum assume that modified 

emission units are some of the older units in the industry, and likewise operate with control 

devices at the end of their useful life such that a new control device would be expected to be 

installed if the emission unit is modified. Representatives of the pulp and paper industry have 

questioned this assumption, and reported that some modifications of NSPS emission sources may 

occur as a result of mills consolidating production through one relatively modern emission unit 

in order to retire an aging emission unit. For example, a mill may increase production through a 

newer recovery furnace (a modification, as defined under the General Provisions for NSPS) in 

order to cease operation of an older recovery furnace. Similarly, a mill might consolidate lime 

production into one modified lime kiln. The recovery furnace or lime kiln being modified to 

increase production would likely already be subject to the current NSPS limit in subpart BB and 

existing source MACT limit for PM in subpart MM (0.044 gr/dscf at 8 percent O2 for recovery 

furnaces, and 0.064 gr/dscf at 10 percent O2 for lime kilns) but would not trigger the new source 

MACT PM limit upon modification. Therefore, a revised NSPS limit established at the level of 

the new source MACT limit could have an impact on the modified source. Industry 

representatives expressed concern that the cost effectiveness of this scenario could be somewhat 

different (e.g., higher) than estimated using the approach described in the main body of this 

memorandum (where projected modifications were assigned to older emission units based on 

their age).

Because we have no way to predict which mills and emission units might consolidate 

production by modifying a modern emission unit, we analyzed this scenario for model recovery 

furnaces and lime kilns based on the average unit capacity and relation of flow rate to capacity 

derived from ICR results and an assumption that a modern unit’s throughput would be increased 

by 25% to accommodate additional throughput.1

 Costs from BE&K 2001 were scaled to 2012 

dollars and adjusted for production rate to estimate the cost difference under the following 

control device upgrade scenarios. 

NDCE1: Adding two parallel fields to upgrade an NDCE recovery furnace ESP to 

compensate for the increased gas flow and continue to meet 0.044 gr/dscf (baseline for 

modification), versus a more costly ESP modification to meet 0.015 gr/dscf (an NSPS 

review option for modification) 

NDCE2: No NDCE recovery furnace ESP upgrade needed to continue to meet 0.044 

gr/dscf upon modification due to sufficient ESP collection area and compliance margin 

with the current control system (baseline), versus adding two parallel fields to upgrade 

the NDCE recovery furnace ESP to meet 0.015 gr/dscf (an NSPS review option for 

modification) 

LK1: No lime kiln ESP upgrade needed to continue to meet 0.064 gr/dscf upon kiln 

modification due to sufficient ESP collection area and compliance margin with the 

 

1 Our approach was tested with larger increases in throughput, and we found that assumptions of increased 

throughput greater than 25 percent decreased the cost per ton of emissions reduced.

C-1
current control system (baseline), versus adding a single new field to upgrade the kiln 

ESP to meet 0.010 gr/dscf (an NSPS review option for modification) 

Table C1 summarizes the cost effectiveness values calculated under these scenarios. The 

detailed analysis is presented below the table. The cost effectiveness values were all less than 

$10,000 per ton of PM reduced. 

Table C1. Summary of Annualized Costs and Cost Effectiveness Values Estimated for 

Modern Recovery Furnace and Lime Kiln Modifications

Scenario

Baseline 

capacity 

(gas flow 

dscfm)

Modified 

capacity 

(gas flow 

dscfm)

Baseline 

annualized 

cost for 

modified 

ESP that 

meets 

current 

limits, $/yr1

Revised 

NSPS 

option 

annualized 

cost for 

modified 

ESP, $/yr2

Incremental 

cost, $/yr

Incremental 

PM 

reduction of 

revised NSPS 

option, tpy

Cost 

effectiveness, 

$/ton

NDCE1 3.2 MMlb 

BLS/day 

(174,130)

4.0 MMlb 

BLS/day 

(217,662)

$1,392K $1,646K $253K 237 tpy $1,070/ton

NDCE2 $0 $1,646K $1,646K $6,940/ton

LK1 300 ton 

CaO/day 

(23,703)

375 ton 

CaO/day 

(29,629)

$0 $523K $523K 60 tpy $8,700/ton

1. The currently applicable existing source limits are 0.044 gr/dscf for recovery furnaces and 0.064 gr/dscf for lime 

kilns.

2. The revised NSPS limit options under consideration are 0.015 gr/dscf for recovery furnaces and 0.010 gr/dscf for 

lime kilns.

C-2
Scenario NDCE1: Suppose a mill modifies (increases capacity) of an NDCE in order to retire an older RF.

The modified NDCE would add fields to the ESP designed to meet 0.044 gr/dscf to compensate for the increased gas flow rate while still meeting 0.044 gr/dscf.

If the revised NSPS was 0.015 gr/dscf for modified units, then a more costly modification to the ESP would be required to meet 0.015.

Baseline NDCE capacity (MM lb BLS/day) 3.2

Average MMlb BLS/day for NDCEs in baseline sheet (see

BLS_flow_eqn tab)

Baseline NDCE flow rate 174130 dscfm = 31359 (MM lb BLS/day) + 73781. See BLS_flow_eqn tab

Assumed capacity increase upon modification: 0.25 25%

Modified NDCE capacity (MM lb BLS/day) 4.0 25% capacity increase

Modified NDCE flow rate, dscfm 217662 Assumed increase is proportional to capacity increase

Baseline ESP upgrade costs to meet 0.044 gr/dscf

Baseline total installed costs (2012$) $ 6,903,992

Updated BE&K cost (2012$) of $6,588,481 with 6/10 rule applied. You can adapt capital costs to each size unit using the 6/10 cost rule: C1/C2 = (Q1/Q2)^0.6. e.g., C1 = C2*(Q1/Q2)^0.6 where Q is the capacity parameter (e.g., BLS firing rate, lime production rate)

Baseline annualized costs (2012$)

2001 Labor, $/yr $13,333

Maintenance & Materials $/yr $89,984Electricity, $/yr $80,850Fuel, $/yr $0Water, wastewater, solid waste, steam & compressed air, $/yr $0Equipment Testing, $/yr $5,000Total, $/yr $189,167

2012 Labor, $/yr $14,483 Labor rate updated to 2012

Maintenance & Materials $/yr $138,080 BE&K M&M was 2% of TIC

Electricity, $/yr $108,824 Electricity costs of $0.05 updated to $0.0673

Fuel, $/yr $0Water, wastewater, solid waste, steam & compressed air, $/yr $0

Equipment Testing, $/yr $5,000

Overhead, $/yr $91,538 60% of labor and maintenance & materials

Admin, taxes, insurance, $/yr $276,160 4% of TIC

Capital recovery, $/yr $758,021 =(0.07*(1+0.07)^15)/((1+0.07)^15‐1)*TIC

Total, $/yr $1,392,106

NSPS Option ESP upgrade costs to meet 0.015 gr/dscfNSPS option total installed costs (2012$) $ 8,243,911

Updated BE&K cost (2012$) of $6,588,481 with 6/10 rule applied. You can adapt capital costs to each size unit using the 6/10 cost rule: C1/C2 = (Q1/Q2)^0.6. e.g., C1 = C2*(Q1/Q2)^0.6 where Q is the capacity parameter (e.g., BLS firing rate, lime production rate)

NSPS option annualized costs (2012$)

2001 Labor, $/yr $13,333

Maintenance & Materials $/yr $107,448Electricity, $/yr $88,200Fuel, $/yr $0Water, wastewater, solid waste, steam & compressed air, $/yr $0Equipment Testing, $/yr $5,000Total, $/yr $213,981

2012 Labor, $/yr $14,483 Labor rate updated to 2012

Maintenance & Materials $/yr $164,878 BE&K M&M was 2% of TIC

Generic_mod, p. 1 

C-3
Electricity, $/yr $118,717 Electricity costs of $0.05 updated to $0.0673

Fuel, $/yr $0Water, wastewater, solid waste, steam & compressed air, $/yr $0

Equipment Testing, $/yr $5,000

Overhead, $/yr $107,617 60% of labor and maintenance & materials

Admin, taxes, insurance, $/yr $329,756 4% of TIC

Capital recovery, $/yr $905,137 =(0.07*(1+0.07)^15)/((1+0.07)^15‐1)*TIC

Total, $/yr $1,645,589Cost difference to meet 0.015 $253,483Emissions reduction, tpy 237

=(0.044‐0.015) gr/dscf x (modified dscfm) / (7000 gr/lb) x (60

min/hr) x (8760 hr/yr) / (2000 lb/ton)

Cost effectiveness, $/ton $1,070

Scenario NDCE2: Alternatively, if assume current control requires no expansion to meet 0.044:

Cost difference to meet 0.015 $1,645,589

Emissions reduction, tpy 237

Cost effectiveness, $/ton $6,944

Generic_mod, p. 2 

C-4
Scenario LK1: Suppose a mill modifies (increases capacity) of a lime kiln in order to retire an older lime kiln.

The modified kiln would likely add fields to the ESP designed to meet 0.064 gr/dscf to compensate for the increased gas flow rate while still meeting 0.064 gr/dscf.

However, we will assume that the ESP currently has enough excess collection area and compliance margin beneath the 0.064 gr/dscf PM limit to handle the increased flow.

If the revised NSPS was 0.010 gr/dscf for modified units, then a costly modification to the ESP would be required to meet 0.010.

Baseline kiln capacity (MM lb BLS/day) 300

Average ton CaO/day for lime kilns in baseline sheet (see

LK_flow_eqn tab)

Baseline kiln flow rate 23703 dscfm = 53.397 (ton CaO/day) + 7683.9. See LK_flow_eqn tab

Assumed capicity increase upon modification: 0.25 25%Modified kiln capacity (MM lb BLS/day) 375 25% capacity increaseModified kiln flow rate, dscfm 29629 Assumed increase is proportional to capacity increase

Baseline ESP upgrade costs to meet 0.064 gr/dscf

Baseline total installed costs (2012$) $ ‐

Assumed the lime kiln ESP has the capacity and PM compliance margin to handle the aditional flow to meet 0.064 gr/dscf

Baseline annualized costs (2012$) $ ‐

NSPS Option ESP upgrade costs to meet 0.010 gr/dscf

NSPS option total installed costs (2012$) $ 2,438,972

Updated BE&K cost (2012$) of $1,866,014 with 6/10 rule applied. You can adapt capital costs to each size unit using the 6/10 cost rule: C1/C2 = (Q1/Q2)^0.6. e.g., C1 = C2*(Q1/Q2)^0.6 where Q is the capacity parameter (e.g., BLS firing rate, lime production rate)

NSPS option annualized costs (2012$)

2001 Labor, $/yr $19,999

Maintenance & Materials $/yr $12,743Electricity, $/yr $29,400Fuel, $/yr $0Water, wastewater, solid waste, steam & compressed air, $/yr $0Equipment Testing, $/yr $5,000Total, $/yr $67,142

2012 Labor, $/yr $21,725 Labor rate updated to 2012

Maintenance & Materials $/yr $48,779 BE&K M&M was 2% of TIC

Electricity, $/yr $39,572 Electricity costs of $0.05 updated to $0.0673

Fuel, $/yr $0Water, wastewater, solid waste, steam & compressed air, $/yr $0

Equipment Testing, $/yr $5,000

Overhead, $/yr $42,302 60% of labor and maintenance & materials

Admin, taxes, insur, $/yr $97,559 4% of TIC

Capital recovery, $/yr $267,786 =(0.07*(1+0.07)^15)/((1+0.07)^15‐1)*TIC

Total, $/yr $522,724Cost difference to meet 0.010 $522,724Emissions reduction, tpy 60

=(0.064‐0.010) gr/dscf x (modified dscfm) / (7000 gr/lb) x (60

min/hr) x (8760 hr/yr) / (2000 lb/ton)

Cost effectiveness, $/ton $8,702

Generic_mod, p. 3 

C-5
The affected industry developed cost estimates for various scenarios for smelt dissolving 

tanks and lime kilns. The cost estimates pertaining to regulatory options under consideration by 

EPA are summarized in Table C2 below.2 The highest cost effectiveness of any the scenarios 

reported in the industry analysis for SDTs was approximately $30,000 per ton of PM reduced 

which is higher than the cost effectiveness value of approximately $6,600 reported in Table 4 in 

the main body of this memorandum. For lime kilns, the maximum cost effectiveness was 

reported in the industry analysis to be $16,000 per ton PM reduced, the same as the costeffectiveness value for lime kilns presented in Table 4 of this memorandum. 

Table C2. Summary of Relevant Costs from AF&PA’s Cost-Effectiveness Analysis of the of 

Lowering the NSPS Subpart BB PM Emissions for SDTs and Lime Kilns2

Scenario Description

Small emission 

unit1, $/ton PM 

reduced

Large emission 

unit1, $/ton PM 

reduced

SDTs

1 Modified or reconstructed SDT has 

scrubber that would not need replacing in 

absence of revised NSPS PM limit of 0.12 

lb/ton BLS. Additional annualized costs are 

for capital recovery and increased 

operational costs for the new scrubber.

$29,854 $23,867

22 Modified or reconstructed SDT with 

scrubber in need of replacement. The new 

scrubber must meet a revised NSPS PM 

limit of 0.12 lb/ton BLS. Additional 

annualized costs are the increased 

operational costs for the new scrubber.

$1,441 $1,158

3a New or reconstructed SDT that does not 

trigger new source MACT; needs new 

scrubber

same as 2

3b New or reconstructed SDT that does not 

trigger new source MACT; has scrubber 

that would not need replacing in absence of 

revised NSPS PM limit of 0.12 lb/ton BLS

same as 1

4 New/rec SDT that triggers new source 

MACT

no cost associated with NSPS

Lime Kilns

1 Modified kiln has scrubber that would have 

sufficed in absence of revised NSPS PM 

limit of 0.010 gr/dscf. Additional 

annualized costs are for installation of an 

ESP in front of the scrubber.

$15,678 $12,207

 

2 Spence, K., U.S. Environmental Protection Agency. Meeting Notes for the March 14, 2013 Meeting with AF&PA 

and NCASI. March 26, 2013. 

C-6
Scenario Description

Small emission 

unit1, $/ton PM 

reduced

Large emission 

unit1, $/ton PM 

reduced

22 Modified kiln has scrubber in need of 

replacement. Additional annualized costs 

are for installation of an ESP to meet the 

revised NSPS PM limit of 0.010 gr/dscf.

$13,831 $10,768

3 Modified kiln has ESP or ESP/scrubber 

combination that would have sufficed in 

absence of revised NSPS PM limit of 0.010 

gr/dscf. Additional annualized costs are for 

an ESP upgrade.

$14,379 $11,268

4 New kiln that triggers new source MACT no cost associated with NSPS

1. Small SDT = 40 tons BLS/hr, Large SDT = 70 tons BLS/hr, Small lime kiln = 20,000 dscfm, 

large lime kiln = 40,000 dscfm 

2. The AF&PA analysis states that this scenario would be less likely to occur, as a facility would 

be more likely to upgrade newer equipment that already complies with the NSPS limit rather 

than older equipment that does not. 

In addition to considering the industry’s analysis, using the model costs from Appendix B 

of this memorandum, we also tested the effects on the cost analysis of assuming that modified 

units would require a new control device in the absence of lower limits under the NSPS review. 

We considered the incremental annualized costs of new recovery furnace and lime kiln ESPs and 

SDT scrubbers. If a new control would not have been required to meet the baseline standard 

(subpart BB or subpart MM existing source MACT), the incremental costs between baseline and 

the NSPS option are the full capital and capital recovery costs of a new control system (as 

opposed to incremental capital costs), plus the incremental difference in operating costs for the 

baseline and NSPS option systems. The additional costs for model emission units are shown in 

yellow in Table C3 below and the cost effectiveness values are shown in the calculations 

thereafter. The cost-effectiveness values were approximately $27,000 per ton PM removed for 

recovery furnaces, $15,400/ton PM for lime kilns, and $15,500/ton PM for SDTs. A cost 

effectiveness for TRS emissions from SDTs was estimated to be $76,400 per ton TRS removed if 

a new scrubber were required (but would not have been required in the absence of revised 

NSPS).

C-7
Table C3. Model Baseline and NSPS Control Costs for NSPS Regulatory Options (2012 Dollars)

Equipment Design size Total capital 

cost Labor Maintenance & materials Electricity Equip-ment testing Overhead Admin., taxes, ins.

Capital 

recovery

Total

Baseline: ESP designed to meet 0.044 

gr/dscf $37,462,787 $28,966 $1,311,198 $800,378 $5,000 $804,099 $1,498,511 $4,113,213 $8,562,367 

NSPS option: ESP designed to meet 

0.015 gr/dscf $42,916,055 $28,966 $1,502,062 $1,143,398 $5,000 $918,618 $1,716,642 $4,711,952 $10,027,640 

Difference in costs if new ESP would 

not have been required to meet 

baseline2

$42,916,055 $0 $190,864 $343,020 $0 $114,519 $218,131 $4,711,952 $5,578,486 

Baseline: Scrubber designed to meet 

0.2 lb PM/ton BLS and 0.033 lb TRS/ton 

BLS

$3,357,299 $14,483 $67,146 $113,438 $5,000 $48,978 $134,292 $368,613 $752,952 

NSPS option: Scrubber designed to 

meet 0.12 lb PM/ton BLS and 0.0168 lb 

TRS/ton BLS1

$3,469,129 $14,483 $69,383 $142,608 $5,000 $50,320 $138,765 $380,892 $802,452 

Difference in costs if new scrubber 

would not have been required to meet 

baseline2

$3,469,129 $0 $2,237 $29,170 $0 $1,342 $4,473 $380,892 $418,114 

Baseline: ESP designed to meet 0.064 

gr/dscf $4,121,983 $21,725 $123,660 $74,043 $5,000 $87,231 $164,879 $452,572 $930,110 

NSPS option: ESP designed to meet 

0.010 gr/dscf $4,911,727 $21,725 $147,352 $105,775 $5,000 $101,447 $196,469 $539,281 $1,118,050 

Difference in costs if new ESP would 

not have been required to meet 

baseline2

$4,911,727 $0 $23,692 $31,732 $0 $14,216 $31,590 $539,281 $640,511 

1. In some site-specific circumstances process changes may be required in addition to wet scrubbing to reduce TRS emissions to 0.0168 lb/ton BLS. 

 No cost information is available for process changes that could reduce TRS emissions from SDTs, so the costs of reducing the SDT TRS limit were estimated 

 on the same basis as for reducing the SDT PM limit (i.e., wet scrubber replacement).

2. If a new control would not have been required to meet baseline, the incremental costs between baseline and the NSPS option are the full capital and capital recovery costs 

 of a new control system (as opposed to incremental capital costs), plus the incremental difference in operating costs for the baseline and NSPS option systems.

Lime kiln 240 ton CaO/d

Baseline/ NSPS control

Annual cost, $/yr

SDT

NDCE recovery furnace 3.7 MM lb 

BLS/d

3.7 MM lb 

BLS/d

C-8
Model Cost Effectiveness Values if a New APCD is Not Assumed as the Baseline for Sources Triggering NSPS

Recovery Furnace PM:

gr/dscf ton/yr PM

Reduction 

from 

baseline, tpy

Annualized cost, 

$

Cost effectiveness, 

$/ton

Baseline 0.044 314

NSPS option 0.015 107 207 $ 5,578,486 26,994

 189,809 dscfm = 31359 (3.7 MM lb BLS/day) + 73781. See BLS_flow_eqn tab

Lime Kiln PM:

gr/dscf ton/yr PM

Reduction 

from 

baseline, tpy

Annualized cost, 

$

Cost effectiveness, 

$/ton

Baseline 0.064 49

NSPS option 0.01 8 42 $ 640,511 15,412

 20,499 dscfm = 53.397 (240 ton CaO/day) + 7683.9. See LK_flow_eqn tab

SDT PM and TRS:

TRS, lb as 

H2S/ton BLS ton/yr TRS

Reduction 

from 0.033

Annualized cost, 

$

Cost effectiveness, 

$/ton

Baseline 0.033 11

NSPS option 0.0168 6 5 $ 418,114 76,444

PM, lb/ton 

BLS ton/yr PM

Reduction 

from 0.2

Cost 

effectiveness @ 

$10,000

Cost effectiveness 

@ $1M

Baseline 0.2 68

NSPS option 0.12 41 27 $ 418,114 15,480

3.7 Model SDT BLS (MMlb/day)

 675,250 Avg SDT BLS (ton BLS/yr)

C-9
ICR data were used to derive the following relations between recovery furnace and lime kiln 

capacity and gas flow rate (dscfm). 

C-10
Appendix D 

Emission Factors Used In Impact Calculations 
Appendix D. Emission Factors Used to Estimate Secondary Air Emissions

Emissionfactors Value Units Fuel % of generation 

1.9 lb/MM ft3 natural gas Coal 53%

0.00186275 lb/MMBtu natural gas Oil/natural gas 21%

0.03 lb/MMBtu solid, liquid, gaseous fuel Nuclear 17% No s

84 lb/MM ft3 natural gas Hydroelectric 6% No s

0.0824 lb/MMBtu natural gas Renewable 2% No s

0.19 lb/MMBtu solid fuel Other 1% Assu

100 lb/MM ft3 natural gas Notes:

0.0980 lb/MMBtu natural gas 1. Assume electricity generated using the above m

0.38 lb/MMBtu solid fuel for the year 2015).

0.6 lb/MM ft3 natural gas 2. IPM = EPA Integrated Planning Model, which is 

0.00059 lb/MMBtu natural gas determinisƟc linear programmingmodel of the U.

1.2 lb/MMBtu solid fuel provides forecasts of least‐ cost capacity expansio

53.02 kg/MMBtu natural gas emission control strategies for meeting energy de

93.4 kg/MMBtu solid fuel transmission, dispatch, and reliability constraints.

0.001 kg/MMBtu natural gas

0.011 kg/MMBtu solid fuel

0.0001 kg/MMBtu natural gas Conversion factors Units

0.0016 kg/MMBtu solid fuel 3415.179 Btu/kWh

Notes: 2.204623 lb/kg

1. For natural gas combustion, used AP‐42 emission factors for PM, CO, NOx, and SO2, 1,020 Btu/ft3 natural gas

and used 40 CFR part 98, subpart C emission factors for CO2, CH4, and N2O. 13,000 Btu/lb coal

Assumed 1,020 Btu/ft3 of natural gas in estimating secondary emissions

2. For solid fuel combustion, used NSPS emission factors for PM and SO2 (40 CFR part 60, Global Warming Potentials

subpart Da, coal‐fired utility plants), used AP‐42 emission factors for NOx and CO CH4 21

(bituminuous/subbituminous coal combustion/spreader stoker). The NOx emission N2O 310

factor was based on average of NOx emission factors for spreader stoker type boilers

burning bituminous (11 lb/ton) and subbituminous (8.8 lb/ton) coal. Assumed 13,000Btu/lb of coal in estimating NOx and CO secondary emissions. Used 40 CFR part 98,subpart C emission factors for CO2 (bituminous coal) and CH4 and N2O (coal/coke).

3. The 40 CFR Part 98 emission factors and global warming potentials are current as of January 30, 2012

CO

PM

N2O

CO2

CH4

NOX

SO2

D1
Median Mean Units

TB 884 Table 4.10 Black liquor oxidation unit TPM 0.0049 0.0049 lb/ton BLS

TB 884 Table 4.11 DCE recovery furnace TPM 0.70 0.74 lb/ton BLS

TB 884 Table 4.12 NDCE recovery furnace TPM 0.37 0.65 lb/ton BLS

TB 884 Table 4.13 Lime kiln with ESP TPM 0.089 0.175 lb/ton CaO

TB 884 Table 4.13 Lime kiln with wet scrubber TPM 1.16 1.59 lb/ton CaO

TB 884 Table 4.15 Smelt dissolving tank TPM 0.15 0.16 lb/ton BLS

TB 973 Table 4.20 Black liquor oxidation unit TRS as S 0.0612 0.0584 lb/ton BLS

TB 973 Table 4.21 DCE recovery furnace TRS as S 0.0932 0.146 lb/ton BLS

TB 973 Table 4.23 NDCE recovery furnace TRS as S 0.0259 0.0396 lb/ton BLS

TB 973 Table 4.25 Lime kiln TRS as S 0.0561 0.0796 lb/ton CaO

TB 973 Table 4.28 Smelt dissolving tank TRS as S 0.0187 0.0201 lb/ton BLS

TB 849 Table 20 Saltcake mix tank TRS as S 0.0001 0.0022 lb/ton BLS

Note:

1. "TPM" is total filterable particulate matter.

2. "TRS as S" is total reduced sulfur expressed as sulfur.

Emission factor

Emission unit Pollutant

TB table

no.

NCASI Technical

Bulletin (TB)

D2
Appendix E 

Emissions Inventory and Detailed Unit-by-Unit Impact Analysis