### 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: K elley 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 exi sting 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 AirW atchers 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 , specify ing 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 reduce d sulfur (TRS) compounds from new,

modified, and reconstructed digester s, brown stock washers, multiple- effect evaporators,

condensate stripper s, 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 (H 2 

### S), methyl mercaptan (CH 4 

### S)

, dimethyl sulfide ((CH 3 

### ) 2 

### S) , and dimethyl disulfide ((CH 3 

### ) 2 

### S 2 

### ).

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 emiss ions 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 impac ts associated with the NSPS review.

### 2 II. Emissions Inventory for the NSPS Review

A. Organization of the Inventory

The first step was to s et up an inventory o f all U.S. kraft pulp mills , including those kraft

mills co

- located with other types of pulping processe s (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 II I of a three

- part information collection request

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

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 revie w).

D igesters, 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, kra ft/semichemical, kraft/mechanical,

kraft/secondary;

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

• Year installed;

• Operating hours;

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

(exhaust gas temp erature, moisture content);

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

etc.;

• W hether 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);

• B lack liquor solids firing rate ;

• Lime production rate ; and

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

In some ca ses, 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). D ata 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 an d 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 e missions data from EPA’s National Emissions Inventory (NEI);

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

furnaces;

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

• PM and TRS e missions 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 da ta in the NEI are presented in a variety of formats (TRS, TRS as H 2 

### S, TRS as

sulfur); and

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

(H 2 

### S, CH 4 

### S, (CH 3 

### ) 2 

### S, and/or (CH 3 

### ) 2 

### S 2 

### ), which provides an incomplete picture of the

ove rall 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 em ission 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 ;

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

• E mission fa ctor —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

SD Ts 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 s um 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 ti tle 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, SmurfitSton e

2008, RockTenn 2012, NCASI 2010 ) Th e BLS firing rates for recovery furnace s 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 furn ace

at that mi ll and vice versa

.

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

emission factors :

### 5 Equation 1—Current emissions from r ecovery furnaces/BLO units/SDTs:

A nnual emissions (t py PM or TRS ) = emission factor (lb PM or TRS/ton BL S) * (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 l ime kilns:

A nnual emissions (t py 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)



### T o determine the current nationwide emissions for each emission unit type , the emissions

estimated based on performance data and e missions 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 Natio nwide Emissions for Recovery F urnaces

(and A ssociated BLO Units ) , SDTs, and Lime Kilns

Emission unit E missions, tpy

PM TRS

Recovery furnaces 12,916 2,328

NDCE recovery furnaces 10,1 97 1,248

DCE recovery furnaces 2,719 1,080

BLO units 32 411

S DTs 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 N SPS review (s ubpart BBa) Incremental c ost 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. C o sts 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 c ost 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 ch ange to ppm limit. 3

35% opacity with 6% allowance RF Opac: D ecrease 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. N o new control or opacity

monitoring cost. 3 Added cost for

parameter monitoring for compliance

purposes.

Lime kiln Venturi scrubber with 30 in. H 2 O

pressure drop meeting 0.066

gr/dscf for gas

- fired kilns, 0.13

gr/dscf for oil

- fi red 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 m odified 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 caus tic 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. N o 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 N SPS review (s ubpart BBa) Incremental c ost basis

Smelt

dissolving

tank Wet scru bber 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 NSP S 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

mod ified 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 H 2 S SDT TRS 1 : Maintain cu rrent 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 i nstallation) 5

1. Concentration limits for recovery furnaces are at 8 percent oxygen ( O 2 ) , while concentration limits for lime kilns are at 10 percent O 2

. 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 S ectio n

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 reconstruct ed 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 incrementa l 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, modif ied, or reconstructed sources is provided in a

separate memorandum . (RTI 2013a) A total of 10 mills are pr oje cted 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

C osts 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 estimat ed to be impacted . Inc remental costs were determined as the NSPS option

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

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

Mo del 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 t his 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 201 2 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 Oc tober 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 administra tive 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 doll ars 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 emissi on 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)



### Be cause 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 ratioin g 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

. On ce 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 S ection B below .) The costs and cost effectiveness were estima ted 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

T he 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 s ubpart 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. T he 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

- y ear payment period.

3. E SP 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 $3 1,000 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 in itial 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 in clude costs associated with two instances of affirmative

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

with TRS upper limit caps and /or adjusted allowances

. Details on these cost estimates, as well as

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

the supporting statement for s ubpart BBa . (EPA 2013)

Table 3. Incremental R&R C osts for I nclusion in the C ost Impact A nalysis

Labor cost item Incremental

R&R costs,

$/m ill Incremental R&R

labor hours per

mill

Initial labor costs

ERT

. Initial during 5

- year impact period, and once every 5 years

thereafter. $5 40 5

Time to adjust existing data acquisition systems at modified sources to

include startup and shutdown perio ds 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

Affir mative defense cost $6,750 60

ESP parameter monitoring labor $10,26 4 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 Emission s and Emissions Reductions

As described in S ection 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 associate d 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 s ubpart 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 s tringent that the current NSPS s ubpart BB standards, emission sources are already

required t o 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 emission s reductions would be obtained under each NSPS review control option 1

because these options a re 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

t he baseline emissions

. The emission s 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 basel ine (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 liquo r 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 ( dscf m) * ( 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:

Reg ulatory 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 con tent:

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 % H 2 O – exhaust gas moisture content (% H 2 O) ) /(100 % H 2 O – 0 % H 2 O)



### 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 I mpacts

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) T he 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 A ir E missions

On ce the incremental energy impacts were determined , the associated incremental

secondary air emissions were estimated

. Se condary emissions typically include the criteria air

pollutant emissions —PM, carbon monoxide (CO), nitrogen oxides (NO X 

### ), and sulfur dio xide

(SO 2 

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

purposes of this analysis, t he electricity was assumed to be purchased from offsite utilities, rather

### 13 than generated onsite. S econdary emissions estimates were also developed for the greenhouse

gases carbon dioxide (CO 2 

### ), methane (CH 4 

### ), and nitrous oxide (N 2 

### O) that are expected to be

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

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

specific mix of fuels to g enerate the needed electricity.

Equation 8

-- Incremental s econdary emissions (PM, CO, NO X 

### , SO 2 

### ):

Incremental secondary emissions (tpy PM, CO, NO X , or SO 2 ) = incremental ene rgy 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 s econdary e missions (CO 2 

### , CH 4 

### , N 2 

### O):

Incremental secondary emissions (tpy CO 2 , CH 4 , N 2 O) = 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

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



### Global warming potentials of 1 for CO 2 

### , 21 for CH 4 

### , and 310 for N 2 

### O were used to estimate CO 2 

### equivalent emissions (CO 2 

### eq). Appendix D of this memorandum provides the emission fact ors

used in impact calculations . Additional d etails 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 W aste and Wa stewater I mpacts

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 exi sting 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 Na 2 

### SO 4 

### (i.e., saltcake) and Na 2 

### CO 3 

### . 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 i s

assumed to have su fficient capacity to absorb the additional PM resulting fr om 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 catc h resulting from

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

expected with option LK PM 2.

Option SDT PM 2 would require mills to i ncreas e 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 c ontrol SDTs from the current NSPS TRS limit of 0.033 lb/ton BLS to a

re vised NSPS limi t of 0.0168 lb/ton BLS . As with the costs, the impacts of option SDT TRS 2

were estimated on the same basis as o ption 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 th e 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. Sum mary 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

Ap pendix 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 sm all 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 Cos t Effectiveness of the NSPS

Review Regulatory Options (2012 dollars)

Regulatory

o ption Mills

affected Baseline control c osts Incremental c ontrol c osts for

NSPS review o ption Incremental

e mission s

r eduction,

tpy Cost

effectiveness,

$/ton Capital,

$ M Annu alized,

$ M Capital, $ M Annualized, $ M

Particulate m atter 1



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

RF PM2 2 n ew

6 mod $0 new

$ 23.9 mod $0 new

$ 5.69 mod 207

(93 PM 2.5 

### ) $27,500

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

LK PM2 1 new

2 mod 3 

### $0 new

$1.87 mod $0 ne w

$ 0.423 mod 26

(11 PM 2.5 

### ) $16,000

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

SDT PM2 2 new

6 mod 4 

### $0 new

$ 0.489 mod $0 new

$ 0.188 mod 29

(24 PM 2.5 

### ) $ 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

Othe r incremental c osts

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 n ationwide c osts and e mission s r eductions for options s elected 2



### TOTAL 2 

### $0.578 $ 0

. 390 PM: 0

TRS: 0

1

. Fine PM (PM 2.5 ) emissions reductions were estimated from the filterable PM emissions reductions presented in the table by applying the following percentages

of PM 2.5 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 un der 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 Im pacts of the NSPS Review Regulatory Options

Regulatory

o ption Energy i mpa cts Secondary air i mpacts, tpy

Electricity,

MWh/yr PM CO NOx SO2 GHG as CO2eq

RF PM1 0 0 0 0 0 0

RF PM2 18,292 0.5 1 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 .0 43 0.3 2 0. 5 9 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 U ltimate 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/month ly/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 Decem ber 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 Pap er Mill Sources –A Second

Update . National Council for Air and Stream Improvement. Technical

Bulletin No. 973. February 2010.

RISI 2012 RISI. Mill Asset Data b ase

. Query of database conducted August 2012.

RockTenn 2012 Title V Air Operation Permit Renewal: R ockTenn 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

. Mem orandum to U.S. Environmental Protection

Agency. May 1 5, 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 N o. PRO40126. September 4, 2008.

### Appendix A

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

Within 5 Years of the Applica bility DateAppA_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 TRS2 1

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)

Equip

ment Design size Baseline/ NSPS control Total

capital cost Annual cost, $/yr

Labor Mainte

nance &

m aterials Electricity Equip

ment

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 $3,3 57,299 $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 BLS 1 $3,469,129 $14,483 $69,383 $142,608 $5,000 $50,320 $138,765 $380,892 $802,452

Lime

kiln 240 t on

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 t he 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 an d Trigger NSPS t hrough 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. Representativ es 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 O 2 

### for recovery

furnaces, and 0.064 gr/dscf at 10 percent O 2 

### 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 g as 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/dsc f 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

modifica tion)

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 em issions reduced.

### 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

annu alized

cost for

modified

ESP that

meets

current

limits, $/yr 1 Revised

NSPS

option

annualized

cost for

modified

ESP, $/yr 2 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.ScenarioNDCE1:Supposeamillmodifies(increasescapacity)ofanNDCEinordertoretireanolderRF.ThemodifiedNDCEwouldaddfieldstotheESPdesignedtomeet0.044gr/dscftocompensatefortheincreasedgasflowratewhilestillmeeting0.044gr/dscf.IftherevisedNSPSwas0.015gr/dscfformodifiedunits,thenamorecostlymodificationtotheESPwouldberequiredtomeet0.015.BaselineNDCEcapacity(MMlbBLS/day)3.2AverageMMlbBLS/dayforNDCEsinbaselinesheet(seeBLS_flow_eqntab)BaselineNDCEflowrate174130dscfm=31359(MMlbBLS/day)+73781.SeeBLS_flow_eqntabAssumedcapacityincreaseuponmodification:0.2525%ModifiedNDCEcapacity(MMlbBLS/day)4.025%capacityincreaseModifiedNDCEflowrate,dscfm217662AssumedincreaseisproportionaltocapacityincreaseBaselineESPupgradecoststomeet0.044gr/dscfBaselinetotalinstalledcosts(2012$)6,903,992$Updated BE&K cost (2012$) of $6,588,481 with 6/10 ruleapplied. You can adapt capital costs to each size unit using the6/10 cost rule: C1/C2 = (Q1/Q2)^0.6. e.g., C1 = C2*(Q1/Q2)^0.6where Q is the capacity parameter (e.g., BLS firing rate, limeproduction rate)Baselineannualizedcosts(2012$)2001 Labor,$/yr$13,333Maintenance&Materials$/yr$89,984Electricity,$/yr$80,850Fuel,$/yr$0Water,wastewater,solidwaste,steam&compressedair,$/yr$0EquipmentTesting,$/yr$5,000Total,$/yr$189,1672012 Labor,$/yr$14,483Laborrateupdatedto2012Maintenance&Materials$/yr$138,080BE&KM&Mwas2%ofTICElectricity,$/yr$108,824Electricitycostsof$0.05updatedto$0.0673Fuel,$/yr$0Water,wastewater,solidwaste,steam&compressedair,$/yr$0EquipmentTesting,$/yr$5,000Overhead,$/yr$91,53860%oflaborandmaintenance&materialsAdmin,taxes,insurance,$/yr$276,1604%ofTICCapitalrecovery,$/yr$758,021=(0.07*(1+0.07)^15)/((1+0.07)^15‐1)*TICTotal,$/yr$1,392,106NSPSOptionESPupgradecoststomeet0.015gr/dscfNSPSoptiontotalinstalledcosts(2012$)8,243,911$Updated BE&K cost (2012$) of $6,588,481 with 6/10 ruleapplied. You can adapt capital costs to each size unit using the6/10 cost rule: C1/C2 = (Q1/Q2)^0.6. e.g., C1 = C2*(Q1/Q2)^0.6where Q is the capacity parameter (e.g., BLS firing rate, limeproduction rate)NSPSoptionannualizedcosts(2012$)2001 Labor,$/yr$13,333Maintenance&Materials$/yr$107,448Electricity,$/yr$88,200Fuel,$/yr$0Water,wastewater,solidwaste,steam&compressedair,$/yr$0EquipmentTesting,$/yr$5,000Total,$/yr$213,9812012 Labor,$/yr$14,483Laborrateupdatedto2012Maintenance&Materials$/yr$164,878BE&KM&Mwas2%ofTICGeneric_mod,p.1AppCElectricity,$/yr$118,717Electricitycostsof$0.05updatedto$0.0673Fuel,$/yr$0Water,wastewater,solidwaste,steam&compressedair,$/yr$0EquipmentTesting,$/yr$5,000Overhead,$/yr$107,61760%oflaborandmaintenance&materialsAdmin,taxes,insurance,$/yr$329,7564%ofTICCapitalrecovery,$/yr$905,137=(0.07*(1+0.07)^15)/((1+0.07)^15‐1)*TICTotal,$/yr$1,645,589Costdifferencetomeet0.015$253,483Emissionsreduction,tpy237=(0.044‐0.015)gr/dscfx(modifieddscfm)/(7000gr/lb)x(60min/hr)x(8760hr/yr)/(2000lb/ton)Costeffectiveness,$/ton$1,070ScenarioNDCE2:Alternatively,ifassumecurrentcontrolrequiresnoexpansiontomeet0.044:Costdifferencetomeet0.015$1,645,589Emissionsreduction,tpy237Costeffectiveness,$/ton$6,944Generic_mod,p.2AppCScenarioLK1:Supposeamillmodifies(increasescapacity)ofalimekilninordertoretireanolderlimekiln.ThemodifiedkilnwouldlikelyaddfieldstotheESPdesignedtomeet0.064gr/dscftocompensatefortheincreasedgasflowratewhilestillmeeting0.064gr/dscf.However,wewillassumethattheESPcurrentlyhasenoughexcesscollectionareaandcompliancemarginbeneaththe0.064gr/dscfPMlimittohandletheincreasedflow.IftherevisedNSPSwas0.010gr/dscfformodifiedunits,thenacostlymodificationtotheESPwouldberequiredtomeet0.010.Baselinekilncapacity(MMlbBLS/day)300AveragetonCaO/dayforlimekilnsinbaselinesheet(seeLK_flow_eqntab)Baselinekilnflowrate23703dscfm=53.397(tonCaO/day)+7683.9.SeeLK_flow_eqntabAssumedcapicityincreaseuponmodification:0.2525%Modifiedkilncapacity(MMlbBLS/day)37525%capacityincreaseModifiedkilnflowrate,dscfm29629AssumedincreaseisproportionaltocapacityincreaseBaselineESPupgradecoststomeet0.064gr/dscfBaselinetotalinstalledcosts(2012$)‐$Assumed the lime kiln ESP has the capacity and PM compliancemargin to handle the aditional flow to meet 0.064 gr/dscfBaselineannualizedcosts(2012$)‐$NSPSOptionESPupgradecoststomeet0.010gr/dscfNSPSoptiontotalinstalledcosts(2012$)2,438,972$Updated BE&K cost (2012$) of $1,866,014 with 6/10 ruleapplied. You can adapt capital costs to each size unit using the6/10 cost rule: C1/C2 = (Q1/Q2)^0.6. e.g., C1 = C2*(Q1/Q2)^0.6where Q is the capacity parameter (e.g., BLS firing rate, limeproduction rate)NSPSoptionannualizedcosts(2012$)2001 Labor,$/yr$19,999Maintenance&Materials$/yr$12,743Electricity,$/yr$29,400Fuel,$/yr$0Water,wastewater,solidwaste,steam&compressedair,$/yr$0EquipmentTesting,$/yr$5,000Total,$/yr$67,1422012 Labor,$/yr$21,725Laborrateupdatedto2012Maintenance&Materials$/yr$48,779BE&KM&Mwas2%ofTICElectricity,$/yr$39,572Electricitycostsof$0.05updatedto$0.0673Fuel,$/yr$0Water,wastewater,solidwaste,steam&compressedair,$/yr$0EquipmentTesting,$/yr$5,000Overhead,$/yr$42,30260%oflaborandmaintenance&materialsAdmin,taxes,insur,$/yr$97,5594%ofTICCapitalrecovery,$/yr$267,786=(0.07*(1+0.07)^15)/((1+0.07)^15‐1)*TICTotal,$/yr$522,724Costdifferencetomeet0.010$522,724Emissionsreduction,tpy60=(0.064‐0.010)gr/dscfx(modifieddscfm)/(7000gr/lb)x(60min/hr)x(8760hr/yr)/(2000lb/ton)Costeffectiveness,$/ton$8,702Generic_mod,p.3AppC

### The affected industry deve loped 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 effec tiveness was reported in the industry analysis to be $16,000 per ton PM reduced , the same as the cost

effectiveness 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 Kilns 2



### Scenario Description Small emission

unit 1 

### , $/ton PM

reduced Large emission

unit 1 

### , $/ton PM

reduced

SDTs

1 M odified or reconstructed SDT has

scrubber that would not need replaci ng 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

2 2 

### Modified or reconstructed SDT with

scrubber in need of replacement. Th e 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

3 a 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 Mod ified 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 , 201 3 Meeting with AF&PA

and NCASI

. March 26 , 201 3.

### Scenario Description Small emission

unit 1 

### , $/ton PM

reduced Large emission

unit 1 

### , $/ton PM

reduced

2 2 

### Mod ified kiln has scrubb er 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 Mod ified kiln has ESP or ESP/scrubber

combination that would have sufficed in

absence of revised NS PS 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 ds cfm,

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 lowe r 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 sou rce 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 remove d 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 a bsence of revised

NSPS).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

baseline 2 $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 BLS 1 $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

baseline 2 $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

baseline 2 $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/dModel 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 $ 2 6,994

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 $ 1 5,412

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 $ 7 6,444

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 $ 1 5,480

3.7 Model SDT BLS (MMlb/day)

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

### ICR data were used to derive the following relations between recovery furnace and lime kiln

capacity and gas flow rate (dscfm)

.

### Appendix D

Emission Factors Used In Impact Calculati onsAppendixD.EmissionFactorsUsedtoEstimateSecondaryAirEmissionsEmissionfactors Value UnitsFuel %ofgenerationNotes1.9lb/MMft3naturalgasCoal 53%0.00186275 lb/MMBtunaturalgasOil/naturalgas21%0.03 lb/MMBtusolid,liquid,gaseousfuelNuclear17% Nosecondaryairemissions84lb/MMft3naturalgasHydroelectric 6% Nosecondaryairemissions0.0824 lb/MMBtunaturalgasRenewable2% Nosecondaryairemissions0.19 lb/MMBtusolidfuelOther1% Assumedequivalenttonatural100lb/MMft3naturalgasNotes:0.0980 lb/MMBtunaturalgas1.Assumeelectricitygeneratedusingtheabovemix(fromIPMVersion3.00.38 lb/MMBtusolidfuelfortheyear2015).0.6lb/MMft3naturalgas2.IPM=EPAIntegratedPlanningModel,whichisamulti‐regional,dynamic,0.00059 lb/MMBtunaturalgasdeterminisƟclinearprogrammingmodeloftheU.S.electricpowersectorthat1.2 lb/MMBtusolidfuelprovidesforecastsofleast‐costcapacityexpansion,electricitydispatch,and53.02 kg/MMBtunaturalgasemissioncontrolstrategiesformeetingenergydemandandenvironmental,93.4 kg/MMBtusolidfueltransmission,dispatch,andreliabilityconstraints.0.001 kg/MMBtunaturalgas0.011 kg/MMBtusolidfuel0.0001 kg/MMBtunaturalgasConversionfactors Units0.0016 kg/MMBtusolidfuel3415.179 Btu/kWhNotes:2.204623 lb/kg1.Fornaturalgascombustion,usedAP‐42emissionfactorsforPM,CO,NOx,andSO2,1,020Btu/ft3naturalgasandused40CFRpart98,subpartCemissionfactorsforCO2,CH4,andN2O.13,000 Btu/lbcoalAssumed1,020Btu/ft3ofnaturalgasinestimatingsecondaryemissions2.Forsolidfuelcombustion,usedNSPSemissionfactorsforPMandSO2(40CFRpart60,GlobalWarmingPotentialssubpartDa,coal‐firedutilityplants),usedAP‐42emissionfactorsforNOxandCOCH421(bituminuous/subbituminouscoalcombustion/spreaderstoker).TheNOxemissionN2O310factorwasbasedonaverageofNOxemissionfactorsforspreaderstokertypeboilersburningbituminous(11lb/ton)andsubbituminous(8.8lb/ton)coal.Assumed13,000Btu/lbofcoalinestimatingNOxandCOsecondaryemissions.Used40CFRpart98,subpartCemissionfactorsforCO2(bituminouscoal)andCH4andN2O(coal/coke).3.The40CFRPart98emissionfactorsandglobalwarmingpotentialsarecurrentasofJanuary30,2012COPMN2OCO2CH4NOXSO2D1

### 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

Pollutant Emission unit TB table

no. NCASI Technical

Bulletin (TB)

D2

### Appendix E

Emissions Inventory and Detailed Unit- by

- Unit Impact Analysis