### Date: November 1 1 , 2011

Subject: Inputs to the Pulp and Paper Industry

EPA Contract No. EP From: Thomas Holloway , Katie Hanks To: John Bradfield and Bill Schrock

U.S. Environmental Protection Agency Research Triangle Park, NC **I. Introduction**  Section 112(f)(2) of the Clean Air Act (CAA) directs Agency ( EPA ) to conduct risk assessments on each source category subject to maximum achievable control technology (MACT) standards and determine if additional standards are needed to reduce residual risks. Section 112(d)(6) of the CAA requires EPA to revie the MACT standards, as necessary, taking into account developments in practices, processes, and control technologies. The section 112(f)(2) residual risk review are to be done 8 years after promulgation emissions standards for hazardous air pollutants (NESHAP) for the pulp and paper industry (40 CFR part 63, subpart S) w ere promulgated in 1998 and 112(f)(2) and 112(d)(6) . In February

2011 , the EPA initiated a three gather information from U.S. pulp and paper manufacturers needed to conduct the CAA regulatory

reviews . The second part of the ICR (Part II), which concluded in targeted towards facilities that are major sources of HAP emissions, and involved an update of pre -populated National Emissions I nventory (NEI) data data sets). The response rate for Part II of EPA’s ICR submitting NEI

spreadsheets for not previously

included in the NEI) Two substantial quality

assurance (QA) efforts were conducted on the order to create the modeling files spreadsheets submitted by each mill prior to import into the compiled standardization of the compiled database this memo. (Note: Modeling files were needed for both the subpart S category and facility, so QA efforts focused on data for all emission sources at pulp and paper facilities.)

Pulp and Paper Industry October 2011 Residual Risk Modeling EP - D - 0 7 - 019 ; Work Assignment No. 4 - 0 9 Katie Hanks , Corey

Gooden, and Matt Hakos Bill Schrock onmental Protection Agency Research Triangle Park, NC 27711 Section 112(f)(2) of the Clean Air Act (CAA) directs the U.S. Environmental Protection to conduct risk assessments on each source category subject to maximum achievable control technology (MACT) standards and determine if additional standards are Section 112(d)(6) of the CAA requires EPA to revie the MACT standards, as necessary, taking into account developments in practices, processes, and

The section 112(f)(2) residual risk review and section 112(d)(6) technology are to be done 8 years after promulgation of the original standards . The national standards for hazardous air pollutants (NESHAP) for the pulp and paper industry (40

promulgated in 1998 and are due for review under CAA section the EPA initiated a three -part Information Collection Request (ICR) to gather information from U.S. pulp and paper manufacturers needed to conduct the CAA

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

National Emissions I

nventory (NEI) data spreadsheets (or creation of new NEI The response rate for Part II of EPA’s ICR was 100 percent, with respondents

for 17 1 major sources ( 2 of which were new NEI data sets for mills not previously

included in the NEI) . quality assurance (QA) efforts were conducted on the P art II data in r to create the modeling files needed for the residual risk assessment : (1) QA of the spreadsheets submitted by each mill prior to import into the compiled database , and (2) QA and database . These QA efforts are discussed in sections II and III of (Note: Modeling files were needed for both the subpart S category and facility, so QA efforts focused on data for all emission sources at pulp and paper facilities.) Residual Risk Modeling

the U.S. Environmental Protection to conduct risk assessments on each source category subject to maximum achievable control technology (MACT) standards and determine if additional standards are Section 112(d)(6) of the CAA requires EPA to revie w and revise the MACT standards, as necessary, taking into account developments in practices, processes, and ion 112(d)(6) technology The national standards for hazardous air pollutants (NESHAP) for the pulp and paper industry (40 due for review under CAA section s part Information Collection Request (ICR) to gather information from U.S. pulp and paper manufacturers needed to conduct the CAA - required June 2011, was targeted towards facilities that are major sources of HAP emissions, and involved an update of spreadsheets (or creation of new NEI

respondents of which were new NEI data sets for mills art II data in : (1) QA of the , and (2) QA and sections II and III of (Note: Modeling files were needed for both the subpart S category and the whole facility, so QA efforts focused on data for all emission sources at pulp and paper facilities.)

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The purpose of this memorandum is to document the inputs to the residual risk modeling file, specifically

(1) QA and standardization of the NEI data for the pulp and paper industry including the default parameters used (Sections II and III) , (2) pollutant speciation and apportionment factors (Section IV) , ( 3 ) emission process groups assigned to the pulp and paper source classification codes (SCCs) (Section V) , ( 4 ) allowable emissions multipliers (Section VI) , ( 5 ) acute emissions multipliers (Section VII) , and (6) information relating to acrolein emissions estimation (Section VIII) . **II. QA of Part II NEI Update Spreadsheets**  **A. Review Checklist**  The first step in preparing the inputs to the residual risk modeling file was to QA the individual NEIupdate spreadsheets received from each of the pulp and paper mills in response to Part II of the February

2011 survey

sent to the pulp and paper industry . NEI update spreadsheets for 17 1 major sources were reviewed. W e began our QA of the pulp and paper NEI update spreadsheets using a checklist, which is provided in Appendix A to this memorandum . The checklist looked at consistency in facility name, information in the wrong column, equipment we expected to see, pollutants we expecte d to see, missing stack and fugitive parameters, missing latitude/longitude values, and any other observations, such as recommendations for follow -up with the mills (e.g., if the spreadsheets were missing the information we expected to see). Associated tab les of the subpart S equipment we expected to see are also provided in Appendix A. In addition to providing recommendations for follow -up, the checklists were also useful in informing the later, more in - depth review and revision of each inventory spreadsh eet . If we found any obvious errors (e.g., providing text in code columns), we corrected them. If any information was provided in the wrong column (e.g., new data placed in revision columns), we moved it to the correct column. Because some columns in the inventory files did not have revision columns (e.g., facility name, emission unit ID, etc.), we included an “RTINotes” column in the revised files that noted any changes to those columns. Revisions to the inventory fi les were highlighted in yellow. Several mills were contacted with follow - up questions, and these clarifications were incorporated into the Part II spreadsheets before further processing. The revised inventory

files were transferred to the NEI team for compilation into a database file. Prior to transferring the files, we also made any necessary

formatting changes to facilitate the compilation (e.g., eliminating merged cells, merging/cop ying notes that had been spread across rows). The following sections discuss in greater detail the in - depth QA we conducted of the inventory spreadsheets. It should be noted that, over the course of reviewing the many inventory spreadsheets, the scope of the QA evolved (increased) , such that some of the QA activities discussed below were only conducted in the later reviews .

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**B. Recommended Inventory Deletions**  At the start of each in - depth QA , we evaluated the acceptability of each mill’s recommended inventory deletions to ensure that the mills did not mark for deletion something that was no t replaced and would be need ed for subpart S modeling or whole - facility modeling. If the file included detailed reasons for why certain records were deleted (e.g., equipment no longer in operation, replacement data provided in specified rows, emissions vented to a vent gas collection system) we evaluated those reasons and provided our recommendation regarding those deletions in the “RTI Notes” column. If the file did not include detailed reasons, we determined the acceptability

of the deletions by first filtering on the rows selected for deletion and noting the SCCs included in that dataset, and then filtering on the replacement rows and noting which SCCs in the deletion dataset were included in the replacement dataset. (This approach was necessary because mills often used emission unit IDs in their replacement inventories that were completel y different from the emission unit IDs in the inventories marked for deletion.) If an SCC was not included in the replacement dataset, we attempted to determine the reason why (e.g., equipment no l onger in operation, emissions vented to a vent gas collection system , not a source of hazardous air pollutant [ HAP ] emissions , a different SCC was use d for the same process, etc.). In most cases, we found the deletions to be reasonable, and noted “OK to de lete” in the “RTI Notes” column. If we could find no reason why a particular SCC was selected for deletion, we included a note in the “RTI Notes” column stating that the emission unit associated with that SCC should not be deleted and exp laining why . Where necessary , we followed up with mills regarding these suggested deletions. Some of the emission units consistently marked for deletion and not replaced include methanol storage tanks, chlorine dioxide generators, coating operations, boilers, landfills, saltcake mix tanks, etc., presumabl y because these equipment are not regulated under subpart s S or MM or were not specifically required to be reported in the Part II survey . (Note: We only kept the HAP data for these emission units, since only those data are needed for risk modeling.) Once we had decided which records to keep (i.e., not delete), we reviewed those records to ensure that they

would be consistent with the replacement inventory (e.g., same facility

name, facility ID, etc.). If we found additional records that needed deletion (e.g., not emission points), we marked those rows for deletion (with the rows highlighted in yellow in the spreadsheet) and noted the reasons for the deletion in the “RTI Notes” column. After reviewing all recommended deletions, we filtered the inventory spreadsheets to view only the accepted records, and we conducted the rest of our review looking at just the filtered (accepted) data. **C. ID Fields**  After filtering the data, w e checked each inventory spreadsheet for gaps in the various ID fields

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

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we added more process IDs (one for each SCC for a given emission unit). We also checked the emission release point ID against the stack and fugitive parameters to ensure that there was onl y one set of parameters per emission release point ID. If there was more than one set of parameters, we added more emission release point IDs (one for each set of parameters for a given emission unit). **D. S** **ource Classification Codes** After checking the IDs, we reviewed the SCCs to ensure that they reasonably matched the emission unit description, as well as the mill type ( e.g., kraft, sulfite, non - sulfur semichemical, neutral sulfite semichemical (NSSC), thermo mechanical, groundwood, secondary fiber, paper onl y) and were internall y consistent within the spreadsheet . For boilers, w e looked to see that the SCC was for industrial boilers (as opposed to commercial, institutional , or utility boilers) and matched the SCC to the fuel ty pe (e.g., coal, wood, oil, natural gas) in the emission unit description . Where we determined the SCCs w ere incorrect, we replaced them with more appropriate SCCs from the SCC listing provided in the lookup spreadsheet file included with Part II of the survey . We also tried to substitute a more precise SCC for any generic SCC (e.g., 30700199, 30700499, 3999 9999), where possible. We used emission unit descriptions to come up with more precise SCCs. If emission unit descriptions were missing, we checked the emission unit ID against the mill’s Part Isurvey response and/or permit to determine the identity of th e emission unit and make a more precise SCC assignment. **E. Pollutants and Emissions**  We then checked for gaps in the pollutant fields

— pollutant code, pollutant description, and HAP category

name. Where we found gaps in these fields, we filled them using the p ollutant code table provided in the lookup spreadsheet file included with Part II of the pulp and p aper survey . If a pollutant code was not provided in the lookup table, we found the CAS number for the pollutant online and entered that into the inventory f ile as the pollutant code. If a CAS number was not available for a particular pollutant (e.g., m,p - xylene), we left the cell blank (with the problem to be resolved later in the QA of the compiled database file ) . We also checked for missing emissions data and, if we were no t able to fill the data gaps easily (e.g., the data were not for an identical ty pe of emission unit), we followed up with the mill to obtain the missing data. We did not check the reasonableness of the emissions data in the spreadsheets or whether there were any duplicate emissions data (that would be done in the QA of the compiled file), unless it was obvious. Where emissions data were obviously suspicious, we followed up with the mill regarding the data. Where there were obviously dupli cate emissions data, our approach varied depending on the situation. We either followed up with the mill, added more process IDs or emission release point IDs to eliminate duplication for a given emission unit, or added a note to the “RTI Notes” column to combine or delete the duplicate data at a later time (during the QA of the compiled file) . We also noted where HAP data were completel y missing from a mill’s inventory of subpart S sources , but deferred any solution to that problem until the compiled file had been received .

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**F. MACT Codes**  We compared the MACT codes to the SCCs in the inventory spreadsheets to determine whether they were reasonable and internally consistent within the spreadsheet , for example:  Subpart S MACT code (1626 - 1) for SCCs associated with pulp and paper production  Subpart MM MACT code (1626 - 2) for SCCs associated with pulp and paper chemical recovery  Pulp and paper non - MACT facility MACT code (1626 - 3) for SCCs associated with landfills, wood handling, etc. at pulp and paper mills  Boiler MACT codes (0107 - 1, - 2, - 3, - 4) for SCCs associated with boilers at pulp and paper mills  Paper and other web coating MACT code (0711) for SCCs associated with paper coating that was not specifically

identified as on - machine coating. If we determined that the MACT codes were incorrect, we replaced them with the correct MACT codes from the MACT code listing provided in the lookup spreadsheet file included with Part II of the survey . **G. Latitudes** 

**/ Longitudes**  After reviewing the MACT codes, we checked for gaps in the latitude and longitude data. If we found gaps, we checked the rest of the file to see if latitude and longitude data were provided elsewhere for that particular emission point and could be copied. Otherwise, we used the default latitude and longitude values for the entire mill. We did not check the accuracy of the latitude and longitude data in this step . That task was to be handled b y EPA in the compiled file. **H. Stack and Fugitive Parameters**  We also checked the stack and fugitive parameters against emission release point ty pe to see whether they

were consistent. If an emission point had stack parameters but was labeled as a fugitive emission source (emission release point ty pe of “01”), we changed the emission release point ty pe to “02,” c onsistent with a stack emission source. Similarly , if an emission point had fugitive parameters but was labeled as a stack emission source (emission release point ty pe of “02” through“0 6 ”), we changed the emission release point ty pe to “01,” consistent with a fugitiv e emi ssion source. This check was performed by filtering on emission release point ty pe (i.e., filtering on “01” to review fugitive parameters and filtering on the other emission release point ty pes to review stack parameters). Lastl y, we checked the stack and fugitive parameters for data gaps and errors. Where there were data gaps for stack emission sources, we checked the rest of the file to see if stack parameter data were provided elsewhere for that particular emission point and could be copied. Where possible, we calculated the missing data. For example, if exit gas velocity was missing but we had exit gas flow rate and stack diameter, we calculated the velocity using the following equation: Exit gas velocity

= exit gas flow rate/stack area, where stack area = π * (diameter/2) 2

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We also estimate d missing gas flow rate and stack diameter data using this equation. Where the exit gas flow rate provided b y the mill was suspiciously high, we used this equation to determine if the flow rate might be in units of actual cubic feet per minute (acfm), instead of actual cubic feet per second (acfs). If we determined that was the case, we divided the exit gas flow rate b y 60. If it appeared the mill had left the data blank deliberatel y (e.g., by indicating in a note that the data were unknown, by indicating in a note or stack default flag that they wanted stack defaults, or b y leaving only certain columns blank), we added a note to the “RTI Notes” column to provide stack defaults for those missing parameters during the QA of the compiled database file. If the mill used the term “ambient” for exit gas temperature, we assumed a temperature of 72°F. If the mill used the term “NA” for exit gas flow rate, we assumed a flow rate of 0 acfs according to the NEI default for f ugitive sources . If it appeared the mill had left the data blank mistakenl y (e.g., because this ty pe of emission unit would ty

pically have stack parameters, because the mill did not indicate they wanted stack defaults, or because all columns were left bla nk), we followed up with the mill to see if they

had the stack parameters. Where there were data gaps for fugitive emission sources (i.e., fugitive length, fugitive width, fugitive angle), we left the data gaps and did not follow up with the mill. (Measurements of some fugitive parameters may not be readil y available or eas y to obtain . ) In stead, we decided to fill the data gaps with fugitive defaults during our QA of the compiled file. Because such data gaps were numerous in the individual inventory files, we did not include any notes about them in the “RTI Notes” column. In the course of our QA , w e also provided stack defa ults for each fugitive emission source. If a mill provided release height and temperature values for a fugitive source, we kept those v alues and provided national default values for the rest of the stack parameters : 0.003 foot ( ft) stack diameter, 0.0003 foot per second ( ft/sec ) exit gas velocity, and 0 acfs exit gas flow rate. If a mill provided release height but not temperature, we provided the national default temperature (72°F) for fugitive source s . If a mill provided neither release height nor temperature, we provided the national defaults for both (10 ft, 72°F). If a mill provided a release height of 0 ft (e.g., for a wastewater basin), we changed the release height to the closest whole number (1 ft), consistent with EPA guidance. **III. QA of**  **Compiled NEI Database**  Once the inventory

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

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The intermediate draft compiled file for QA was composed of a Facility table which include d detailed facility

information and a KEEP table which included the emissions and parameter information that we had indicated should be kept , plus some limited facility information that could be linked back to the Facility tab le . (Note: There was another compiled file that also included all records from the inventory spreadsheets, including those we marked for deletion. We did not QA this file but used it for reference .) At the beginning of our QA, the KEEP table contained over 1 45 ,000 records covering HAP, criteria air pollutants (CAP), total reduced sul fur (TRS) and other pollutants . Columns were included to reflect original data from the pre -populated Part II NEI data spreadsheets , edited Part II data from respondents , and final data to be included in the NEI modeling file . Any additional records identified for deletion in the course of our QA of the compiled file were moved to a Deleted_items table in the file . We entered line -by- line review notes in the “ RTINotes ” and “ Delete Comment” columns as needed to reflect changes made to the data. We inserted a few “QAd” columns in the data base as needed to reflect our changes. However, due to Access table width constraints, in some cases we just entered revisions into the “FINAL” column (e.g., for MACT code). **A. Facilit** 

**y /Emission Unit**  **Information** Number of facilities . We first checked the Facility and KEEP tables in the compiled file to ensure that both tables included all the mills we expected to see . No issues were found. Major/area source status . We double - checked the major/area status of each mil l and concluded that all were major sources , with the exception of NEIWI4430444 - ST Paper, LLC , Oconto Falls, WI. Our P art Isurvey records indicate this is a sy nthetic area source that should be removed from the Part II inventory prior to risk modeling. The facility did not make any updates to their Part II survey

(but instead indicated all the data were okay as is). There were a handful of facilities that left their inventory labeled as “area” source, but whose Part I survey

response indicates they

are a major source. We updated the FINAL Facility Category Code to reflect major source status for these facilities . Facility name . We checked to ensure the facility name used by each facility wa s consistent throughout the database. A few instances of different names being used for the same mill were detected (a carryover from a few spreadsheets that were not complete inventory replacements) . We corrected the facility names in the KEEP table where necessary to match the names in the Facility table . Emission unit description . We noted that some of the facility records for emission unit description were blank. If other fields contained descriptive information, we copied that to the emission unit description column for convenience. However, some blanks remain.

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**B. Co**  **des, IDs, and**  **Dates** Emission unit/process/emission release point IDs . Gaps in these IDs were resolved first before we did any further work in the database. Next, we added the following concatenations to the beginning of the table to facilitate a review of records b y unique emission unit: RTI _Unit: NEI ID -- Emission Unit ID -- Process ID RTI _EmPt: NEI ID -- Emission Unit ID - - P rocess ID - - Emissio n Release Point ID We also added the following concatenations to the end of the table to facilitate detection of duplicate and differing values for stack parameters and latitudes/longitudes : Release_point_combo: State County FIPs --NE I ID -- Emission Release Point ID Process_combo: State County FIPs - -NEIID -- Emission Unit ID SIC/NAICS codes . Many Part II survey respondents used text different from the lookup table in their Standard Industrial Classification ( SI C ) code descriptions and North American Industry Classification System (NAI CS ) code descriptions. We reviewed the SIC and NAICS codes to ensure they

were consistent with the text used by the respondents and made any appropriate corrections . The final codes reside in the corresponding “FINAL” columns. We deleted the column with respondents’ SIC description s after reviewing the SIC and NA IC S codes to save space due to database size limitations (e.g., character limitation across rows ). The final SIC or NAICS descriptions can be linked from a standard lookup table, as needed. SCC/MACT codes . We spent considerable time on standardizing SCCs and MACT codes to ensure consistency within in the database . First, we reviewed each SCC by the emission unit description (and other descriptive columns) to ensure they were consistent. Next, we cross tabbe d SCC vs. MACT code to look for inconsistencies. Except for the not - elsewhere classified SCC ( 39999999 ), each SCC is now affiliated with only one MACT code. We reduced the number of not - elsewhere classified SCCs (e.g., ***** 999 s) by reviewing available pro cess descriptions and assigning more specific SCCs where possible. Table 1 at the end of this memorandum lists the MACT codes used in the compiled file. Once the MACT codes were standardized, we removed the lengthy un - standardized MACT code and SCC descriptions supplied by the respondents in order to save space . As with SIC and NAICS descriptions, final code descriptions can be linked from a standard lookup table, as needed. Start and end dates . We reviewed the base ye ar information th at facilities provided in their Part II responses and corrected any obvious errors. Missing dates were populated with dates from the mill ’s NEI update spreadsheets. Note: The Buckeye, Perry FL mill (NEI ID No. NEI47091) submitted data for a direct contact evaporator (DCE ) re covery furnace that was converted to a non - direct contact evaporator (NDCE ) recovery

furnace mid- ye ar. DCE data were supplied for January through June 2010, and NDCE data were provided for July through Dec ember 2010. Rather than model the now obsolete DCE data, we converted the NDCE data to reflect one year’s worth of operation (i.e., multiplied

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by 2) from July

2010 through June 2011. The DCE data were flagged for deletion and moved to the Deleted

_i tems table. Data source code . We corrected any respondent misspellings and errors. Respondents were asked to enter “RTR09” for new records , but there were some obvious drag errors, misspellings, etc . Control measure codes . We reviewed these codes for consistency with code definitions in the lookup table and stan dardized them . Since these columns are not critical for the modeling file, we did not cop y all codes down where they appeared for just some rows for a given emission unit. Emission release point type code s . Emission release point ty pe codes were reviewed against the stack and fugitive parameters included in the database to ensure they were identified correctly . An emission release point ty pe code of “01” indicates fugitive emissions, while all other emission release point ty pe codes ( “ 02 ” through “ 0 6 ” ) indicate stack emissions. Where it was obvious that the code was in error, the emission release point ty pe code was revised accordingl y. **C. Pollutants and**  **Emissions** Pollutant codes . The pollutant codes and names received with the Part II survey responses required extensive QA and standardization. There were missing and invalid codes, various permutations of pollutant names, etc. We made several specific changes to pollutant codes where necessary (e.g., coding thallium as a radionuclide). There were also many non - HAP pollutants included in the Part II responses that were not previously

included in the NEI lookup table. For these “new” pollutants, we looked up their CAS numbers ( either to verify

the codes submitted by

respondents or to obtain missing pollutant codes ) and ensured the compiled database file included these pollutant codes. We created a lookup table for the compiled file that contains all of the old pollutant codes from the original NEI code lookup table and added to this table the “new” pollutants for pulp and paper (giving standardized names to the new pollutants , based generall y on the most commonly reported name). The EPA NEI team reviewed and provided comments on the ta ble , and we made the corresponding corrections. Table 2 presents the new non - HAP pollutants added to the NEI pollutant lookup table. Actual Emissions . We reviewed the magnitude of emission s. We followed up with mills (as needed) for correction of obvious errors (e.g., 4.5 million tons per year [ tpy] of chloroform). In many cases, there was a conversion error made by the respondent. We looked at HAP emission s from individual processes above 100 tpy to identify obvious errors . Th e QA of emission s data focused more on HAP (particularl y from 1626 MACT codes) than on CAP or TRS due to time constraints. Some potentially random high emissions remain for non - 1626 processes and for CAP and TRS releases .

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In a couple of cases where emissions were obviously in error, and where emission factors were used in creating the estimates, we used ratios of emission factors to revise the emission s estimate s . Duplicate pollutant s . Numerous duplicate pollutants app eared in the database for each RTI

_EmPt. The reasons for most of the duplicates appeared to be:  Part II respondent error (e.g., respondents updating old data and including new data for the same pollutant but not necessaril y the same emission rate, etc.).  Pollutant coding issues where onl y one code applied for what respondents considered a separate pollutant (e.g., cresols, xyl enes, s ynonyms of pollutants).  Coding of emission units that was not detailed enough (e.g., multi - fuel - fired boilers with different emissions estimates for each fuel but only one RTI_EmPt). We spent a considerable amount of time resolving these duplicate issues. We resolved duplication issues relating to xyl ene that resulted from the double - counting of mixed and individual xylene isom ers (with several xyl ene rows being moved to the Deleted_items table). For example, some data for m,p–xylenes in the compiled file received pollutant code 1330207 [for “Xylenes (mixed isomers”)] , which resulted in a problem if there was already data for total xylenes with pollutant code 1330207 (resulting in two rows with the same pollutant code and different emissions). In many cases, the solution to duplicate pollutants was to recode the emission units, processes, or emission release points, a s applicable. In some cases, we found we needed to delete exact duplicate pollutants, or delete the lowest of two duplicates (e.g., if there was an order- ofmagnitude difference in emissions such that the second duplicate didn’t add much). We noted the problem and corrective action in a separate spreadsheet (and often in the “ RTINotes ” or “ Delete Comment” in the compiled database file ). For a few mills, we found that we had to sum up emissions after contacting the respondent. Hexachloroethane emissions from pulp storage tanks . We noted that some pulp storage tanks had hexachloroethane emission s estimates. During our QA of a prior preliminary risk modeling file, we learned that National Council for Air and Stream Improvement (NCASI) -- the leading source of environmental data affecting th e pulp and paper industry-- had eliminated th e emission factor for hexachloroethane for unbleached pulp mills. Upon review, we decided to keep the hexachloroethane emissions estimates as is because most were for bleached pulp mills , where hexachloroethane might be expected . Routine maximum hourly emisisons . This database field was structured as a text field. We added a numeric - double field called “ RoutineEmMaxHourly _lb/hr” so we could use the values in calculations. We compared the maximum pound per hour ( lb/hr) values with the actual tpy values and found wide discrepancies for many emission units (e.g., maximum lb/hr values resulting in less than the routine tpy ; lb/hr and tpy values differing by

more than a factor o f 1000 ). Therefore, we concluded that extreme caution should be exercised when using the maximum hourly emissions field , and w e do not recommend using the maximum hourly emissions field for acute risk

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modeling. Rather, we recommend considering this information in the development of acute multipliers, where out - of - range values can be discounted , as needed. (For further information, see the section on acute multipliers later in this memorandum.) Startup and s hutdown emissions . Very little data were provided by survey respondents for startup and shutdown. Less than 2 percent of respondents supplied startup and shutdown emission rates, and , in most cases , the startup and shutdown emission rates matched the maximum lb/hr emission rates for routine operation. The se data were considered in development of acute multipliers, but ultimately were not useful. Missing emissions . For several mills, HAP emissions data were not provided for their subpart S (1626 - 1) sources . In some cases, the volatile organic compound (VO C ) emissions data that were provided were multiplied by HAP/VOC ratios to estimate the HAP emissions (where HAP emissions were expected) . The HAP/VOC ratios were based on HAP and VOC emission factors in NCASI Technical Bulletin 973, which is a compilation of the latest HAP emission factors for the pulp and paper industry . We developed HAP estimates for both routine annual emissions and maximum hourly emissions , where VOC were available for both . Where no VOC data were provided, we estimated the HAP emission s using the HAP emission factors from the NCASIbulletin and the production information from the mills’ Part Isurvey responses. TRS . The NEI data submitted with Part II contained TRS in various forms:  Individual speciated TRS compounds (e.g., hydrogen sulfide [H 2 

### S], methyl mercaptan)  Total TRS as sulfur (S)  T otal TRS as H 2 

### S  T otal TRS (on an unspecified basis) When standardizing pollutants in the NEIdata file, we were careful to retain whether total TRS was labeled “as S” or “as H 2 

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

### S. There are several TRS compounds. These compounds are easily

identifiable in the compiled NEI data file because they have a general HAP category

name of “ H 2 

### S ” or “ TRS .” H owever, the NSPS regulatory definition of TRS includes four compounds: H 2 

### S, methyl mercaptan, dimethyl disulfide and dimethyl sulfide . For mills supplying only

total TRS data (e.g., TRS, TRS as S, or TRS as H 2 

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

**itudes /**  **L ong** **itude**

**s** We reviewed the latitudes and longitudes for individual stack and fugitive release points in the compiled file. Where we f ound gaps in latitude/longitude data, we populated the gaps with data (where available) from a prior draft residual risk modeling effort. Often , coordinates for the center of the mill were used. Once we had filled all of the data gaps, we exported the latitude/longitude data into a spreadsheet file and sent the file to EPA, where the data were reviewed using Google Earth . Any latitudes and longitudes that were off -property were brought to the center of the property (unless the location of the emission release point was obvious, in

### 12

which case the latitudes and longitudes were moved to the emission release point). As discussed further below, EPA also used Google Earth to QA fugitive parameters, as ne eded. After EPA had completed its QA of the latitude/longitude data, we re - imported the data back into the database file . W e checked the latitudes and longitudes by using the Release_point_combo concatenated codes (State County FIPS --NEI ID -- Emission Release Point ID ) . We found numerous duplic ates where the same emission release point had multiple coordinates , which we corrected (ty pically by creating new emission release point IDs for the duplicate records ) . **E. Stack**  **P**

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

### /sec exit gas flow rate. The reported fugitive release height and temperature (if different from the 10 ft and 72 ° F defaults) were retained. Stack parameters for all other emission release p oint codes of “02” through “06” ( i.e., stacks) were reviewed. Where possible, information supplied was used to populate missing fields ( e.g., if diameter and flow rate were provided, this information was used to back- calculate velocity). Except for paper machines (SCC 30700401), unresolved blanks were populated with the 2002 NEI default parameters for each SCC, MACT code, and SIC. 1 

### The hierarchy applied for assigning the stack defaults was SCC > MACT code > SIC . Paper Machines . For paper machines, a specific set of stack parameters was applied, consistent with guidance from industry (se e Appendix B for documentation) . We applied the following default stack parameters for paper mach ine SCC 30700401:  Stack height: 70 feet (ft)  Stack diameter: 4.6 ft  Exit gas velocity : 30 feet per second (ft/sec)  Exit gas flow rate: 499 cubic feet per second ( acfs ) Note: Industry ’s guidance document on paper machine default stack parameters mentions applying these parameters to two SCCs: 30700401 and 30700405. SCC 30700405 is no longer in use for the pulp and paper industry and was replaced in the compiled file with SCC 30700401 . The default parameter w e used for exit gas temperature varied, depending on whether the paper machine emission points were indicated in the NEI emission process description to be from the wet or dry

end of the paper machine, or were not indicated:  Wet end: 104°F  Dry end: 149°F  N ot indicated: 125°F

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

### 13

For paper machine emission release point types identified as stack (codes “ 02 ” through “ 0 6 ” ), we kept the stack parameters determined to be actual data and replaced those determined to be NEI defaults for any facilities where NEI defa ults had not already

been resolved through the Part II survey

process . For those paper machine emission release point ty pes identified as fugitive (code “ 01 ” ), we looked to see whether they had fugitive parameters (length and width). If they did, we left those parameters in place. If they did not, we revised the emission release point ty pe code to indicate stack emissions (code “ 02 ” ) and then replaced the NEI national default stack parameters (10 ft height, 72°F temperature, 0.003 ft diameter, and 0.0003 f t/s velocity) with the industrysupplied default stack parameters noted above. Other NEI stack parameter checks . We performed certain stack parameter checks that are ty picall y done for NE I data. Flow rates were checked based on the aforementioned calculation using the stack exit diameter and velocity . Any flow rates varyingby more than 10 percent from the calculated value were set to the calculated value. The stack parameters were also checked against the Release_point_combo concatenated codes (S tate County

FIPS --NEI ID -- Emission Release Point ID) to re solve any duplicate or differing information (e.g., by adding new emission release point IDs, correcting stack parameters) . The stack parameters were also checked to ensure that the stack diameter was not greater than the stack height. Where this occurred, we reviewed each case individually to resolve the situation (e.g., replaced the stack height and/or diameter with correct information from the mill’s NEI update spreadsheet, replaced the stack diameter with a default value , back- calculated stack diameter based on exit gas velocity and flow rate) . We also checked to determine if the emission release point ty

pe was consistent with the ty pe of equipment (SCC) and type of release parameters provided. **F. F**  **ugitive P**  **arameters** After determining which emission release p oint types in the database were fugitive “01,” we reviewed the fugitive length, width, and angle. EPA plotted and measured several fugitive emission sources (e.g., wastewater, liquor ponds, some paper machine buildings coded as fugitive) to verify

length and width and to check fugitive angle, particularly when no angle was provided. Numerous fugitive parameters were blank or zero. In some cases, EPA populated the blank fugitive dimensions with values measured using Google Earth where such measurements were possible . EPA also used Google Earth to resolve fugitive angles that were negative or greater than 180 degrees. Non - wastewater fugitive parameters . W ith the exception of wastewater, w e populated the remaining blanks for fugitive length and width with SCC - specific fugitive dimension defaults we created based on QA of the actual fugitive defaults provided for each SCC and engineering judgment. To be con servative, w e erred on the side of underestimating the dimensions, while

### 14

improving on the representativeness of the values (i.e., replacing the zeroes). The fugitive angle was considered to be zero. A table of the SCCs with affected fugitive emissions is provided in Appendix C. Wastewater fugitive parameters . The following default fugitive parameters were supplied by industry representatives for wastewater (see Appendix D f or industry

documentation):  Primary

clarifiers: fugitive length and width = 177 ft; fugitive angle assumed to be zero  Aeration stabilization basins (ASBs): fugitive length = 1500 ft; fugitive width = 1000 ft; fugitive angle assumed to be zero  Activated sludge treatment (AST) systems: fugitive length = 829 ft; fugitive width = 166 ft; fugitive angle assumed to be zero Note: Length and width for AST systems were calculated based on the midpoint (27,500 ft2 

### ) of the range of AST areas (20,000 to 35,000 ft2 

### ) provided by industry, using the midpoint (5) of the length/width ratio provided by industry (2 to 8). The information we received from industry does not speak to release height, but the NEI defaults (e.g., 1 ft, 10 ft) seem reasonable for these ty pes of sources (since some clarifiers or concrete basins are elevated). For those wastewater emission release point ty pes identified as fugitive (code “ 01 ” ), we added the industry- supplied fugitive parameters where site - specific fugitive parameters were not already available (e.g., through the Part II survey response or from a Google Earth measurement). We defaulted the release height to 10 ft for those records, if they had a higher release height. If the release height was 0 ft, we defaulted to 10 ft for clarifiers and 1 ft for ASBs and AST systems. For those wastewater emiss ion release point ty pes identified as stack (codes “ 02 ” through “ 0 6 ” ), where there were clearl y NE I default stack parameters that carried through the Part II survey process , we changed the emission release point ty pe to fugitive and added the industrysupp lied fugitive parameters and default release height specified above. Where the stack parameters could not be identified as default, we left the emission release point ty pe and stack parameters as reported . **IV. Pollutant**  **Speciation and Apportionment**  **A. Chromium Sp**  **eciation** Chromium compounds are a significant contributor to increased cancer risk, but the level of risk largel y depends on the oxidation state (species) of the compounds. The two most common chromium species are hexavalent chromium (Cr+6 

### ) and trivalent chromium (Cr+3 

### ). EPA has classified Cr+6 

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

### is not classified as to its human carcinogenicity. Consequentl y, determining the percentage of total chromium that is Cr+6 

### vs. Cr

+3 

### is a major factor in estim ating the level of risk from chromium exposure. Table 3 at the end of this memorandum presents the default chromium speciation profile s that w ere used for the October 2011 risk modeling to generate estimates of Cr+6 

### (pollutant code

### 15

18540299) and Cr+3 

### (pol lutant code 16065831) . S peciation profile s are documented f or each SCC applicable to the pulp and paper industry (and included in the October 2011 risk modeling). The chromium speciation profile s w ere applied where onl y total chromium estimates were provided ( for pollutant code 7440473 or 136 ) . S ome mills provided estimates for both total chromium and Cr+6 

### for a particular source . In those cases , we subtracted the Cr+6 

### from the total chromium to calculate Cr+3 

### and then deleted the total chromium estimate . **B. Mercury S** 

**peciation** Like chromium, the different oxidation states of mercury compounds vary

in toxicity, but also in exposure pathway (e.g., inhalation, ingestion). The most common mercury species are divalent mercury

(Hg+2 

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

### ). We recommend speciating mercury compounds (pollutant codes 7439976 and 199) using the NEI default multipliers of 0.2 for particulate divalent mercury (pollutant code 202) , 0.3 for gaseous divalent mercury (pollutant code 201) , and 0.5 for elemental gaseous mercury (pollutant code 200) for all sources in the compiled database file . (EPA 2006a) It should be noted that there are a few records in the compiled file that are already speciated as elemental mercury (pollutant code 200), and no further speciation is required for these records. **C. POM**  **S**

**peciation** Polycyclic organic matter (POM) is comprised of a large number of individual compounds (POM species) , each with their own toxicity levels and exposure pathways. Within the pulp and paper production category (MACT code 1626 - 1 ), there were several listings for POM in the compiled file that were unspeciated (pollutant code 246). Most facilities that reported POM speciated the data into individual compounds. Unspeciated (total) POMs were reported for some paper machines and direct - fired paper machine dryers (SCC 30700401 ). Since many mills provided speciated POM compounds , POM speciation profile s were developed from those mills to speciate total POM for mills with unspeciated POM data . Table 4 at the end of this memorandum presents the POM speciation profile s used to replace unspeciated POM for paper machines and paper machine dryers (SCC 30700401 ). **D. Dioxin** 

**/Furan Speciation**  **and Apportionment** The predominant sources of dioxin/furan emissions at pulp and paper mills are the power boilers used to provide steam and electricity for the mill and the chemical recovery combustion sources (i.e., recovery

furnaces and lime kilns) at the mill. Most mills reported dioxin/furan emissions for specific SCCs and MACT codes. However, some dioxin/furan apportionment was needed for mill processes with an SCC of 39999999 (Misc Manuf/Indus Processes/Other Not Classified) and a MACT code of 1626 - 3 (Pulp and Paper Production - N on - MACT Facilities ). One mill (NEI ID NEI47077) had dioxin/furan emissions data listed for SCC 39999999 and MACT code 1626 - 3 . The dioxin/furan data were already speciated (i.e., had TEQ congeners ). Since the mill had both boilers and chemical recovery combustion sources, w e apportioned the dioxin/furan data to the 0107 MACT code (boilers at the facility) and 1626 - 2

### 16

MACT code ( chemical recovery combustion sources) using the following methodology-- 5 5 percent to boilers and 45 percent to chemical recovery combustion sources . Two other mills (NEI IDs NEI33135 and NEI41252) had dioxin/furan emissions data listed for SCC 39999999 and MACT code 1626 - 2 , but the data were unspeciated (i.e., reported as total dioxin, pollutant code 155), so we developed a congener profile for th e se sources . Because most dioxin/furan emissions from MACT code 1626 - 2 are expected to come from the recovery furnace, we used the dioxin/furan congener profile for recovery furnaces in Table 5 - 13 of EPA ’s dioxin/furan inventory report (EPA 2006b ) to estimate the congener emissions . Table 5 at the end of this memorandum presents the dioxin/furan congener profile and toxic equivalency factors (TEFs) used to replace the unspeciated dioxin/furan estimates for these 1626 - 2 sources with individual congener estimates ( expressed as 2,3,7,8 - TCDD TEQ). The toxic equivalency factors are b ased on the latest EPA guidance . The EPA plans to QA the entire dioxin/furan emissions database and do further evaluations during the RTR process planned for the subpart MM category (MACT code 1626 - 2) and anticipates further refinements in dioxin/furan emission s estimates when the Boiler MACT rule is finali zed ( subpart DDDDD). For these reasons and because dioxin/furan emissions are not part of the subpart S category, EPA did not model these emissions at this time. **E. Glycol Ether Speciation**  There are some listings of total gl ycol ethers in the database for MACT codes 1626 - 1, 1626 - 2, and a few other MACT codes. We coded all total gl ycol ether records (identified as pollutant code 171) as 1,2 - dimethoxyethane (pollutant code 110714). The pollutant 1,2 - dimethoxyethane is the most commonly emitted gl ycol ether for pulp and paper. Consequently, we recommend using the risk benchmarks for 1,2 - dimethoxyethane when performing risk modeling for these records. **V. Emission Process Group Assignments**  Descriptive emission process groups were assigned to each SCC to group similar emission units and facilitate anal ys is of the risk results. Each SCC is affiliated with only one emission process group (but one emission process group can apply for multiple SCCs). Table 6 A at the end of this memorandum provides a listing of the SCCs co ntained in the October 2011 risk modeling file and the emission process groups assigned. Through the use of emission process groups, we can focus our anal ys es of risk results and emissions on 82 consolidated emission process groups rather than on 225 SCCs . Some of the processes listed in Table 6 A do not emit HAP or TRS and do not appear in the risk modeling file. T o aid in anal ys is of the risk results, the emission process groups were developed to be more detailed for SCCs within the 1626 - 1 risk modeling c ategory, but less detailed for emission units outside the category . (For example, we combined all boilers into one emission process group.) Allowable and acute multipliers for the pulp and paper subpart S category (MACT code 1626 - 1) are affiliated with the emission process groups . The basis for these multipliers is discussed in the sections below.

### 17

**VI. Actual**  **vs. Allowabl**  **e Emissions**  **A. Background**  In addition to evaluating the residual risks associated with actual emissions, EPA evaluates the risk associated with the emissions that would be allowed under the NESHAP, i.e., “allowable emissions,” since they reflect the maximum level that sources could emit and still comply with the national standards. Actual emissions are sometimes less than allowable emissions due to a compliance cushion, a more stringent state or local rule, or over- control due to the use of control technologies, equipment, or work practices that are significantly better than that required b y MACT. Any over- control from pulp and paper processes, e.g . , for mills using the subpart S clean condensate alternative or an equivalency-by-permit compliance option, would be site - specific and not estimable. The remainder of this section documents how multipliers were estimated to calculate allowable emissions. **B. Allowable Multipliers**  **for October 2011**  **Risk Modeling** Appendix E at the end of this memorandum lists the standards in subpart S to which pulp and paper production sources are subject. The sources include:  Kraft pulping vent gases  S oda or semichemical pulping vent gases  Sulfite pulping vent gases  New and existing bleaching vent gases  Kraft pulping process condensates Under subpart S, these sources were given a series of compliance options to choose from, including equipment standards, work practice standards, numeric emission limits, and a clean condensate alternative. Appendix E i dentifies the standard format for each of these compliance options. Based on industry responses to the Part I survey , we looked at the most commonly chosen subpart S compli ance options for each emission process group in determining how to estimate allowable multipliers for pulp and paper production sources. Equipment or work practice standards . For equipment standards and work practice standards, it is generall y assumed that allowable emissions equal actual emissions (because emissions ty

pically are not measured when equipment or work practices are in effect). Based on the survey

data we have received, we have determined that mills generally are not using equipment or work practices superior to that required by MACT. Therefore, we are assuming actual and allowable emissions are equivalent under the equipment and work practice standards, resulting in an allowable multiplier of 1. Numeric emission limits . For numeric emission limits, certain information is needed to estimate allowable multipliers, which varies depending on the type of limit. The subpart S compliance options include three types of numeric emission limits, including performance limits (percent reduction), concentration limits (parts per million by volume [ppmv] or weight [ppmw]), and production -based emission limits (pounds per ton of oven - dried pulp [lb/ton

### 18

ODP]). Appendix E i dentifies the types of information that is needed to calculate allowable multipliers. To calculate allowable multipliers based on performance limits (percent reduction), we would need to know the actual performance (percent reduction) level achieved, which is available from the survey responses for subpart S sources. To calculate allowable multipliers based on concentration limits (ppmv and ppmw), we would need to know the molecular weight of the pollutant, stack gas temperature, and stack gas flow rate. The numeric emission limits in subpart S use surrogate pollutants for total HAP, specifi call y methanol for pulping process vent gases and condensates and chlorine for bleaching processes. The molecular weights of methanol and chlorine could be used in allowable emissions calculations. B ased on our review of the survey responses for subpart S sources, most kraft mills have chosen to meet the equipment standards rather than the concentration limit s for kraft pulping vent gases and kraft pulping process condensates. Also, c alculatin g allowable multipliers based on concentration limits would be very site - specific and subject to considerable variability , depending on the stack gas temperature and flow rate data used in the calculations. Consequently, we have estimated allowable multipliers for kraft pulping vent gases and kraft pulping process condensates based on performance limits rather than concentration limits. To calculate allowable multipliers for sulfite mills based on their production -based emission limits (lb/ton ODP emitted), we would need information on actual production levels (e.g., ton ODP per ye ar), which is available from the survey responses for subpart S sources. Based on our review of the survey responses for subpart S sources, m ost sulfite mills have chosen to meet either the 0.89 lb/ton ODP limit (for Ca- and Na-based sulfite mills) or 2.2 lb/ton ODP limit (for NH 3 

### -based sulfite mills) . Although we have sufficient information from these mills’ Part Isurvey

responses to calculate their allowable emissions, we do not have sufficient information from the NEI on the actual pulping emissions for these mills to enable us to develop an allowable multiplier. Therefore, we instead used the equivalent 92 percent performance limit for Ca- and Na-based sulfite mills and 87 percent performance limit for NH 3 

### -based sulfite mills to calculate the allowable multipliers . (Note that there are no longer any M g -based sulfite mills in operation that would be subject to subpart S standards.) To calculate allowable multipliers for kraft pulping process condensates based on their production -based “remo val” emission limits (lb/ton ODP removed), we would need information on actual production levels (e.g., ton ODP per ye ar) and uncontrolled emissions (from which the limits would be subtracted) . However, we do not have uncontrolled emissions data for kraft pulping process condensates. Therefore, we instead used the equivalent 92 percent performance limit to calculate the allowable multiplier for kraft pulping process condensates. Clean condensate alternative (CCA) . Subpart S provides a clean condensate alternative, which is an emissions averaging approach to offset emissions from certain existing kraft pulping sources (e.g., high volume low concentration [HVLC] sources). Emissions reductions achieved under this compliance alternative are calculated on a site - specific basis and must be at least as great that those achieved through the kraft pulping HVLC system standards. Although the subpart S survey

responses showed a number of mills using the CCA option, we are not

### 19

evaluating this option for allowable emissions for the October 2011 risk modeling due to the site specific nature of the emissions calculations. Uncontrolled emission units . Actual and allowable emissions are equivalent for uncontrolled emission sources, resulting in an allowable multiplier of 1. Based on our anal ys is of the survey

data, most emission sources within the subpart S source category that were not subject to subpart S standards are uncontrolled. Emission units controlled under other emission standards . Permit limits requested in th e pulp and paper survey

were used to evaluate whether there are emission units in the pulp and paper industry

with emission limitations more stringent than the pulp and paper standards (in which case allowable emissions would be lower than the “MACT allowa ble” emissions). We found no directl y comparable information showing any HAP emission limitations more stringent than MACT are in place for subpart S sources . Allowable multipliers . For the October 2011 risk modeling, analysis of actual vs. allowable emissions is focused on the subpart S performance (percent reduction) limits and equipment or work practice standards. This anal ys is relies on actual emissions reductions presented in the Part I survey results (including actual emissions data and specific compliance options used). A summary

of the allowable multipliers for each emission source ty pe is provided in Table 7 at the end of this memorandum , and the allowable multipliers assigned to each emission process group for residual risk modeling are provided in Table 6 B . **VII. Acute**  **Exposure Estimation Approach**  **A. Background**  In addition to the chronic, long - term exposures addressed under cancer risk, EPA also considers acute, short- term exposures in its risk-based decision - making. Inthe absence of shortterm emissions data, EPA estimates peak, short- term emissions using available annual emissions data in the NEI. In previous RTR rulemakings, EPA has assumed that a facility ’s peak, 1 - hour emissi on rate could exceed its annual average hourly emission rate by

as much as a factor of 10, under worst - case meteorological conditions and the presence of a human receptor at the facility boundary . (EPA 2010) Inmeetings with pulp and paper industry representatives, we were tol d that a default peak- to - mean ratio of 10 was unrepresentative of some pulp and paper processes. The pulp and paper industry initiated a study

of peak- to - mean ratios for two pulp and paper emission sources—

papermaking and wastewater

—for EPA’s consideration . In order to refine the default - 10 assumption, peak hourly emission rates (lb/hr) (referred to in Part II of the pulp and paper survey as “routine emissions maximum hourly rate”) were collected in the Part II survey (the results for which were received on June 6, 2011). These peak hourly emission rates were reviewed as part of the Part II data review . Under ideal circumstances, these data would be used directly to evaluate acute, short- term exposures. However, the data provided by respondents had considerable inconsistencies. When compared to

### 20

the annual emissions (tpy) reported in the Part II survey (assuming 8,760 hours per year [ hr/y r] ) the primary

outliers identified were:  Underestimate of peak hourly emission rates

– The peak hourl y emission rate scaled to a peak annual emission rate did not exceed actual annual emissions.  Overestimate of peak hourly emission rates

– The peak hourl y emission rate scaled to a peak annual emission rate excessivel y exceeded actual annual emissions.  Zero emission rates

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

used to develop the acute multipliers for the October 2011 modeling is provided below. Table 8 presents the acute multipliers. **B. Acute Multipliers**  **for October 2011**  **Risk Modeling** Papermaking and w astewater . Pulp and paper industry representatives provided the following peak- to - mean ratios (acute multipliers):  Paper machines -- 1.6  Wastewater-- 2 Analys es from the industry to support these ratios are provided in Appendices F and G at the end of this memorandum . We have reviewed the papers and , through our own independent anal ys is of survey

data , found the rationale acceptable. We recommend using these ratios for the October 2011 risk modeling. The paper machine peak- to - mean ratio of 1.6 was developed considering peak- to - mean paper production rates. Emissions from all equipment in the paper mill are expected to be uncontrolled and have emissions somewhat related (either directl y or indirectl y) to paper machine production rate. Therefore, for purposes of the October 2011 modeling, we recommend using the paper machine peak- to - mean ratio of 1.6 for all equipment in the paper mill that is related to papermaking (e.g., stock preparation, repulping, dryers, etc.). The wastewater peak- to - mean factor of 2 was developed considering wastewater from primary clarifiers and aeration stabilization basins (ASBs) at kraft mills, but, for purposes of the October 2011 modeling, we recommend appl ying it to all wastewater treatment units (not just primary clarifiers and ASBs at kraft mills). Other processes . Part II of the pulp and paper survey (received June 6, 2011) requested information on annual emission rates (referred to in Part II as “routine emissions”) and peak

### 21

hourly emission rates (discussed above). Peak- to - mean (acute) ratios were derived from the Part II survey data as follows:  Mean = Average annual lb/hr = Routine emissions (tpy) / (8760 hr/yr) x (2000 lb/ton)  Peak = Routine emissi ons maximum hourly rate (lb/hr)  Peak/Mean = [Routine emissions maximum hourly rate (lb/hr)] / (Average annual lb/hr) As detailed above, the peak hourly emission rates provided by industry had outliers in the data set. Although these values were precluded from direct input into the short- term risk model, they can be used to develop more realistic acute multipliers, as industry has indicated that a default peak - to - mean ratio of 10 is unrepresentative. The following approach was used. All 1626 - 1 HAP emissions data from the Part II survey (57,281 records ) w ere compiled. A peak- to - mean ratio was calculated for each HAP or TRS compound from each emission source ty pe. Zero emission rates and all peak- to - mean ratios less than one were removed from the data set. A peak- to - mean ratio less than one indicates that the peak value provided is incorrect (does not exceed the average hourly emission rate and is , therefore , not a peak). The median peak- to mean ratio for each general equipment ty pe was then determined. Removing peak- to - mean values less than one and using the median value reduce d the e ffects of excessively low and unusually high outliers. It should be noted that we considered the startup and shutdown hourly rates collected in P art II in this anal ys is. However, the startup and shutdown data were sparse and, in all cases, the startup and shutdown hourly rates were the same as the rates provided for peak hourl y emissio n rate. Therefore, these data ultimately were not useful for anal ys is of peak- to - mean ratios. Acute multipliers . A summary of median peak- to - mean ratios (acute multipliers) for each emission source ty

pe is provided in Table 8 at the end of this memorandum , and the acute multipliers assigned to each emission process group for residual risk modeling are provided in Table 6 B . **VIII. Acrolein Data**  Appendix H provides EPA ’s conclusions regarding use of the acrolein data provided in the Part II survey

responses. **IX. References**  EPA 2006 a U.S. Environmental Protection Agency . 2005 National Emissions Inventory Data

& Documentation, Inventory Documentation, Mercury Speciation . Web site: http://www.epa.gov/ttn/chief/net/2005inventory .html . December 19, 2006 . EPA 2006b U.S. Environmental Protection Agency . An Inventory of Sources and

Environmental Releases of Dioxin -Like Compounds in the United States for the Years 1987, 1995, and 2000 . EPA/600/P - 03/002F. November 2006.

### 22

EPA 2010 U.S. Environmental Protection Agency . Draft Residual Risk Assessment for the

Chromic Acid Anodizing, Decorative Chromium Electroplating, and Hard Chromium Electroplating Source Categories . Appendix 4: Analysis of data on short - term emission rates relative to long - term emission rates. July 2010.

### 23

**Table 1. MACT**  **C odes**  **Used for**  **the October 2011**  **Pulp and Paper Risk Modeling MACT**  **code MACT source category**  0105 - 1 Stationary Reciprocating Internal Combustion Engines

– Natural Gas 0105 - 2 Stationary Reciprocating Internal Combustion Engines

– Oil 0107 - 1 Industrial/Commercial/ Institutional Boilers & Process Heaters

– coal 0107 - 2 Industrial/Commercial/ Institutional Boilers & Process Heaters

– gas 0107 - 3 Industrial/Commercial/ Institutional Boilers & Process Heaters

– oil 0107 -4 Industrial/Commercial/ Institutional Boilers & Process Heaters

– wood or waste 0108 - 1 Stationary Combustion Turbines

– Natural Gas 0108 - 2 Stationary Combustion Turbines

– Oil 0601 Gasoline Distribution (Stage I) 0602 Organic Liquids Distribution (Non - Gasoline) 0711 Paper & Other Webs (Surface Coating) 0714 Printing/Publishing (Surface Coating) 1626 - 1 Pulp & Paper Production

– Pulping and Bleaching Systems at Kraft, Soda, Sulfite, and

Semichemical Pulping Mills (Subpart S) 1626 - 2 Pulp & Paper Production

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

and Stand- alone Semichemical Pulping Mills (Subpart MM) 1626 - 3 Pulp and Paper Production

– NonMACT Faciliti es

### 24 **Table 2. New Pollutants Added to NEI Pollutant List**  **Pollutant code Description**  **Pollutant type a**  **Pollutant Category Nam e**  10049044 Chlorine Dioxide Chlorine Dioxide 100516 Benzyl Alcohol Benzyl Alcohol 100527 Benzaldehyde Benzaldehyde 107039 n- Propyl Mercaptan TRS 108601 Bis(2 - Chloroisopropyl) ether Bis(2 - Chloroisopropyl) ether 108941 Cyclohexanone Cyclohexanone 109795 n- Butyl Mercaptan TRS 110009 Furan Furan 110010 Tetrahydro - Thiophene Tetrahydro - Thiophene 110021 Thiophene Thiophene 110623 Valeraldehyde Valeraldehyde 110816 Diethyl Disulfide TRS 117840 Di - n - octyl phthalate Di - n - octyl phthalate 120832 2,4 - Dichlorophenol 2,4 - Dichlorophenol 123728 Butyraldehyde/n - Buty raldehyde Butyraldehyde/n - Buty raldehyde 124481 dibromochloromethane dibromochloromethane 127913 Beta - Pinene Beta - Pinene 1334787 m,p - Tolualdehyde m,p - Tolualdehyde 13466789 3 - Carene 3 - Carene 156592 1,2 - Dichloroethylene 1,2 - Dichloroethylene 27323188 Monochlorobiphenyl Monochlorobiphenyl 352932 Diethyl Sulfide TRS 37680685 Trichlorobiphenyl Polychlorinated Biphenyls 513440 Isobutyl Mercaptan TRS 529204 o - Tolualdehyde o - Tolualdehyde 540498 1,2 - Dibromoethene 1,2 - Dibromoethene 540590 1,2 - Dichloroethylene 1,2 - Dichloroethylene 5779942 2,5 - Dimethyl Benzaldehyde 2,5 - Dimethyl Benzaldehyde 590863 Isovaleraldehyde Isovaleraldehyde 5989275 Limonene Limonene 616444 Methyl Thiophene Methyl Thiophene 624895 Ethyl Methyl Sulfide TRS 624920 Dimethyl Disulfide TRS 638028 2,5 - Dimethyl thiophene 2,5 - Dimethyl thiophene 64175 Ethanol Ethanol 65850 Benzoic Acid Benzoic Acid 66251 Hexaldehyde Hexaldehyde 67630 Isopropanol [Isopropyl Alcohol] Isopropanol [Isopropyl Alcohol] 67641 Acetone Acetone 7429905 Aluminum Aluminum 7439896 Iron Iron 7439932 Lithium Lithium

### 25

**Pollutant code Description**  **Pollutant type a**  **Pollutant Category Nam e**  7439954 Magnesium Magnesium 7439987 Moly bdenum Moly bdenum Compounds 7440097 Potassium Potassium 7440213 Silicon Silicon 7440224 Silver Silver Compounds 7440235 Sodium Sodium 7440246 Strontium Strontium Compounds 7440280 thallium Thallium Compounds 7440315 Tin Tin Compounds 7440326 Titanium Titanium Compounds 7440393 Barium Barium Compounds 7440428 Boron Boron 7440508 Copper Copper Compounds 7440622 Vanadium Vanadium Compounds 7440655 Yttrium Yttrium Compounds 7440666 Zinc Zinc Compounds 7440699 Bismuth Bismuth 7440702 Calcium Calcium 74840 Ethane Ethane 74931 Methyl Mercaptan TRS 74953 Dibromomethane [methylene

bromide] Dibromomethane [methylene bromide] 75081 Ethyl Mercaptan TRS 75183 Dimethyl Sulfide TRS 75274 Bromodichloromethane Bromodichloromethane 75332 Isopropyl Mercaptan TRS 75661 Tert- Butyl Mercaptan TRS 75694 Trichlorofluoromethane Trichlorofluoromethane (CFC - 11) 76222 Camphor Camphor 7664939 Sulfuric Acid Sulfuric Acid 7782414 Fluorine Fluorine 78842 Isobutyraldehyde Isobutyraldehyde 79925 Camphene Camphene 80568 Alpha - Pinene Alpha - Pinene 84662 Diethyl Phthalate Diethyl Phthalate 85687 Butyl Benzyl Phthalate Butyl Benzyl Phthalate 872559 2 - Ethyl Thiophene 2 - Ethyl Thiophene 88755 2 -Nitrophenol 2 -Nitrophenol 95578 Chlorophenol [2 - Chlorophenol] Chlorophenol [2 - Chlorophenol] 95636 1,2,4 - Trimethylbenzene 1,2,4 - Trimethylbenzene 98555 Alpha - Terpineol Alpha - Terpineol 99854 gamma - Terpinene gamma - Terpinene 99876 p - Cymene p - Cymene

### 26

**Pollutant code Description**  **Pollutant type a**  **Pollutant Category Nam e**  CFC Chlorofluorocarbons CFC Nitrate Nitrate Compounds Nitrate Compounds TRS Total Reduced Sulfur OTH TRS TRS (H2S) Total Reduced Sulfur (as H2S) OTH TRS TRS as S Total Reduced Sulfur (as S) OTH TRS a. All are non - HAP pollutants.

### 27 **Table 3**  **. Chromium Speciation Approach for October 2011**  **Pulp and Paper Risk Modeling SCCs included in**  **October 2011 m odeling**  **Cr +6**  **m ultiplier for**  **October 2011 m**  **odeling 2**  **Comment on u**  **se of Cr +6**  **m ultiplier for**  **October 2011 m**  **odeling SCC**  **Short n**  **am e**  **1 Process**  **MACT c**  **ode** 10200201 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized

Coal: Wet Bottom 0107 - 1 0.12 10200202 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized

Coal: Dry Bottom 0107 - 1 0.12 10200203 Ext Comb /Industrial /Bitum/Subbit Coal /Cyclone

Furnace 0107 - 1 0.12 10200204 Ext Comb /Industrial /Bitum/Subbit Coal /Spreader

Stoker 0107 - 1 0.12 10200212 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized

Coal: Dry Bottom (Tangential) 0107 - 1 0.12 10200218 Ext Comb /Industrial /Bituminous Coal /Atmospheric

Fluidized Bed Combustion: Circulating Bed 0107 - 1 0.12 10200219 Ext Comb /Industrial /Bituminous Coal /Cogeneration 0107 - 1 0.12 10200222 Ext Comb /Industrial /Subbituminous Coal /Pulverized

Coal: Dry Bottom 0107 - 1 0.12 10200224 Ext Comb /Industrial /Subbituminous Coal /Spreader

Stoker 0107 - 1 0.12 10200401 Ext Comb /Industrial /Residual Oil /Grade 6 Oil 0107 - 3 0.18 10200501 Ext Comb /Industrial /Distillate Oil /Grades 1 and 2 Oil 0107 - 3 0.18 10200502 Ext Comb /Industrial /Distillate Oil /10 - 100 Million

Btu/hr ** 0107 - 3 0.18 10200601 Ext Comb /Industrial /Natural Gas /> 100 Million

Btu/hr 0107 - 2 0.04 10200602 Ext Comb /Industrial /Natural Gas /10 - 100 Million

Btu/hr 0107 - 2 0.04 10200603 Ext Comb /Industrial /Natural Gas /< 10 Million Btu/hr 0107 - 2 0.04 10200604 Ext Comb /Industrial /Natural Gas /Cogeneration 0107 - 2 0.04 10200799 Ext Comb /Industrial /Process Gas /Other: Specify in

Comments 0107 - 2 0.04 10200804 Ext Comb /Industrial /Petroleum Coke /Cogeneration 0107 - 1 0.12 10200901 Ext Comb /Industrial /Bark- fired Boiler 0107 - 4 0.56

### 28 **SCCs included in October 2011 m** **odeling Cr**  **+6 m**  **ultiplier for October 2011**  **m odeling**  **2 Comment on**  **u se of Cr**  **+6 m**  **ultiplier for October 2011**  **m odeling**  **SCC Short**  **n am** **e 1**  **Process MACT**  **c ode**  10200902 Ext Comb /Industrial /Wood/Bark- fired Boiler 0107 - 4 0.56 10200903 Ext Comb /Industrial /Wood - fired Boiler - Wet Wood

(:=20% moisture) 0107 - 4 0.56 10200907 Ext Comb /Industrial /Wood - fired Boiler - Wet Wood

(:=20% moisture) 0107 - 4 0.56 10200911 Ext Comb /Industrial /Wood/Bark Waste /Stoker boilers

** 0107 - 4 0.56 10200912 Ext Comb /Industrial /Wood/Bark Waste /Fluidized bed

combustion boiler 0107 - 4 0.56 10201002 Ext Comb /Industrial /LPG /Propane 0107 - 2 0.04 10201201 Ext Comb /Industrial /Solid Waste /Specify Waste

Material in Comments 0107 - 4 0.56 10201202 Ext Comb /Industrial /Solid Waste /Refuse Derived Fuel 0107 - 4 0.56 10500106 Ext Comb /Space Heater /Industrial /Natural Gas 0107 - 2 0.04 20200102 Int Comb /Industrial /Distillate Oil (Diesel)

/Reciprocating 0105 - 2 0.18 20200203 Int Comb /Industrial /Natural Gas /Turbine:

Cogeneration 0105 - 1 0.04 20200401 Int Comb /Industrial /Large Bore Engine /Diesel 0105 - 2 0.18 20201702 Int Comb /Industrial /Gasoline /Reciprocating Engine 0105 - 2 0.18 Cr+6 multiplier assumed to be same as for fuel oil. 20300101 Int Comb /Comm- Inst /Distillate Oil (Diesel)

/Reciprocating 0105 - 2 0.18 30700104 Sulfate (Kraft) Pulping /Recovery Furnace/Direct

Contact Evaporator 1626 - 2 0.171 NCASI TB 973 (Table 4.22) contains Cr+6 and total Cr emissions test data for one DCE recovery furnace. Total Cr emissions were non - detect (3.5E - 05 lb/ton BLS). Using 1/2 of the detection limit for total Cr, Cr+6 wa s approximately 17.1% of the total Cr. 30700105 Sulfate (Kraft) Pulping /Smelt Dissolving Tank 1626 - 2 0.148 NCASI TB 973 (Table 4.29) contains Cr+6 and total Cr emissions test data for one SDT. Total Cr emissions were 2.3E - 05 lb/ton BLS, and Cr+6 emissions were 3.40E - 06 lb/ton BLS, yielding a Cr+6 factor of 14.8%.

### 29 **SCCs included in October 2011 m** **odeling Cr**  **+6 m**  **ultiplier for October 2011**  **m odeling**  **2 Comment on**  **u se of Cr**  **+6 m**  **ultiplier for October 2011**  **m odeling**  **SCC Short**  **n am** **e 1**  **Process MACT**  **c ode**  30700106 Sulfate (Kraft) Pulping /Lime Kiln 1626 - 2 0.032 NCASI TB 973 (Table 4.27) contains Cr+6 and total Cr emissions test data for three lime kilns with wet scrubbers. The data were unable to be interpreted for two of the kilns because the Cr+6 data were non- detect, with detection limits higher than the corresponding detect data for the total Cr tests. A Cr+6 to total Cr ratio of 3.2% was observed for the third kiln. 30700110 Sulfate (Kraft) Pulping /Recovery Furnace/Indirect

Co ntact Evaporator 1626 - 2 0.229 NCASI TB 973 (Table 4.24) contains Cr+6 and total Cr emissions test data for three NDCE recovery furnaces. The average Cr+6 to total Cr ratio was 22.9% (ranging from 1.5% to 50.0%). 30700127 Sulfate (Kraft) Pulping / Non - condensible Gases

Incinerator 1626 - 1 0.04 NCGs are process gases. Most Cr+6 factors for process gas are 0.04, including for SCC 30790014 (Industrial Processes, Pulp and Paper and Wood Products, Fuel Fired Equipment, Process Gas: Incinerators). Only 6 records affected. Use Cr+6 = 0.04, same as "priority 2" default for SCC 30790014. 30700222 Sulfite Pulping /Recovery System: NH 3 1626 - 2 0.34 30700353 Soda / lime kiln 1626 - 2 0.032 Assume same multiplier as kraft lime kiln. 30700401 Paper and Paperboard Manufacture / Paper Machine /

Pulp Dryer 1626 - 1 0.04 This SCC represents paper machines (like SCC 30700405). Chromium from paper machines is likely attributed to combustion of natural gas in direct - fired dryers on the machine. Therefore, the Cr+6 factor should be 0.04 if we follow the convention for combustion of natural gas. 30900500 Fabricated Metal /Welding /General 1626 - 3 1 Cr+6 multiplier based on multiplier for SIC 2631 (priority 3) . 3 1 record. MACT code questionable. 40201301 Paper Coating /Coating Operation 0711 0 Chromium is not expected from this process (not a combustion process). Only 1 record (coater) - likely anomaly. Use 0 for Cr+6 factor. 1 The marker “**” is part of the SCC description and indicates notes related to SCC assignment (not relevant for this table). 2 The balance is considered Chromium III (Cr+3 ). For example, if the Cr+6 multiplier is 0.04, then 4% of total chromium is considered to be Chromium VI, and 96% is considered to be Chromium III. Unless otherwise sp ecified in the comments column, the Cr+6 multiplier is derived from EPA’s priority 1 list of NEI default Cr+ 6 multipliers. 3

### 30 3 NEI Chromium p rofile priorities: **Priority Hierarchy**  1 Use MACT code speciation profiles. NOTE: For pulp and paper (MACT codes 1626 - 1, 1626 - 2, 1626 - 3), use MACT code and SCC. 2 Use SCC speciation profiles if MACT code speciation profiles are unavailable. NOTE: Nonroad SCCs are truncated in table. 3 Use SIC code speciation profiles if MACT code and SCC speciation profiles are unavailable. 4 Use default speciation multiplier of 0.34 if MACT code, SCC, and SIC code speciation profiles are unavailable.

### 31

**Table 4**  **. POM Speciation Approach for**  **October 2011 Pulp and Paper Risk Modeling**  **Equipment Pollutant code**  **POM species POM multipliers**  Paper machines 85018 Phenanthrene 0.612 86737 Fluorene 0.101 129000 Py

rene 0.18 206440 Fluoranthene 0.108 Gas - fired paper machine dryers 85018 Phenanthrene 0.328 86737 Fluorene 0.054 91576 2 - Methylnaphthalene 0.463 129000 Py

rene 0.097 206440 Fluoranthene 0.058 Oil - fired paper machine dryers 91576 2 - Methylnaphthalene 1

### 32 **Table 5**  **. CDD/CDF Speciation Approach**  **Congener CDD/CDF**  **mean**

**emission factors for recovery furnaces**  **(ng/kg feed) Congener** 

**profile TEF**  **Annual emissions, tpy**

**NEI33135 --**  **1 --**  **1 --**  **1 NEI33135**  **-- 1**  **-- 2**  **-- 2**  **NEI41252 --**  **1 --**  **2 —** **2** Total CDD/CDF from file 1.27339E - 07 1.15774E - 06 7.99E - 07 2,3,7,8 - TCDD 0 0.00% 1 0 0 0 1,2,3,7,8 -PeCDD 0 0.00% 1 0 0 0 1,2,3,4,7,8 -HxCDD 0.001 0.03% 0.1 3.75963E - 12 3.41817E - 11 2.35902E - 11 1,2,3,6,7,8 -HxCDD 0.003 0.09% 0.1 1.13E - 11 1.03E - 10 7.07706E - 11 1,2,3,7,8,9 -HxCDD 0.006 0.18% 0.1 2.26E - 11 2.05E - 10 1.41541E - 10 1,2,3,4,6,7,8 -HpCDD 0.108 3.19% 0.01 4.06E - 11 3.69E - 10 2.54774E - 10 OCDD 1.033 30.50% 0.0003 1.17E - 11 1.06E - 10 7.3106E - 11 2,3,7,8 - TCDF 0.04 1.18% 0.1 1.50E - 10 1.37E - 09 9.43608E - 10 1,2,3,7,8 -PeCDF 0.03 0.89% 0.03 3.38367E - 11 3.07636E - 10 2.12312E - 10 2,3,4,7,8 -PeCDF 0.033 0.97% 0.3 3.72204E - 10 3.38399E - 09 2.33543E - 09 1,2,3,4,7,8 -HxCDF 0.007 0.21% 0.1 2.63174E - 11 2.39272E - 10 1.65131E - 10 1,2,3,6,7,8 -HxCDF 0.012 0.35% 0.1 4.51156E - 11 4.10181E - 10 2.83082E - 10 1,2,3,7,8,9 -HxCDF 0.005 0.15% 0.1 1.87982E - 11 1.70909E - 10 1.17951E - 10 2,3,4,6,7,8 -HxCDF 0.01 0.30% 0.1 3.75963E - 11 3.41817E - 10 2.35902E - 10 1,2,3,4,6,7,8 -HpCDF 0.024 0.71% 0.01 9.02E - 12 8.20E - 11 5.66165E - 11 1,2,3,4,7,8,9 -HpCDF 0 0.00% 0.01 0.00E+00 0.00E+00 0 OCDF 0.113 3.34% 0.0003 1.27E - 12 1.16E - 11 7.99708E - 12 Total TEQ 7.84E - 10 7.13E - 09 4.92E - 09 Other TCDD 0.106 3.13% Other PeCDD 0.013 0.38% Other HxCDD 0.094 2.78% Other HpCDD 0.144 4.25% Other TCDF 1.23 36.32% Other PeCDF 0.307 9.06%

### 33 **Congener CDD/CDF**  **mean**

**emission factors for recovery furnaces**  **(ng/kg feed) Congener** 

**profile TEF**  **Annual emissions, tpy**

**NEI33135 --**  **1 --**  **1 --**  **1 NEI33135**  **-- 1**  **-- 2**  **-- 2**  **NEI41252 --**  **1 --**  **2 —** **2** Other HxCDF 0.068 2.01% Other HpCDF 0 0.00% Total CDD/CDF 3.39 100.00% Source : U.S. Environmental Protection Agency. An Inventory of Sources and Environmental Releases of Dioxin - like Compounds in the United States for the Years 1987, 1995, and 2000 . EPA/600/P - 03/002F. November 2006. Page 5 - 44. Table 5 - 13: CDD/CDF mean emission factors (ng/kg feed) for black liquor recovery boilers; Column 4: NCASI (1995) (6 facilities); Nondetect set to zero.

### 34 **Table 6 A.**  **Emission Process Groups Assigned for Each SCC in the October 2011**  **Risk Modeling SCC**  **SCC Short Name**  **SCC EI Sector**  **Emission Process Group** 10200201 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized Coal:

Wet Bottom Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200202 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized Coal:

Dry Bottom Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200203 Ext Comb /Industrial /Bitum/Subbit Coal /Cyclone Furnace Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200204 Ext Comb /Industrial /Bitum/Subbit Coal /Spreader Stoker Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200205 Ext Comb /Industrial /Bitum/Subbit Coal /Overfeed Stoker Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200206 Ext Comb /Industrial /Bitum/Subbit Coal /Underfeed Stoker Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200212 Ext Comb /Industrial /Bitum/Subbit Coal /Pulverized Coal:

Dry Bottom (Tangential) Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200218 Ext Comb /Industrial /Bituminous Coal /Atmospheric

Fluidized Bed Combustion: Circulating Bed Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200219 Ext Comb /Industrial /Bituminous Coal /Cogeneration Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200222 Ext Comb /Industrial /Subbituminous Coal /Pulverized Coal:

Dry Bottom Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200224 Ext Comb /Industrial /Subbituminous Coal /Spreader Stoker Fuel Comb - Industrial Boilers, ICEs - Coal ICI Boiler/PH 10200401 Ext Comb /Industrial /Residual Oil /Grade 6 Oil Fuel Comb - Industrial Boilers, ICEs - Oil ICI Boiler/PH 10200402 Ext Comb /Industrial /Residual Oil /10 - 100 Million Btu/hr ** Fuel Comb - Industrial Boilers, ICEs - Oil ICI Boiler/PH 10200404 Ext Comb /Industrial /Residual Oil /Grade 5 Oil Fuel Comb - Industrial Boilers, ICEs - Oil ICI Boiler/PH 10200405 Ext Comb /Industrial /Residual Oil /Cogeneration Fuel Comb - Industrial Boilers, ICEs - Oil ICI Boiler/PH 10200501 Ext Com

b /Industrial /Distillate Oil /Grades 1 and 2 Oil Fuel Comb - Industrial Boilers, ICEs - Oil ICI Boiler/PH 10200502 Ext Comb /Industrial /Distillate Oil /10 - 100 Million Btu/hr ** Fuel Comb - Industrial Boilers, ICEs - Oil ICI Boiler/PH 10200503 Ext Com

b /Industrial /Distillate Oil /< 10 Million Btu/hr ** Fuel Comb - Industrial Boilers, ICEs - Oil ICI Boiler/PH 10200601 Ext Comb /Industrial /Natural Gas /> 100 Million Btu/hr Fuel Comb - Industrial Boilers, ICEs - Natural Gas ICI Boiler/PH 10200602 Ext Comb /Industrial /Natural Gas /10 - 100 Million Btu/hr Fuel Comb - Industrial Boilers, ICEs - Natural Gas ICI Boiler/PH 10200603 Ext Comb /Industrial /Natural Gas /< 10 Million Btu/hr Fuel Comb - Industrial Boilers, ICEs - Natural Gas ICI Boiler/PH 10200604 Ext Comb /Industrial /Natural Gas /Cogeneration Fuel Comb - Industrial Boilers, ICEs - Natural Gas ICI Boiler/PH

### 35

**SCC SCC**  **Short Name SCC EI**  **Sector Emission Process Group**  10200799 Ext Comb /Industrial /Process Gas /Other: Specify in

Comments Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 10200802 Ext Comb /Industrial /Petroleum Coke /All Boiler Sizes Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 10200804 Ext Comb /Industrial /Petroleum Coke /Cogeneration Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 10200901 Ext Com

b /Industrial /Bark- fired Boiler Fuel Comb - Industrial Boilers, ICEs - Biomass ICI Boiler/PH 10200902 Ext Comb /Industrial /Wood/Bark- fired Boiler Fuel Comb - Industrial Boilers, ICEs - Biomass ICI Boiler/PH 10200903 Ext Comb /Industrial /Wood - fired Boiler - Wet Wood (:=20%

mo isture) Fuel Comb - Industrial Boilers, ICEs - Biomass ICI Boiler/PH 10200904 Ext Comb /Industrial /Bark- fired Boiler (< 50,000 Lb Steam)

** Fuel Comb - Industrial Boilers, ICEs - Biomass ICI Boiler/PH 10200905 Ext Comb /Industrial /Wood/Bark- fired Boiler (< 50,000 Lb

Steam) ** Fuel Comb - Industrial Boilers, ICEs - Biomass ICI Boiler/PH 10200907 Ext Comb /Industrial /Wood/Bark Waste /Wood Cogeneration Fuel Comb - Industrial Boilers, ICEs - Biomass ICI Boiler/PH 1020091 1 Ext Comb /Industrial /Wood/Bark Waste /Stoker boilers ** Fuel Comb - Industrial Boilers, ICEs - Biomass ICI Boiler/PH 10200912 Ext Comb /Industrial /Wood/Bark Waste /Fluidized bed

combustion boiler Fuel Comb - Industrial Boilers, ICEs - Biomass ICI Boiler/PH 10201002 Ext Comb /Industrial /LPG /Propane Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 10201201 Ext Comb /Industrial /Solid Waste /Specify Waste Material in

Comments Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 10201202 Ext Comb /Industrial /Solid Waste /Refuse Derived Fuel Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 10201301 Ext Comb /Industrial /Liquid Waste /Specify Waste Material

in Comments Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 10201302 Ext Comb /Industrial /Liquid Waste /Waste Oil Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 10201401 Ext Comb /Industrial /CO Boiler /Natural Gas Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 10500106 Ext Com

b /Space Heater /Industrial /Natural Gas Fuel Comb - Industrial Boilers, ICEs - Natural Gas ICI Boiler/PH 10500110 Ext Comb /Space Heater /Industrial /Liquified Petroleum Gas

(LPG) Fuel Comb - Industrial Boilers, ICEs - Other ICI Boiler/PH 20200101 Int Comb /Industrial /Distillate Oil (Diesel) /Turbine Fuel Comb - Industrial Boilers, ICEs - Oil Turbine 20200102 Int Comb /Industrial /Distillate Oil (Diesel) /Reciprocating Fuel Comb - Industrial Boilers, ICEs - Oil RICE 20200201 Int Comb /Industrial /Natural Gas /Turbine Fuel Comb - Industrial Boilers, ICEs - Natural Gas Turbine 20200202 Int Comb /Industrial /Natural Gas /Reciprocating Fuel Comb - Industrial Boilers, ICEs - Natural Gas RICE

### 36

**SCC SCC**  **Short Name SCC EI**  **Sector Emission Process Group**  20200203 Int Comb /Industrial /Natural Gas /Turbine: Cogeneration Fuel Comb - Industrial Boilers, ICEs - Natural Gas Turbine 20200209 Int Comb /Industrial /Natural Gas /Turbine: Exhaust Fuel Comb - Industrial Boilers, ICEs - Natural Gas Turbine 20200301 Int Comb /Industrial /Gasoline /Reciprocating Engine Fuel Comb - Industrial Boilers, ICEs - Other RICE 20200401 Int Comb /Industrial /Large Bore Engine /Diesel Fuel Comb - Industrial Boilers, ICEs - Oil RICE 20201001 Int Comb /Industrial /Liquified Petroleum Gas /Propane:

Reciprocating Fuel Comb - Industrial Boilers, ICEs - Other RICE 20201702 Int Comb /Industrial /Gasoline /Reciprocating Engine Fuel Comb - Industrial Boilers, ICEs - Other RICE 20300101 Int Comb /Comm- Inst /Distillate Oil (Diesel) /Reciprocating Fuel Comb - Comm/Institutional - Oil RICE 30101814 Chem Manuf /Plastics Production /Extruder Industrial Processes - Chemical Manuf Chem Manuf 30101815 Chem Manuf /Plastics Production /Pellet Silo Industrial Processes - Storage and Transfer Chem Manuf 30187009 Chem Manuf /Inorganic Chem Stor (Fixed Roof Tanks)

/Sulfuric Acid: Breathing Loss Industrial Processes - Storage and Transfer Chem Manuf 30187097 Chem Manuf /Inorganic Chem Stor (Fixed Roof Tanks)

/Specify Liquid: Breathing Loss Industrial Processes - Storage and Transfer Chem Manuf 30190099 Chem Manuf /Fuel Fired Equipment /Specify in Comments

Field Industrial Processes - Chemical Manuf Chem Manuf 30501009 Coal Mining, Cleaning & Material Handling /Raw Coal

Storage Industrial Processes - Mining Coal Handling 30501010 Coal Mining, Cleaning & Material Handling /Crushing Industrial Processes - Mining Coal Handling 30501011 Coal Mining, Cleaning & Material Handling /Coal Transfer Industrial Processes - Mining Coal Handling 30501015 Coal Mining, Cleaning & Material Handling /L oading Industrial Processes - Mining Coal Handling 30501031 Coal Mining, Cleaning & Material Handling /Scrapers: Travel

Mode Industrial Processes - Mining Coal Handling 30501040 Coal Mining, Cleaning & Material Handling /Truck

Unloading: End Dump - Coal Industrial Processes - Mining Coal Handling 30501043 Coal Mining, Cleaning & Material Handling /Open Storage

Pile: Coal Industrial Processes - Mining Coal Handling 30501049 Coal Mining, Cleaning & Material Handling /Wind Erosion:

Exposed Areas Industrial Processes - Mining Coal Handling 30501099 Coal Mining, Cleaning & Material Handling /Other Not

Classified Industrial Processes - Mining Coal Handling 30502099 Stone Quarrying & Processing /Not Classified ** Industrial Processes - NEC Mineral Handling

### 37

**SCC SCC**  **Short Name SCC EI**  **Sector Emission Process Group**  30510199 Mineral Prods /Bulk Materials Conveyors /Other Not

Classified Industrial Processes - Storage and Transfer Mineral Handling 30510203 Mineral Prods /Bulk Materials Storage Bins /Coal Industrial Processes - Storage and Transfer Mineral Handling 30510204 Mineral Prods /Bulk Materials Storage Bins /Coke Industrial Processes - Storage and Transfer Mineral Handling 30510205 Mineral Prods /Bulk Materials Storage Bins /Limestone Industrial Processes - Storage and Transfer Mineral Handling 30510298 Mineral Prods /Bulk Materials Storage Bins /Mineral: Specify

in Comments Industrial Processes - Storage and Transfer Mineral Handling 30510299 Mineral Prods /Bulk Materials Storage Bins /Other Not

Classified Industrial Processes - Storage and Transfer Mineral Handling 30510303 Mineral Prods /Bulk Materials Open Stockpiles /Coal Industrial Processes - Storage and Transfer Mineral Handling 30510499 Mineral Prods /Bulk Materials Unloading Op /Other Not

Classified Industrial Processes - Storage and Transf er Mineral Handling 30531008 Coal Mining, Cleaning & Material Handling /Unloading Industrial Processes - Mining Coal Handling 30700101 Sulfate (Kraft) Pulping /Digester System - Continuous or

Batch Industrial Processes - Pulp & Paper Kraft Pulping: Digester LVHC 30700102 Sulfate (Kraft) Pulping /Brown Stock Washing System Industrial Processes - Pulp & Paper Kraft Pulping: Washing 30700103 Sulfate (Kraft) Pulping /Multi - effect Evaporators and

Concentrators Industrial Processes - Pulp & Paper Kraft Pulping: Evaporator LVHC 30700104 Sulfate (Kraft) Pulping /Recovery Furnace/Direct Contact

Evaporator Industrial Processes - Pulp & Paper DCE 30700105 Sulfate (Kraft) Pulping /Smelt Dissolving Tank Industrial Processes - Pulp & Paper SDT (Kraft) 30700106 Sulfate (Kraft) Pulping /Lime Kiln Industrial Processes - Pulp & Paper Lime Kiln 30700107 Sulfate (Kraft) Pulping /Turpentine Condenser Industrial Processes - Pulp & Paper Kraft Pulping: Turpentine LVHC 30700108 Sulfate (Kraft) Pulping /Fluid Bed Calciner Industrial Processes - Pulp & Paper Calciner 30700109 Sulfate (Kraft) Pulping /Black Liquor Oxidation System Industrial Processes - Pulp & Paper BLO 30700110 Sulfate (Kraft) Pulping /Recovery Furnace/Indirect Contact

Evaporator Industrial Processes - Pulp & Paper NDCE 30700112 Sulfate (Kraft) Pulping /Lime Mud Washers Industrial Processes - Pulp & Paper Causticizing: Lime Mud 30700113 Sulfate (Kraft) Pulping /Lime Mud Filter System Industrial Processes - Pulp & Paper Causticizing: Lime Mud 30700114 Sulfate (Kraft) Pulping /Bleach Plant Industrial Processes - Pulp & Paper Bleaching: Kraft 30700115 Sulfate (Kraft) Pulping /Chlorine Dioxide Generator Industrial Processes - Pulp & Paper Bleaching: ClO2 Generator 30700116 Sulfate (Kraft) Pulping /Turpentine Loading Facilities Industrial Processes - Pulp & Paper Kraft Pulping: Turpentine LVHC

### 38

**SCC SCC**  **Short Name SCC EI**  **Sector Emission Process Group**  30700117 Sulfate (Kraft) Pulping /Venting of condensate stripper offgases Industrial Processes - Pulp & Paper Condensate Stripper 30700119 Sulfate (Kraft) Pulping /Salt Cake Mix Tank (Boiler Ash

Handling) Industrial Processes - Pulp & Paper Salt Cake Tank 30700120 Sulfate (Kraft) Pulping /Stock Washing/Screening Industrial Processes - Pulp & Paper Kraft Stock Washing 30700121 Sulfate (Kraft) Pulping /Wastewater: General Industrial Processes - Pulp & Paper Wastewater (Kraft) 30700122 Sulfate (Kraft) Pulping /Causticizing: Miscellaneous Industrial Processes - Pulp & Paper Causticizing: Misc 30700123 Sulfate (Kraft) Pulping / Lime Slaker Vent Industrial Processes - Pulp & Paper Causticizing: Slaker 30700124 Sulfate (Kraft) Pulping / Black Liquor Storage Tanks Industrial Processes - Pulp & Paper Kraft Pulping: BL Tanks HVLC 30700125 Sulfate (Kraft) Pulping / Low Volume High Concentration

Syste m Venting of Non - condensible Gases Industrial Processes - Pulp & Paper Kraft Pulping: LVHC 30700126 Sulfate (Kraft) Pulping / High Volume Low Concentration

System Venting of Non - condensible Gases Industrial Processes - Pulp & Paper Kraft Pulping: HVLC 30700127 Sulfate (Kraft) Pulping / Non - condensible Gases Incinerator Industrial Processes - Pulp & Paper Kraft Pulping: Incinerator 30700128 Sulfate (Kraft) Pulping / Total Reduced Sulfur Thermal

Oxidizer Industrial Processes - Pulp & Paper Kraft Pulping: Incinerator 30700129 Sulfate (Kraft) Pulping / Enclosed secondary wastewater

treatment system vents Industrial Processes - Pulp & Paper Wastewater (Kraft) 30700130 Sulfate (Kraft) Pulping / Decker system Industrial Processes - Pulp & Paper Kraft Pulping: Decker 30700131 Sulfate (Kraft) Pulping / Knotter / Deknotter System Industrial Processes - Pulp & Paper Kraft Pulping: Knotter 30700132 Sulfate (Kraft) Pulping / Green Liquor Processing Industrial Processes - Pulp & Paper Causticizing: Green Li quor 30700133 Sulfate (Kraft) Pulping / White Liquor Processing Industrial Processes - Pulp & Paper Causticizing: White Liquor 30700134 Sulfate (Kraft) Pulping / Oxygen delignification system Industrial Processes - Pulp & Paper Kraft Pulping: O2 Delig HVLC 30700135 Sulfate (Kraft) Pulping / Pulp Storage - Bleached and

Unbleached Industrial Processes - Pulp & Paper Kraft Pulp Storage 30700136 Sulfate (Kraft) Pulping / Tall Oil System Industrial Processes - Pulp & Paper Tall Oil 30700199 Sulfate (Kraft) Pulping /Other Not Classified Industrial Processes - Pulp & Paper Kraft Misc 30700211 Sulfite Pulping /Digester/Blow Pit/Dump Tank: Calcium Industrial Processes - Pulp & Paper Sulfite Pulping (Ca) 30700214 Sulfite Pulping /Digester/Blow Pit/Dump Tank: NH3 with

Process Change Industrial Processes - Pulp & Paper Sulfite Pulping (NH3) 30700216 Sulfite Pulping / Bleach Plant Industrial Processes - Pulp & Paper Bleaching: Sulfite 30700222 Sulfite Pulping /Recovery System: NH3 Industrial Processes - Pulp & Paper Sulfite Recovery

### 39

**SCC SCC**  **Short Name SCC EI**  **Sector Emission Process Group**  30700224 Sulfite Pulping /Wastewater: General Industrial Processes - Pulp & Paper Wastewater (Sulfite) 30700231 Sulfite Pulping /Acid Plant: NH3 Industrial Processes - Pulp & Paper Sulfite Pulping (NH3) 30700233 Sulfite Pulping /Acid Plant: Ca Industrial Processes - Pulp & Paper Sulfite Pulping (Ca) 30700234 Sulfite Pulping /Knotters/Washers/Screens/etc. Industrial Processes - Pulp & Paper Sulfite Pulping 30700299 Sulfite Pulping /See Comment ** Industrial Processes - Pulp & Paper Sulfite Pulping 30700301 Neutral Sulfite Semichemical Pulping /Digester/Blow

Pit/Dump Tank Industrial Processes - Pulp & Paper NSSC Pulping 30700305 Neutral Sulfite Semichemical Pulping / Liquor Combustion Industrial Processes - Pulp & Paper NSSC Recovery 30700306 Neutral Sulfite Semichemical Pulping /Wastewater: General Industrial Processes - Pulp & Paper Wastewater (NSSC) 30700307 Neutral Sulfite Semichemical Pulping / Pulp washing system Industrial Processes - Pulp & Paper NSSC Pulping 30700308 Neutral Sulfite Semichemical Pulping / Pulp storage

tanks/stock chests Industrial Processes - Pulp & Paper NSSC Pulping 30700309 Neutral Sulfite Semichemical Pulping / Liquor storage tanks Industrial Processes - Pulp & Paper NSSC Misc 30700320 Semi - chemical (non - sulfur) / Pulp washing system Industrial Processes - Pulp & Paper Semichem Pulping 30700321 Semi - chemical (non - sulfur) / Pulp storage tanks/stock chests Industrial Processes - Pulp & Paper Semichem Pulping 30700322 Semi - chemical (non - sulfur) / Liquor making system Industrial Processes - Pulp & Paper Semichem Pulping 30700323 Semi - chemical (non - sulfur) / Liquor evaporator system Industrial Processes - Pulp & Paper Semichem Pulping 30700324 Semi - chemical (non - sulfur) / Liquor com bustion Industrial Processes - Pulp & Paper Semichem Recovery 30700325 Semi - chemical (non - sulfur) / Liquor storage tanks Industrial Processes - Pulp & Paper Semichem Pulping 30700326 Semi - chemical (non - sulfur) / Digesters/refiners/blow

tanks/blow heat recovery system Industrial Processes - Pulp & Paper Semichem Pulping 30700327 Semi - chemical (non - sulfur) / Smelt tank Industrial Processes - Pulp & Paper SDT (Semichem) 30700328 Semi - chemical (non - sulfur) /Wastewater: General Industrial Processes - Pulp & Paper Wastewater (Semichem) 30700329 Semi - chemical (non - sulfur) /Other Not Classified Industrial Processes - Pulp & Paper Semichem Misc 30700351 Soda / recovery furnace Industrial Processes - Pulp & Paper Soda Recovery 30700352 Soda / smelt tank Industrial Processes - Pulp & Paper SDT (Soda) 30700353 Soda / lime kiln Industrial Processes - Pulp & Paper Lime Kiln 30700354 Soda /Other Not Classified Industrial Processes - Pulp & Paper Soda Misc 30700399 Neutral Sulfite Semichemical Pulping /Other Not Classified Industrial Processes - Pulp & Paper NSSC Misc

### 40

**SCC SCC**  **Short Name SCC EI**  **Sector Emission Process Group**  30700401 Paper and Paperboard Manufacture / Paper Machine / Pulp

Dryer Industrial Processes - Pulp & Paper Papermaking 30700403 Pulpboard Manuf /Raw Material Storage and Handling Industrial Processes - Storage and Transfer Paper Misc 30700404 Secondary Fiber Pulping /Stock Preparation and Repulper Industrial Processes - Pulp & Paper Paper Stock Prep 30700407 Paper and Paperboard Manufacture /Coating Operations: On Machine Industrial Processes - Pulp & Paper Coating: On Machine 30700408 Secondary Fiber Pulping / Deinking operations Industrial Processes - Pulp & Paper Paper Stock Prep 30700409 Paper and Paperboard Manufacture / Coating Operations: OffMachine Industrial Processes - Pulp & Paper Coating: Off Machine 30700410 Secondary Fiber Pulping / Bleaching / Brightening /

Decoloring Industrial Processes - Pulp & Paper Bleaching: Sec Fiber 30700499 Paper and Paperboard Manuf /See Comment ** Industrial Processes - Pulp & Paper Paper Misc 30700501 Wood Pressure Treating /Creosote Industrial Processes - Pulp & Paper Wood Handling 30700801 Sawmill Operations /Log Debarking Industrial Processes - Pulp & Paper Wood Handling 30700820 Sawmill Operations /Chipping and Screening Industrial Processes - Pulp & Paper Wood Handling 30701199 Paper Coating & Glazing /Extrusion Coating Line with

Solvent Free Resin/Wax Industrial Processes - Pulp & Paper Paper Coating 30701201 Misc Paper Processes /Cyclones Industrial Processes - Pulp & Paper Paper Misc 30701202 Miscellaneous Paper Processes /Wastewater: General Industrial Processes - Pulp & Paper Wastewater (General) 30701220 Mechanical Pulping Ops / Thermomechanical Process and

Chemi - thermomechanical Pulping Industrial Processes - Pulp & Paper Mechanical Pulping 30701221 Mechanical Pulping Ops / Pressurized Groundwood / Stone

Groundwood Industrial Processes - Pulp & Paper Mechanical Pulping 30701222 Mechanical Pulping Ops/Bleaching / Brightening Industrial Processes - Pulp & Paper Bleaching: Mechanical 30701223 Mechanical and Recycle Paper Processes /Wastewater:

General Industrial Processes - Pulp & Paper Wastewater (Mechanical) 30701224 Mechanical Pulping Ops / Refiner Pulping Industrial Processes - Pulp & Paper Mechanical Pulping 30701399 Misc Paper Products /Other Not Classified Industrial Processes - Pulp & Paper Paper Misc 30704001 Pulp&Paper&Wood /Bulk Handling&Stor: Wood - Bark

/Storage Bins Industrial Processes - Storage and Transfer Wood Handling 30704002 Pulp&Paper&Wood /Bulk Handling&Stor: Wood - Bark

/Stockpiles Industrial Processes - Storage and Transfer Wood Handling 30704003 Pulp&Paper&Wood /Bulk Handling&Stor: Wood - Bark

/Unloading Industrial Processes - Storage and Transfer Wood Handling

### 41

**SCC SCC**  **Short Name SCC EI**  **Sector Emission Process Group**  30704004 Pulp&Paper&Wood /Bulk Handling&Stor: Wood - Bark

/Loading Industrial Processes - Storage and Transfer Wood Handling 30704005 Pulp&Paper&Wood /Bulk Handling&Stor: Wood - Bark

/Conveyors Industrial Processes - Storage and Transfer Wood Handling 30788801 Pulp&Paper&Wood /Fugitive Emissions /Specify in

Comments Field Industrial Processes - Pulp & Paper Fugitive Emissions - Misc 30799998 Pulp&Paper&Wood /Other Not Classified Industrial Processes - Pulp & Paper Paper Misc 30900500 Fabricated Metal /Welding /General Industrial Processes - NEC Welding 31299999 Misc Machinery Manuf /Other Not Classified Industrial Processes - NEC Misc Machinery Manuf 38500101 Industrial Process Cooling Tower /Mechanical Draft Industrial Processes - NEC Cooling Tower 38500110 Industrial Process Cooling Tower /Other Not Specified Industrial Processes - NEC Cooling Tower 39090003 Fuel Storage - Fixed Roof Tanks /Distillate Oil (No. 2):

Breathing Loss Industrial Processes - Storage and Transfer Petrol Storage - Transfer 39999999 Misc Manuf / Indus Processes /Other Not Classified Industrial Processes - NEC Manuf Misc 40100251 Degreasing : Stoddard (Petroleum Solvent): General

Degreasing Units Solvent - Degreasing Solvent Use 40100299 Degreasing : Other Not Classified: Open - top Vapor

Degreasing Solvent - Degreasing Solvent Use 40100301 Solvent Evap /Cold Solvent Cleaning/Stripping /Methanol Solvent - Degreasing Solvent Use 40100303 Solvent Evap /Cold Solvent Cleaning/Stripping /Stoddard

(Petroleum Solvent) Solvent - Degreasing Solvent Use 40100307 Solvent Evap /Cold Solvent Cleaning/Stripping /Isopropyl

Alcohol Solvent - Degreasing Solvent Use 40100399 Solvent Evap /Cold Solvent Cleaning/Stripping /Other Not

Classified Solvent - Degreasing Solvent Use 40188898 Solvent Evap /Fugitive Emissions /Specify in Comments Field Solvent - Degreasing Solvent Use 40200101 Surface Coating Application - General /Paint: Solvent-base Solvent - Industrial Surface Coating & Solvent Use Coating Misc 40200601 Surface Coating Application - General /Primer Solvent - Industrial Surface Coating & Solvent Use Coating Misc 40200701 Surface Coating Application - General /Adhesive Application Solvent - Industrial Surface Coating & Solvent Use Coating Misc 40200710 Surface Coating Application - General /Adhesive: General Solvent - Industrial Surface Coating & Solvent Use Coating Misc

### 42

**SCC SCC**  **Short Name SCC EI**  **Sector Emission Process Group**  40200801 Surface Coating Oven - General /General Solvent - Industrial Surface Coating & Solvent Use Coating Misc 40200901 Surface Coating /Thinning Solvents - General /General:

Specify in Comments Solvent - Industrial Surface Coating & Solvent Use Coating Misc 40201001 Surface Coating Oven Heater /Natural Gas Solvent - Industrial Surface Coating & Solvent Use Coating Misc 40201301 Paper Coating /Coating Operation Solvent - Industrial Surface Coating & Solvent Use Paper Coating 40201303 Paper Coating /Coating Mixing Solvent - Industrial Surface Coating & Solvent Use Paper Coating 40201304 Paper Coating /Coating Storage Industrial Processes - Storage and Transfer Paper Coating 40201305 Paper Coating /Equipment Cleanup Solvent - Industrial Surface Coating & Solvent Use Paper Coating 40201399 Paper Coating /Other Not Classified Solvent - Industrial Surface Coating & Solvent Use Paper Coating 40202605 Surface Coating /Steel Drums /Equipment Cleanup Solvent - Industrial Surface Coating & Solvent Use Coating Misc 40204435 Fabric Coating, Transfer Coating /Lamination: Laminating

Device Solvent - Industrial Surface Coating & Solvent Use Coating Misc 40288824 Surface Coating /Fugitive Emissions /Clean - up Solvent - Industrial Surface Coating & Solvent Use Coating Misc 40299998 Surface Coating /Miscellaneous /Specify in Comments Field Solvent - Industrial Surface Coating & Solvent Use Coating Misc 4040 0102 Petrol Prod Stor- Bulk Terminals /Gasoline RVP 10: Breathing

Loss (67000 BBL) - Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage - Transfer 40400104 Petrol Prod Stor- Bulk Terminals /Gasoline RVP 13: Breathing

Loss (250000 BBL) - Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage - Transfer 40400107 Petrol Prod Stor- Bulk Terminals /Gasoline RVP 13: Working

Loss (Diam Independent) - Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage - Transfer 40400108 Petrol Prod Stor- Bulk Terminals /Gasoline RVP 10: Working

Loss (Diam Independent) - Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage - Transfer 40400121 Petrol Prod Stor- Bulk Terminals /Diesel Fuel: Standing Loss

(Diam Independent) - Fixed Roof Tank Bulk Gasoline Terminals Petrol Storage - Tran sfer 40400199 Petrol Prod Stor- Bulk Terminals /See Comment ** Bulk Gasoline Terminals Petrol Storage - Transfer 40400316 Oil&Gas Field Stor&Workg Tanks /Fixed Roof Tank, Diesel,

working+breathing+flashing losses Industrial Processes - Storage and Transfer Petrol Storage - Transfer

### 43

**SCC SCC**  **Short Name SCC EI**  **Sector Emission Process Group**  40400403 Petrol Prod Stor-Underground Tanks /Gasoline RVP 10:

Breathing Loss Bulk Gasoline Terminals Petrol Storage - Transfer 40400404 Petrol Prod Stor-Underground Tanks /Gasoline RVP 10:

Working Loss Bulk Gasoline Terminals Petrol Storage - Transfer 40400413 Petrol Prod Stor-Underground Tanks /Distillate Fuel #2:

Breathing Loss Bulk Gasoline Terminals Petrol Storage - Transfer 40500201 Print- Publish /General /Letter Press: 2751 Solvent - Graphic Arts Print- Publish 40500215 Print- Publish /General /Letterpress: Cleaning Solution Solvent - Graphic Arts Print- Publish 40500301 Print- Publish /General /Printing: Flexographic Solvent - Graphic Arts Print- Publish 40600401 Petrol Trans & Marketg /Filling Vehicle Gas Tanks - Stage II

/Vapor Loss w/o Controls Gas Stations Petrol Storage - Transfer 40688801 Petrol Trans & Marketg /Fugitive Emissions /Specify in

Comments Field Industrial Processes - Storage and Transfer Petrol Storage - Transfer 40700814 Organic Chem Storage - Fixed Roof Tanks - Isopropyl

Alcohol: Working Loss Industrial Processes - Storage and Transfer Storage Tanks - Alcohol 40700815 Organic Chem Storage - Fixed Roof Tanks - Methyl Alcohol:

Breathing Loss Industrial Processes - Storage and Transfer Storage Tanks - Methanol 40700816 Organic Chem Storage - Fixed Roof Tanks - Methyl Alcohol:

Working Loss Industrial Processes - Storage and Transfer Storage Tanks - Methanol 40701698 Organic Chem Storage - Fixed Roof Tanks - Specify Alkane:

Working Loss Industrial Processes - Storage and Transfer Storage Tanks - Organic 40708098 Organic Chem Storage - Fixed Roof Tanks - Specify Nitro

Com pound in Comments: Working Loss Industrial Processes - Storage and Transfer Storage Tanks - Organic 40799997 Organic Chem Storage - Miscellaneous /Specify in Comments Industrial Processes - Storage and Transfer Storage Tanks - Organic 49099998 Solvent Evap /Misc Volatile Organic Evaporation /Identify the

Process and Solvent in Comments Solvent - Industrial Surface Coating & Solvent Us e Solvent Use 50300101 Waste Disp - Indus /Incineration /Multiple Chamber Waste Disposal Waste Disposal - Incineration 50300602 Waste Disp - Indus /Landfill Dump /Liquid Waste Disposal Waste Disposal Landfill 50300801 Waste Disp - Indus /Treatment, Storage, Disp /Surface

Im poundment: Fugitive Emissions Waste Disposal Waste Disposal - Fugitive Emissions 50300810 Waste Disp - Indus /Treatment, Storage, Disp /Waste Piles:

Fugitive Emissions Waste Disposal Waste Disposal - Fugitive Emissions 50300899 Waste Disp - I ndus /Treatment, Storage, Disp /General:

Fugitive Emissions Waste Disposal Landfill 50390006 Waste Disp - Indus /Auxillary Fuel -No Emissions /Natural Gas Waste Disposal Waste Disposal - Incineration

### 44

**Table 6**  **B .**  **Allowable and Acute Multipliers for Emission Process Groups for the**  **October 2011**  **Pulp and Paper Risk Modeling Emission**  **process group Process MACT**  **code Allowable multiplier**  **Acute multiplier**  Bleaching: ClO 2 Generator 1626 - 1 1.4 for chlorinated HAP; 1 for chloroform or non - chlorinated HAP 1.4 Bleaching: Kraft 1626 - 1 1.4 for chlorinated HAP; 1 for chloroform or non - chlorinated HAP 1.4 Bleaching: Mechanical 1626 - 1 1.4 for chlorinated HAP; 1 for chloroform or non - chlorinated HAP 1.4 Bleaching: Sec Fiber 1626 - 1 1.4 for chlorinated HAP; 1 for chloroform or non - chlorinated HAP 1.4 Bleaching: Sulfite 1626 - 1 1.4 for chlorinated HAP; 1 for chloroform or non - chlorinated HAP 1.4 BLO 1626 - 2 Calciner 1626 - 2 Causticizing: Green Liquor 1626 - 1 1 1.5 Causticizing: Lime Mud 1626 - 1 1 1.5 Causticizing: Misc 1626 - 1 1 1.5 Causticizing: Slaker 1626 - 1 1 1.5 Causticizing: White Liquor 1626 - 1 1 1.5 Chem Manuf 1 1626 - 1 , - 3 Coal Handling 1626 - 3 Coating Misc 0711 Coating: Off Machine 0711 Coating: On Machine 0711 Condensate Stripper 1626 - 1 1.6 1.2 Cooling Tower 1626 - 3 DCE 1626 - 2 Fugitive Emissions - Misc 1626 - 3 ICI Boiler/PH 0107 - 1, - 2,

- 3, - 4 Kraft Misc 1626 - 1 1 1.2 Kraft Pulp Storage 1626 - 1 1 1.2 Kraft Pulping: BL Tanks HVLC 1626 - 1 1 1.2 Kraft Pulping: Decker 1626 - 1 1 1.2 Kraft Pulping: Digester LVHC 1626 - 1 1 1.2 Kraft Pulping: Evaporator LVHC 1626 - 1 1 1.2 Kraft Pulping: HVLC 1626 - 1 1 1.2 Kraft Pulping: Incinerator 1626 - 1 1 1.2

### 45

**Emission process group**  **Process MACT code**  **Allowable multiplier Acute**  **multiplier** Kraft Pulping: Knotter 1626 - 1 1 1.2 Kraft Pulping: LVHC 1626 - 1 1 1.2 Kraft Pulping: O 2 Delig HVLC 1626 - 1 1 1.2 Kraft Pulping: Turpentine LVHC 1626 - 1 1 1.2 Kraft Pulping: Washing 1626 - 1 1 1.2 Kraft Stock Washing 1626 - 1 1 1.2 Landfill 1626 - 3 Lime Kiln 1626 - 2 Manuf Misc 2 1626 - 1, - 3 , 0107 -4 1 1.4 Mechanical Pulping 1626 - 1 1 3.1 Mineral Handling 1626 - 3 Misc Machinery Manuf 1626 - 3 NDCE 1626 - 2 NSSC Misc 1626 - 1 1 1 NSSC Pulping 1626 - 1 1 1 NSSC Recovery 1626 - 2 Paper Coating 0711 Paper Misc 2 1626 - 1 , - 3 1 1.6 Paper Stock Prep 1626 - 1 1 1.6 Papermaking 1626 - 1 1 1.6 Petrol Storage - Transfer 0601, 0602 Print -Publish 0714 RI CE 0105 - 1, - 2 Salt Cake Tank 1626 - 2 SDT (Kraft) 1626 - 2 SDT (Semichem) 1626 - 2 SDT (Soda) 1626 - 2 Semichem Misc 1626 - 1 1 1 Semichem Pulping 1626 - 1 1 1 Semichem Recovery 1626 - 2 Soda Misc 1626 - 1 1 1.2 Soda Recovery 1626 - 2 Solvent Use 1 1626 - 1 , - 3 Storage Tanks - Alcohol 1626 - 1 1 1.6 Storage Tanks - Methanol 1626 - 1 1 1.6 Storage Tanks

– Organic 1 0602, 1626 - 1 Sulfite Pulping 1626 - 1 2.7 1.6

### 46

**Emission process group**  **Process MACT code**  **Allowable multiplier Acute**  **multiplier** Sulfite Pulping (Ca) 1626 - 1 2.7 1.6 Sulfite Pulping (NH 3 ) 1626 - 1 1.6 1.6 Sulfite Recovery 1626 - 2 Tall Oil 1626 - 1 1 1.2 Turbine 0108 - 1, - 2 Waste Disposal - Fugitive Emissions 1626 - 3 Waste Disposal

– Incineration 1626 - 3 Wastewater (General) 1626 - 1 1 2 Wastewater (Kraft) 1626 - 1 1.6 2 Wastewater (Mechanical) 1626 - 1 1 2 Wastewater (NSSC) 1626 - 1 1 2 Wastewater (Semichem) 1626 - 1 1 2 Wastewater (Sulfite) 1626 - 1 1 2 Welding 1626 - 3 Wood Handling 1626 - 3 1 No multipliers needed for these 1626 - 1 sources ; only criteria air pollutant emissi ons . 2 Multipliers apply to 1626 - 1 sources only.

### 47 **Table 7**  **. Allowable Multipliers**  **by Emission Source Type for Risk**  **Modeling for Subpart S (MACT Code 1626 -**  **1) Emission source**  **type Subpart S performance**  **level (percent reduction) Reported**  **actual performance level (percent**  **reduction) 1**  **October 2011 a** **llowable multiplier**  **2** Bleaching Chlorinated HAP 99% 99. 3 % 1.4 Chloroform work practice NA 1 Non - chlorinated HAP NA NA 1 Kraft pulping Performance limit 98% 99% 2 Equipment standards NA NA 1 3 Kraft pulping process condensates 4 92% 95% 1.6 Soda or semichemical pulping Performance limit 98% 99% 2 Equipment standards NA NA 1 3 Sulfite pulping Ca or Na sulfite 92% 9 7 % 2.7 NH 3 or Mg sulfite 87% 92 % 1.6 Uncontrolled emission units 5 NA NA 1 1 These reported values for percent reduction are based on survey data received. 2 The allowable multiplier is calculated as follows (using kraft pulping vent gases as an example and canceling out uncontrolled tpy): Allowable multiplier = Allowable = (1

– subpart S limit % reduction) = (1

– 0.9 8 ) = 0.02 = 2 Actual (1

– actual % reduction) (1

– 0.99) 0.01 3 The multiplier for equipment standards is recommended for use in the October 2011 risk modeling because most kraft, soda, and semichemical mills are demonstrating com

pliance with s ubpart S by meeting one of the three equipment standards for kraft, soda, and semichemical pulping . 4 The allowable multiplier wo uld apply for emissions from kraft pulping process condensates , which would typically either be treated by steam stripping or biological treatment (i.e., wastewater treatment). This value is recommended for application to kraft pulping wastewater for the October 2011 risk modeling . 5 For example, causticizing, mechanical pulping, papermaking, storage tanks, non - kraft wastewater , and miscellaneous manufacturing.

### 48 **Table 8**  **. A**  **cute Multipliers**  **by Emission Source**  **Type for Risk**  **Modeling for Subpart S (MACT Code 1626 -**  **1) Emission source**  **type Median peak** **- to**  **- mean ratio**  **(acute multiplier) Notes**  Bleaching 1.4 Causticizing 1.5 Kraft pulping 1.2 Mechanical pulping 3.1 Miscellaneous manufacturing 1.4 No data; assigned based on median of other values Neutral sulfite semichemical pulping 1.0 Non - sulfur s emichemical pulping 1.0 Papermaking 1.6 Industry value used ; data confirmed by our analysis Soda pulping 1.2 Storage tanks 1.6 Sulfite pulping 1.6 Wastewater 2.0 Industry value used; data confirmed by our analysis

### Appendix A **Checklist to R eview NEI**  **Update S preadsheets** 

### A - 1 **Checklist to Review NEI Update Spreadsheets** Name of reviewer

_______ Date of review

_______ NEI ID

_______ RTI ID (in tracking spreadsheet)

_______ Mill type (in tracking spreadsheet; check all that apply) □ kraft □ sod a □ sulfit e □ semi chemica l □ mechanical

(TMP, RMP, SGW, PGW ) □ non woo d □ secondary

fiber (incl . de inking) □ NA

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

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

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

________________________________________________________________ Kraft: 30700101 - 199, and 401

________________________________________________________________ Soda: 30700101 - 199, 351 - 354, and 401 Sulfite: 30700214 - 299, and 401

________________________________________________________________ Semichemical: 30700301 - 329, and 401 Mechanical: 30701220 - 224, and 401

________________________________________________________________ Secondary fiber: 30700401 - 410 and 30701202 Paper only: 30700401 - 410, and 30701202 Are the pollutants what we expect to see? □ ye s □ n o

________________________________________________________________ E.g., acetaldehyde, cresols, formaldehyde, methanol, phenol, styrene, toluene, xylenes, TRS, VOC ________________________________________________________________ Are there any missing stack or fugitive parameters? □ ye s □ n o

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

________________________________________________________________ Any other observations? Any recommended changes? ________________________________________________________________

________________________________________________________________

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

### Pulping process **Subpart S e quipment**  **SCC Kraft**  Bleaching s ys tem 30700114, 30700115 Causticizing system 30700112, 30700113, 30700122, 30700123, 30700132, 30700133 Decker s ys tem 30700130 Digester s ys tem 30700101 Evaporator s ys tem 30700103 HVLC system 30700126 Knotter system 30700131 LVHC system 30700125 In cinerator/thermal oxidizer 30700127, 30700128 Oxygen delignification system 30700134 Papermaking s ys tem 30700401 Process wastewater treatment system 30700121 Pulp washing s ys tem 30700102 Screen s ys tem 30700120 Tall oil reactor s ys tem 30700136 Turpentine recovery

system 30700107, 30700116 Weak liquor storage tank 30700124 **Soda** Bleaching s ys tem 30700114, 30700115, 30700354 LVHC system 30700125, 30700354 Papermaking s ys tem 30700401, 30700354 Process wastewater treatment system 30700121, 30700354 Pulp washing s ys tem 30700102, 30700354 **Semichemical (NSSC)** LVHC system 30700301, 30700302 Papermaking s ys tem 30700401 Process wastewater treatment system 30700306 Pulp washing s ys tem 30700307

### A - 3

**Pulping process Subpart S e**  **quipment SCC**  **Semichemical (non -**  **sulfur)** LVHC system 30700323, 30700326 Papermaking s ys tem 30700401 Process wastewater treatment system 30700328 Pulp washing s ys tem 30700320 **Sulfite** Acid condensate storage tank 30700231 Bleaching s ys tem 30700216 Digester s ys tem 30700214 Evaporator s ys tem 30700222 Papermaking s ys tem 30700401 Process wastewater treatment system 30700224 Pulp washing s ys tem 30700234 Strong liquor storage tank 30700234 Weak liquor storage tank 30700234 **Mechanical** Bleaching s ys tem 30701222 Papermaking s ys tem 30700401 Process wastewater treatment system 30701223 Pulping system 30701220, 30701221, 30701224 **Secondary fiber** Bleaching s ys tem 30700410 Papermaking s ys tem 30700401 Process wastewater treatment system 30701202 Repulping s ys tem 30700404 **None (paper production only)** Bleaching s ys tem 30700410 Papermaking s ys tem 30700401 Process wastewater treatment system 30701202 1 

### HVLC = high - volume, low - concentration; LVHC = low - volume, high - concentration; NSSC = neutral sulfite semichemical.

### Appendix B **Parameters for Modeling of Paper Machine Emissions**

### B - 1 

# ncasi P.O. Box 13318, Research Triangle Park, NC 27709 - 3318 919 - 941 - 6400



# MEMORANDUM DATE: January 18, 2011 TO: Bill Schrock, EPA FROM: John Pinkerton SUBJECT: Parameters for Modeling of Paper Machine Emissions During the January 13 working session, there was some discussion of ho w paper machine emissions were being mo deled. Apparently if a paper machine source is coded in the NEI as a fugitive source, the default parameters for a fugitive source are assigned unless building dimensions (height, length, width, orientation) have been entered. The default parameters are a height of 10 feet, temperature of 72°F, exit velocity of 0.0003 ft/sec, and a diameter of 0.003 ft. These fugitive default parameters are not reflective of paper machine emission sources. Where paper machine sources are coded as stack emission points, the EPA default parameters for SCC 30700401 (paper machine/pulp dryer), 30700405 (paper/board forming), and 30700407 (coating operations: on - machine) are as follows: SCC Ty

pe Height Tem perature Exit Velocity Flow Rate 30700401 Stack 56 ft 50oC 19.4 ft/sec 13,560 acfm 30700405 Stack 62 ft 60oC 34.3 ft/sec 32,220 acfm 30700407 Stack 45 ft 78oC 33.7 ft/sec 233,000 acfm Paper machines are typically located in a long, rectangular building with a flat roof. There are multiple roof vents above the paper machine, many of which have fans to exhaust the building air. The number and type of vents, and vent gas characteristics (flow rate, exit velocity, gas temperature, moisture level), vary considerably from machine to mach ine. The total amount of air exhausted from a paper machine building is not necessarily related to the production capacity of the paper machine. Thus it is difficult to develop a ‘default’ set of parameters representing a ‘typical’ paper machine. NCASI has performed sampling at a number of paper machines over the last 20 years. The following averages are based on information contained in various NCASI reports and company -provided permitting materials. Obviously values for any given paper machine could depart significantly from these averages. Number of vents on wet end (with bulk of exhaust gas)

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

– 6 Vent height

– 70 ft above grade Average vent gas exit velocity

– 30 ft/sec Average vent gas flow rate

– 30,000 dscfm Wet end vent gas parameters

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

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

– 200 m Building width

– 30 mThese averages for dry end sources do not include vents associated with on - machine coaters that have direct- fired

dryers, nor do they include vents for direct- fired Yankee dryers (both of which have relatively high flow rates and tem peratures). Where detailed paper machine source characteristics are not contained in the NEI files, the above average values represent reasonable choices for dispersion modeling purposes. It is suggested that EPA replace any NEI default parameters for SCCs 30700401 and 30700405 with these averages, and model them as stack sources. Further, in Part I of the upcoming survey, we suggest the instructions indicate that the above values will be used for all paper machines in future EPA modeling and risk assessments unless the mill is able to provide more detailed site specific parameters.

### Appendix **C**

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

### C - 1

**Engineering Estimates for Fugitive Length and Width Parameters for Pulp and Paper Fugitive Emission Sources SCC**  **Short Name Notes**  **1 Fugitive**  **Length (ft)**  **Fugitive**

**Width (ft)**  **Fugitive**

**Angle (deg)**  10200503 Ext Comb /I ndustrial /Distillate Oil /< 10 Million Btu/hr ** Based on parameters for similar SCCs. 20 20 0 20200301 Int Comb /I ndustrial /Gasoline /Reciprocating Engine Based on parameters for similar SCCs. 20 20 0 30187009 Chem Manuf /I norganic Chem Stor (Fixed Roof Tanks) /Sulfuric Acid: Breathing Loss Assumed. 8 8 0 30187097 Chem Manuf /I norganic Chem Stor (Fixed Roof Tanks) /Specify Li quid: Breathing Loss Assumed. 8 8 0 30700101 Sulfate (Kraft) Pulping /Digester System - Continuous or Batch Digesters are generally the same size regardless of pulping operations. Capacity is generally increased by adding an additional digester, not expanding one's size. 20 20 0 30700102 Sulfate (Kraft) Pulping /Brown Stock Washing System Brownstock washers are usually about the same size. Brownstock washing capacity is generally increased with the addition of a new washer(s). Washing capacity is relative to the bleaching capacity (via simple mass balance). Some backup pulp is stored before bleaching to prevent downtime. These estimates are per washer. 8 18 0

30700103 Sulfate (Kraft) Pulping /Multi - effect Evaporators and Concentrators 110 110 0 30700106 Sulfate (Kraft) Pulping /Lime Kiln 300 20 0 30700107 Sulfate (Kraft) Pulping /Turpentine Condenser Basic reaction vessel. These are per vessel. 5 5 0 30700110 Sulfate (Kraft) Pulping /Recovery Furnace/I ndirect Contact Evaporator 50 50 0 30700111 Sulfate (Kraft) Pulping /Filtrate Tanks These are smaller stationary storage tanks. These are per tank. 8 8 0 30700112 Sulfate (Kraft) Pulping /Lime Mud Washers These are almost the same as a lime mud filter in capacity and design. These are per washer. 10 10 0 30700113 Sulfate (Kraft) Pulping /Lime Mud Filter System Lime mud filters are relative to the size of the recovery operation. These are usually similar in size to a washer. These estimates are per filter. 10 18 0 30700114 Sulfate (Kraft) Pulping /Bleach Plant Modern bleach plants could be confined to roughly a 2 - acre footprint. This includes all additional equipment. 300 300 0 30700115 Sulfate (Kraft) Pulping /Chlorine Dioxide Generator This estimate is based on one reaction vessel, not the entire processing site. 15 25 0 30700116 Sulfate (Kraft) Pulping /Turpentine Loading Facilities This is a covered pad or building for trucks or tankers to receive turpentine byproducts. 8 40 0 30700117 Sulfate (Kraft) Pulping /Venting of condensate stripper off - gases This is a smaller a stack. These are per stack. 2 2 0 30700118 Sulfate (Kraft) Pulping /Liquor Clarifiers Li quor clarifiers are relative to the size of the pulping operation. These are usually similar to a tank/holding vessel. These estimates are per clarifier. 25 25 0 30700119 Sulfate (Kraft) Pulping /Salt Cake Mix Tank (Boiler Ash Handling) 25 25 0 30700120 Sulfate (Kraft) Pulping /Stock Washing/Screening Same basic idea as brownstock washers. Washers are generally the same in a pulping operation. 8 18 0 30700121 Sulfate (Kraft) Pulping /Wastewater: General Used the fugitive parameters from section III of this memo. 829 166 0 30700122 Sulfate (Kraft) Pulping /Causticizing: Miscellaneous Assumptions were made based on the size of one causticizing vessel. These estimates are per causticizer. 20 20 0 30700123 Sulfate (Kraft) Pulping / Lime Slaker Vent 2 2 0**SCC Short Name**  **Notes 1**  **Fugitive Length**  **(ft) Fugitive** 

**Width (ft)**  **Fugitive**

**Angle (deg)**  30700124 Sulfate (Kraft) Pulping / Black Liquor Storage Tanks These are usually large holding tanks. I would estimate that smaller units are typically 100k- 250k gallons. Most tanks today are 1 million gallon capacity. These estimates are per tank. 35 35 0 30700125 Sulfate (Kraft) Pulping / Low Volume High Concentration System

Venting of Non - condensible Gases These are similar to pressure relief valves. These are on a per vent basis (multiple vents are likely). 1 1 0 30700126 Sulfate (Kraft) Pulping / High Volume Low Concentration System

Venting of Non - condensible Gases These are similar to pressure relief valves. These are on a per vent basis (multiple vents are likely). 1 1 0 30700127 Sulfate (Kraft) Pulping / Non - condensible Gases I ncinerator These are a basic incinerator vessel with a stack. These are per stack. 3 3 0 30700130 Sulfate (Kraft) Pulping / Decker system Same basic idea as brownstock washers. Washers are generally the same in a pulping operation. The only difference -- instead of letting gravity separate the pulp and liquid, the pulp is pressed for dewatering. These are per decker. 8 18 0 30700131 Sulfate (Kraft) Pulping / Knotter / Deknotter System 3 3 0 30700132 Sulfate (Kraft) Pulping / Green Liquor Processing Gr een liquor processing is similar to liquor clarifiers and lime mud washers. 10 10 0 30700133 Sulfate (Kraft) Pulping / White Liquor Processing Based on descriptions from the SCC descriptions tab, these items appear to be individual units, not an entire white liquor processing site. This is why the values may appear small. These estimates are per unit. 10 20 0 30700134 Sulfate (Kraft) Pulping / Oxygen delignification system These are pulping reaction vessels before the bleaching operations. These are tall cylinders. These are per O 2 delig vessel. 20 20 0 30700135 Sulfate (Kraft) Pulping / Pulp Storage - Bleached and Unbleached These are just large storage tanks. These are per storage tank. 30 30 0 30700136 Sulfate (Kraft) Pulping / Tall Oil System Large holding vessel. Usually just a tall tank sitting on its end. These are per vessel. 10 10 0 30700199 Sulfate (Kraft) Pulping /Other Not Classified No indications were available to aid in developing length and width estimates. Used assumed values. 20 20 0 30700211 Sulfite Pulping /Digester/Blow Pit/Dump Tank: Calcium The one SCC record without length and width values was listed as a drain. 1 1 0 30700212 Sulfite Pulping /Digester/Blow Pit/Dump Tank: MgO with

Recovery System Blow tanks must have the capacity to contain the pulp and the black liquor leaving the digester. These are per blow tank/digester. 20 20 0 30700224 Sulfite Pulping /Wastewater: General Used the fugitive parameters from section III of this memo. 829 166 0 30700299 Sulfite Pulping /See Comment ** These are usually drainage systems that may be found in the floor. These are based on a 10 - ft section of drainage grate. 10 1 0 30700301 Neutral Sulfite Semichemical Pulping /Digester/Blow Pit/Dump

Tank Blow tanks must have the capacity to contain the pulp and the black liquor leaving the digester. These are per blow tank/digester. 20 20 0 30700306 Neutral Sulfite Semichemical Pulping /Wastewater: General This was assumed to be floor grates. 10 1 0 30700307 Neutral Sulfite Semichemical Pulping / Pulp washing system Same basic idea as brownstock washers. Washers are generally the same in a pulping operation. 8 18 0 30700308 Neutral Sulfite Semichemical Pulping / Pulp storage tanks/stock

chests These are just large storage tanks. These are per storage tank. 30 30 0 30700309 Neutral Sulfite Semichemical Pulping / Liquor storage tanks These are usually large holding tanks. I would estimate that smaller units are typically 100k - 250k gallons. Most tanks today are 1 million gallon capacity. These estimates are per tank. 35 35 0 30700320 Semi - chemical (non - sulfur) / Pulp washing system Same basic idea as brownstock washers. Washers are generally the same in a pulping operation. These are per washer. 8 18 0 30700321 Semi - chemical (non - sulfur) / Pulp storage tanks/stock chests 15 15 0 30700322 Semi - chemical (non - sulfur) / Liquor making system 10 10 0**SCC Short Name**  **Notes 1**  **Fugitive Length**  **(ft) Fugitive** 

**Width (ft)**  **Fugitive**

**Angle (deg)**  30700325 Semi - chemical (non - sulfur) / Liquor storage tanks These are just large storage tanks. These are per storage tank. 30 30 0 30700326 Semi - chemical (non - sulfur) / Digesters/refiners/blow tanks/blow

heat recovery system Blow tanks must have the capacity to contain the pulp and the black liquor leaving the digester. These are per blow tank/digester. 20 20 0 30700328 Semi - chemical (non - sulfur) /Wastewater: General This was assumed to be floor grates. 10 1 0 30700401 Paper and Paperboard Manufacture / Paper Machine / Pulp Dryer 150 60 0 30700403 Pulpboard Manuf /Raw Material Storage and Handling These appear to be tanks. The same parameters as the SCC 407 tanks were used. 12 20 0 30700404 Secondary Fiber Pulping /Stock Preparation and Repulper Repulpers are generally one size. Again, capacity is increased by adding an additional repulper, not expanding one's size. These are per repulper. 10 10 0 30700407 Paper and Paperboard Manufacture /Coating Operations: On Machine These are the same width as a paper machine. Lengths vary slightly. 3 20 0 30700408 Secondary Fiber Pulping / Deinking operations Deinking operations are generally one size. Again, capacity is increased by adding an additional deinking vessel, not expanding one's size. These are per vessel. 30 30 0 30700499 Paper and Paperboard Manuf /See Comment ** 35 36 0 30700801 Sawmill Operations /Log Debarking 80 12 0 30700820 Sawmill Operations /Chipping and Screening 20 20 0 30701199 Paper Coating & Glazing /Extrusion Coating Line with Solvent

Free Resin/Wax This was assumed to be an extruder. 8 8 0 30701201 Misc Paper Processes /Cyclones This was assumed to be a set of cyclones. 10 2 0 30701202 Miscellaneous Paper Processes /Wastewater: General Used the fugitive parameters from section III of this memo. 1000 1500 0 30701221 Mechanical Pulping Ops / Pressurized Groundwood / Stone

Groundwood These are heavy- duty refiners, without dilute pulp slurry, that physically separate fiber. 5 5 0 30701223 Mechanical and Recycle Paper Processes /Wastewater: General This was assumed to be floor grates. 10 1 0 30701224 Mechanical Pulping Ops / Refiner Pulping This was assumed to be a typical refiner foot print. 10 10 0 30701399 Misc Paper Products /Other Not Classified Using the descriptions provided, an estimate was made. This process would occur within some type of building. 50 50 0 30704001 Pulp&Paper&Wood /Bulk Handling&Stor: Wood - Bark /Storage

Bins 100 100 0 30704002 Pulp&Paper&Wood /Bulk Handling&Stor: Wood - Bark /Stockpiles 200 200 0 30704003 Pulp&Paper&Wood /Bulk Handling& Stor: Wood - Bark /Unloading This was assumed to be truck or rail car size. 50 10 0 30704004 Pulp&Paper&Wood /Bulk Handling&Stor: Wood - Bark /Loading This was assumed to be truck or rail car size. 50 10 0 30704005 Pulp&Paper&Wood /Bulk Handling&Stor: Wood - Bark /Conveyors This assumption was based on belt style conveyors. 250 5 0 30788801 Pulp&Paper&Wood /Fugitive Emissions /Specify in Comments

Field No indications were available to aid in developing length and width estimates. Used assumed values. 200 200 0 30799999 Pulp&Paper&Wood /Other Not Classified /See Comment ** Descriptions indicated these were deinking operations. The same values as SCC 30700408 were used. 10 10 0 39999999 Misc Manuf / I ndus Processes /Other Not Classified No indications were available to aid in developing length and width estimates. Used assumed values. 20 20 0 40700814 Organic Chem Storage - Fixed Roof Tanks - Is opropyl Alcohol:

Working Loss The averages of actual lengths and widths were used. 12 20 0 40700815 Organic Chem Storage - Fixed Roof Tanks - Methyl Alcohol:

Breathing Loss These are usually just large polyethylene tanks. These are per tank. 5 5 0 40700816 Organic Chem Storage - Fixed Roof Tanks - Methyl Alcohol:

Working Loss These are usually just large polyethylene tanks. These are per tank. 5 5 0 40708098 Organic Chem Storage - Fixed Roof Tanks - Specify Nitro The averages of actual lengths and widths were used. 12 20 0**SCC Short Name**  **Notes 1**  **Fugitive Length**  **(ft) Fugitive** 

**Width (ft)**  **Fugitive**

**Angle (deg)**  Compound in Comments: Working Loss 40799997 Organic Chem Storage - Miscellaneous /Specify in Comments The averages of actual lengths and widths were used. 12 20 0 49099998 Solvent Evap /Misc Volatile Organic Evaporation /Identify the

Process and Solvent in Comments Used the averages from the other 407 SCC codes. 12 20 0 1 Items were based on a per unit basis. All sizes are based on 1 piece of that type of equipment. 2 For modeling purposes, fugitive parameter s had to be rounded to whole numbers, so for any values less than 0.5 ft (e.g., 0.25 ft), we round ed them up to 1 ft.

### Appendix D

**Wastewater Treatment Plant (WWTP) Emissions Variability and Default Areas**

### D - 1

**From:** Pinkerton, John [mailto:JPinkerton@NCASI.org] **Sent:** Thursday, February 17, 2011 4:13 PM **To:** Schrock.Bill@epamail.epa.gov **Cc:** Bradfield.John@epamail.epa.gov ; Hanks, Katie P.; hirtz.james@epamail.epa.gov ; palma.ted@epamail.epa.gov ; Hunt, Tim; Jain, Ashok (SRC); Emerson, Zack (SRC); Crapo, Ann (SRC); Palumbo, James (Gmail) **Subject :**  Wastewater Treatment Plant (WWTP) Emissions Variability and Default Areas Bill, Attached is a write - up on variability of WWTP emissions. We believe the effluent loading data and WATER9 sensitivity analysis support a peak -to - mean ratio (maximum short - te rm emission rate to annual average emission rate) of two or less. We have also gathered some dimensional information for primary clarifiers and aerated stabilization basins (ASBs) for the purpose of setting defaults for dispersion modeling whenever the N EI does not contain values (length, width, orientation angle relative to north) for these wastewater fugitive emission sources. We are trying to get more information on the dimensions of activated sludge treatment systems, since we only have information on three of these at present. 1. Primary clarifiers. The most common shape for a primary clarifier is circular. The average diameter for clarifiers at 25 mills for which NCASI has information was 190 ft. In WATER9 modeling, NCASI uses a default value of 200 ft if a site - specific diameter is not available. Since HEM - 3 does not accept circular area sources, Jim Hirtz suggested that the length and width for a circular source be set such that the area of a square source is equal to the area of the circular source. A circle with a 200 ft diameter would have the same area as a square with sides of 177 ft. It isn’t clear what orientation angle should be specified for the square. 2. ASBs. When performing WATER9 modeling to estimate emissions of volatile organic compounds f rom an ASB, the ASB is typically divided into zones. Emissions from a zone depend on many factors, but generally the first zone (where the effluent enters the basin and normally has the most surface aeration) has the highest emission rates. For 10 ASBs tha t have recently been modeled, the average size of the first zone is 13.4 acres (1.46 x 10 6 ft 2 ), and the first zone represented an average of 28% of the total ASB area. Although the first zone could have various shapes, a reasonable assumption would be a l ength to width ratio of 1.5, which would give a length of 1500 ft and width of 1000 ft for a zone with an area of 1.5 x 10 6 ft 2 . It could be conservatively assumed all ASB emissions come from the first zone if site - specific WATER9 modeling has not been con ducted. 3. Activated sludge treatment (AST) systems. These are generally rectangular concrete basins. The size will depend on effluent flow rates, required treatment efficiency, and necessary retention time. For 3 such systems, the areas ranged from 20,000 to 35,000 ft 2 . Length - to width ratios ranged from 2 to 8. It is expected the majority of emissions from most chemical pulp mill wastewater treatment operations will come from the secondary treatment basins (ASB or AST), with relatively little from primary clarifiers and post - secondary treatment basins. Give me a call if there are questions.

### D - 2

Sincerely, John John Pinkerton NCASI National Council for Air and Stream Improvement, I nc. P.O. Box 13318 Research Triangle Park, NC 27709 - 3318 Telephone: 919 - 941 - 6406 Fax: 919 - 941 - 6401 Deliveries: 4815 Emperor Boulevard, Suite 110, Durham, NC 27703 Contact publications@ncasi.org if you do not want to receive future NCASI communications

### Appendix E **Information Needed t o Calculate Allowable**  **Multipliers for**  **Subpart S Risk** 

**Modeling (MACT Code 1626**  **- 1)** 

### E - 1 **Information Needed to Calculate Allowable Multipliers**  **for Subpart S Risk Modeling**  **(MACT Code 1626 -**  **1) Source limit details**  **Typical source control systems**  **Gaseous organic HAP standard**  **Standard form**  **at Allowable**  **multiplier**

**calculation Needed to calculate allowable**  **multiplier** Kraft pulping vent gases : Existing sources: LVHC system 1 ; knotter or screen (above HAP cutoffs), pulp washing, decker (using contaminated water), and O 2 delignification. New sources: Same as existing, except applies for all knotters, screens, and deckers plus weak liquor storage tanks. Route through a c losed vent collection system to a b oiler, lime kiln, recovery f urnace, or thermal o xidizer (1) Reduce total HAP

emissions by ≥98 w

t%; or Numeric

emission limit (performance limit) Allowable multiplier =

(1 - 98% reduction limit) (1 - actual % reduction) Need actual % reduction from Part I response. (2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O 2 (dry basis); or Numeric emission limit (concentration limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = 20 ppm v * MW g/g - mol * g mo l - K/0.08206 l - atm

* 1 atm * 1/temp (C+273) * 1000 l ug/g - m3 * 0.028316847 m3 /ft3 * g/10 6 ug * lb/453.59237 g * cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, and flow from Part I response and actual emissions from NEI. U se MW for surrogate pollutant (methanol ) in allowable calculation.

(3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600 ° F and ≥0.75 sec residence time; or Equipment standard As equipment standard, actual

= allowable , so allowable multiplier = 1 -- (4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or Equipment standard As equipment standard, actual

= allowable , so allowable multiplier = 1 -- (5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the combustion air. Equipment standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

### D - 2

**Source limit details Typical source**  **control systems Gaseous organic HAP**  **standard Standard**  **form at**  **Allowable multiplier** 

**calculation Needed to calculate allowable**  **multiplier** Soda or semichemical pulping vent gases : Existing sources: LVHC system 1 New sources: Same as existing, plus pulp wa shing system. Route through a closed vent collection system to a b oiler, lime kiln, recovery furnace, or thermal o xidizer (1) Reduce total HAP

emissions by ≥98 w

t%; or Numeric

emission limit (performance limit) Allowable multiplier =

(1 - 98% reduction limit) (1 - actual % reduction) Need actual % reduction from Part I response. (2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O 2 (dry basis); or Numeric emission limit (concentration limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = 20 ppm v * MW g/g - mol * g mo l - K/0.08206 l - atm

* 1 atm * 1/temp (C+273) * 1000 l ug/g - m3 * 0.028316847 m3 /ft3 * g/10 6 ug * lb/453.59237 g * cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, and flow from Part I response and actual emissions from NEI. U se MW for surrogate pollutant (methanol ) in allowable calculation.

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

= allowable , so allowable multiplier = 1 -- (4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or Equipment standard As equipment standard, actual

= allowable , so allowable multiplier = 1 -- (5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the combustion air. Equipment standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

### D - 3

**Source limit details Typical source**  **control systems Gaseous organic HAP**  **standard Standard**  **form at**  **Allowable multiplier** 

**calculation Needed to calculate allowable**  **multiplier** Sulfite pulping vent gases : Existing sources: Digester vent, evaporator vent, and pulp washing. New sources: Same as existing, plus strong and weak liquor storage tanks, and acid condensate storage tanks. Route through a

closed vent collection system to a s crubber or other control device (emission limits apply to combined emissions from vents, control device wa stewater, and condensates ) (1a) Ca - or Na -based :

Emit total HAP (a s methanol ) ≤0.89 lb/ton ODP, or Numeric emission limit (productionbased limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = 0.89 lb/ton ODP * ton ODP/yr Need actual ton ODP/yr from Part I response and actual emissions from NEI. (1b) Ca - or Na -based : Reduce total HAP (as methanol) by ≥ 92%; Numeric emission limit (performance limit) Allowable multiplier =

(1 - 92 % reduction limit) (1 - actual % reduction) Need actual % reduction from Part I response. (2a) NH 3 - or Mg -based : Emit total HAP (as methanol ) ≤2.2 lb/ton ODP, or Numeric emission limit (productionbased limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = 2.2 lb/ton ODP * ton ODP/yr Need actual ton ODP/yr from Part I response and actual emissions from NEI. (2b) NH 3 - or Mg -based : Reduce total HAP (as methanol) by ≥87% . Numeric emission limit (performance limit) Allowable multiplier =

(1 - 87 % reduction limit) (1 - actual % reduction) Need actual % reduction from Part I response. New and e xisting bleaching vent gases : Chlorine bleaching systems, kraft/sulfite/soda bleaching with any chlorinated compounds, and mechanical/secondary fiber/non - wood bleaching with ClO 2 . Route through a closed vent collection system to a caustic scrubber or s imilar d evice (1) Reduce total chlorinated

HAP (except chloroform) limit: ≥ 99 w

t%, or Numeric

emission limit (performance limit) Allowable multiplier =

(1 - 99 % reduction limit) (1 - actual % reduction) Need actual % reduction from Part I response. (2) Meet ≤ 10 ppmv of total chlorinated HAP (except chloroform) at control device outlet , or Numeric emission limit (concentration limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = 1 0 ppmv * MW g/g - mol * g mo l - K/0.08206 l - atm

* 1 atm * 1/temp (C+273) * 1000 l ug/g - m3 * 0.028316847 m3 /ft3 * g/10 6 ug * lb/453.59237 g * cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, and flow from Part I response and actual emissions from NEI. U se MW for surrogate pollutant (chlorine ) in allowable calculation.

### D - 4

**Source limit details Typical source**  **control systems Gaseous organic HAP**  **standard Standard**  **form at**  **Allowable multiplier** 

**calculation Needed to calculate allowable**  **multiplier** (3) Meet ≤ 0.002 lb total chlorinated HAP (except chloroform)/ton ODP at control device outlet. Numeric emission limit (productionbased limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = 0.002 lb/ton ODP * ton ODP/yr Need actual ton ODP/yr from Part I response and actual emissions from NEI. (4) Work practice for chloroform - either meet effluent guidelines or use no hypochlorite or chlorine for bleaching. Work practice standard As work practice standard,

actual = allowable , so allowable multiplier = 1 -- Kraft pulping process condensates (process liquids) from digester, turpentine recovery, evaporator, LVHC system 1 , and HVL C system 2 (some exceptions) Route through a

c losed vent collection systems to pulping equipment (1) Reduce total HAP

emissions by ≥98 wt%; or Numeric emission limit (performance limit) Allowable multiplier =

(1 - 98% reduction limit) (1 - actual % reduction) Need actual % reduction from Part I response. (2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppmv @ 10% O 2 (dry basis); or Numeric emission limit (concentration limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = 20 ppm v * MW g/g - mol * g mo l - K/0.08206 l - atm

* 1 atm * 1/temp (C+273) * 1000 l ug/g - m3 * 0.028316847 m3 /ft3 * g/10 6 ug * lb/453.59237 g * cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, and flow from Part I response and actual emissions from NEI. U se MW for surrogate pollutant (methanol ) in allowable calculation.

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

= allowable , so allowable multiplier = 1 -- (4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or Equipment standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

### D - 5

**Source limit details Typical source**  **control systems Gaseous organic HAP**  **standard Standard**  **form at**  **Allowable multiplier** 

**calculation Needed to calculate allowable**  **multiplier** (5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the combustion air. Equipment standard As equipment standard, actual

= allowable , so allowable multiplier = 1 --

Route to biological treatment/ steam stripp er or other control device (1) Reduce total HAP ≥ 92

wt%; or Numeric emission limit (performance limit) Allowable multiplier =

(1 - 9 2 % reduction limit) (1 - actual % reduction) Need actual % reduction from Part I response. (2a) For mills without bleaching, remove ≥ 6.6 lb total HAP/ton ODP, or Numeric emission limit (productionbased removal limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = Uncontrolled emissions (tpy)

– 6.6 lb/ton ODP * ton ODP/yr * 1 ton/2000 lb Need uncontrolled emissions (not available) and actual emissions from NEI.

(2b) For mills without bleaching, meet ≤210 ppmw total HAP at control device outlet; or Numeric emission limit (concentration limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = 210 ppmw * MW g/g - mol * g mo l - K/0.08206 l - atm

* 1 atm * 1/temp (C+273) * 1000 l ug/g - m3 * 0.028316847 m3 /ft3 * g/10 6 ug * lb/453.59237 g * cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, flow from Part I response and actual emissions from NEI. U se MW s for surrogate pollutant s ( acetaldehyde, methanol, MEK , and propionaldehyde ) in allowable calculation. (3a) For mills with bleaching, remove ≥ 10.2 lb total HAP/ton ODP, or Numeric emission limit (productionbased removal limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = Uncontrolled emissions (tpy)

– Need uncontrolled emissions (not available) and actual emissions from NEI.

### D - 6

**Source limit details Typical source**  **control systems Gaseous organic HAP**  **standard Standard**  **form at**  **Allowable multiplier** 

**calculation Needed to calculate allowable**  **multiplier** 10.2 lb/ton ODP * ton ODP/yr * 1 ton/2000 lb (3b) For mills with bleaching, meet ≤ 330 ppmw total HAP at control device outlet. Numeric emission limit (concentration limit) Allowable multiplier =

Allowable emissions Actual emissions (NEI) Allowable emissions = 330 ppmw * MW g/g - mol * g mo l - K/0.08206 l - atm

* 1 atm * 1/temp (C+273) * 1000 l ug/g - m3 * 0.028316847 m3 /ft3 * g/10 6 ug * lb/453.59237 g * cfm * 60 min/hr * 24 hr/d * 365 d/yr Need MW, temp, flow from Part I response and actual emissions from NEI. U se MW s for surrogate pollutant s ( acetaldehyde, methanol, MEK , and propionaldehyde ) in allowable calculation.

Clean condensate alternative (CCA) is an emissions averaging approach to offset emissions from certain existing kraft pulping sources. Install and operate clean condensate alternative technology. Emissions reductions from

CCA ≥ emissions reductions achieved through kraft pulping HVLC system standards Emission averaging limit Site - specific approach N eed site - specific data.

1 The LVHC system includes digester, turpentine recovery, evaporator, and steam strippers . 2 The HVLC system includes pulp washing, knotter, screen, decker, O 2 delignification, weak liquor storage tanks .

### Appendix F **Peak -**  **to -**  **Mean HAP Emissions Ratios for Paper Machine Sources**

**AECOM Technical Services February 15,**  **2011**

### Appendix **G**

**Peak -**  **to -**  **Mean HAP Emissions Ratios for Waste Water Treatment Systems NCASI**  **February 17, 2011**

### G - 1



# Peak **- to**  **- Mean HA**  **P Emissions Ratios for**  **Wa ste W** 

**ater T reatment Systems** 

**NCA SI**  **February 17, 2011** EPA‘s most recent dispersion modeling results suggest acrolein, formaldehyde, chloroform and me thanol released to the air from a few pulp and paper mill wastewater treatment systems may result in elevated acute risks of concern. The acute modeling results discussed with industry representatives on January 13, 2011 indicate the mills with elevated acute risks due to wastewater emissions (identified by SCC 30700121, although some coded as ‘miscellaneous’ fugitive sources may

have included wastewater emissions ) were kraft mills with aerated stabilization basins (ASBs) for secondary treatment. It should be noted these ASBs were all mo deled as point sources rather than area sources. Modeling them as area sources would significantly lower predicted concentrations at most off- site receptors. The hourly emission rates used in the modeling were derived from the NEI emission inventory database, which contained a number for the total annual emissions. This number was divided by 8760 and then multiplied by 10, a standard default factor used by EPA to estimate a peak hourly rate that might occur sometime during the year. EPA has acknowledged the factor of 10 may not be applicable in all situations, and indicated a more realistic factor could be used if suitable documentat ion were provided to justify an alternative. Em issions of a volatile organic compound from an ASB depend upon the amount of the com pound in the entering wastewater, wastewater chemical and physical properties, design and operating characteristics of the ASB, and ambient atmospheric conditions. Em issions are estimated with a model such as WATER9, which requires several input parameters including wastewater flow rate, wastewater temperature, compound concentration, basin area and depth, aeration rate, compo und biorate, ambient temperature, and ambient wind speed. To estimate the variability in emissions that might be expected from an ASB, one needs to first determine the variability in the amount of the organic compound entering the ASB. This requires info rmation on the wastewater flow rate and compound concentration. Flow rates, when me asured, are typically reported in gallons/day. Concentrations are most often obtained from daily grab samples, but most mills do not make such measurements. The exception is kraft mills that use an ASB to satisfy the Cluster Rule condensate treatment requirement. These mills are required to conduct an annual performance test which involves collection of daily samples over a period that may range from one to 15 days, depending on the averaging time specified in the Title V permit. These samples are collected in the so - called hard - pipe, which transfers the collected condensates directly to the ASB. These condensates will contain a significant portion of the organic hazardous air pollutants (methanol, acetaldehyde, propionaldehyde, formaldehyde, acrolein) being sent to the ASB. Thus, the hard - pipe flow and concentration data should provide an indication of the variability in loadings experienced over several days. Table 1 shows the peak - to - me an ratios for hard - pipe loadings (lb/day; obtained from flow and concentration measurements) of methanol (6 mills) and acetaldehyde (3 mills). Daily samples were collected over periods ranging from 12 to 16 days, once per year, with the excep tion of the 360 days of samples collected over a consecutive 13 - mo nth period at Mill A. Mill C had two annual tests, and Mill F had four annual tests. The peak - to - me an ratios range from 1.2 to 2.1, mu ch less than the default factor of 10. Sim ilar ratios wo uld be expected for loadings of acrolein and formaldehyde, also present in condensates.

### G - 2 Table 1. Hard - Pipe Loadings of Methanol and Acetaldehyde Methanol Acetaldehyde Mill A B C D E F B C F Peak/Mean 1.7 1.5 1.3 1.2 1.5 1.3 1.6 1.3 1.5 Number of daily sam ples 360 16 15 16 12 16 16 15 16 Peak/Mean 1.4 1.6 2.1 Number of daily sam ples 26 16 16 Peak/Mean 1.3 1.9 Number of daily sam ples 16 16 Peak/Mean 1.1 1.9 Number of daily sam ples 16 16 Repeated sampling for volatile organic hazardous air pollutants in raw wastewater streams other than hard - piped condensates is rare. Mill D also sampled the raw wastewater entering the primary clarifier (hard - pipe condensates bypass the clarifier) for the same 16 - d ay period as the hard piped condensates were sampled. The peak - to - mean ratio for methanol loadings (lb/day ) was 1.3. Mill G collected random grab samples for methanol analysis from a primary clarifier outlet (prior to entering an ASB) over a five year peri od. This mill has a steam stripper and does not hard - pipe. Table 2 summarizes testing information from this mill. The peak - to - me an ratios for me thanol concentrations ranged from 1.2 to 1.5, very sim ilar to the ratios in methanol loadings observed for hard - piped condensates at other mills.

Table 2. Methanol Concentration Variability at a Primary Clarifier Outlet Year 2010 2009 2008 2007 2006 Mean, mg/L 82 89 99 94 79 Peak, mg/L 97 110 148 130 95 Peak/Mean 1.2 1.2 1.5 1.4 1.2 As mentioned earlier, em issions of a volatile organic compound from an ASB are estimated with a fate model that takes other factors into account besides compound loading. To examine the effect on emissions of certain parameters which may vary in time, a sensitivity analysis usi ng EPA’s WATER9 model was performed. Em ission calculations were made for an ASB with a surface area of 44 acres and depth of eight feet. The ASB was subdivided into 3 zones, two with areas of 11 acres each with 950 hp of surface aeration each, and a third zone of 22 acres with 450 hp of surface aeration. Flow to the ASB was assumed to be 34 million gallons per day, with a methanol concentration of 80 mg/L, and acetaldehyde and formaldehyde concentrations of 0.15 mg/L. A “baseline” set of conditions was firs t used to predict emission rates, and then these conditions were varied to see the effect on the emission predictions. The conditions were changed in a direction that would lead to increased emission rates. Table 3 shows modeled emission rates for this typ ical basin are most sensitive to the assumed biological activity rate, although it should be noted a 50% reduction would be a catastrophic event unlikely to occur on an annual basis. None of the four factors increase emission rates over a factor of two. Considering the number of factors affecting the W AT ER9 em ission estimates, and the inherent uncertainties in this simulation model, it seems reasonable to conclude the peak - to - me an ratio is

### G - 3

no more than a factor of two for emissions of volatile organic haz ardous air pollutants, which would include methanol, acetaldehyde, formaldehyde, acrolein and chloroform. Table 3. WATER9 Sensitivity Analysis Baseline em ission rate for ASB, g/s Change from baseline emission rate

Lower basin temperatures by 10°C Increase wind

speed from 5 to 10 mph Lower

am bient air temperature by 10°C Lower

biological activity rate by 50% Methanol 7.28 - 3% +24% 0 +79% Acetaldehyde 0.065 +5% +5% 0 +46% Form aldeh yd e 0.00045 +9% +32% 0 +86%

### Appendix **H EPA’s**  **Conclusions Regarding Use of the Part II Acrolein D ata** 

### MEMORANDUM

FROM: Project Team (EPA/OAR/OAQPS/SPPD/NRG) TO: Docket EPA - HQ - OAR- 2007 - 0544 DATE: November 30, 2011 SUBJECT: Acrolein Emissions from Paper Machines and Mechanical Pulping

(Non - Combustion Sources) The production of paper involves the processing of raw wood into pulp, chemical recovery, bleaching, paper making, and waste water treatment; the kraft process is shown in Figure 1. The subpart S (MACT 1 and 3) standard from the Pulp and Paper NESHAP applies to major sources of HAP emissions from the pulp production areas at chemical, mechanical, secondary f iber, and non - wood pulp mills, bleaching operations, and pap ermaking systems. These processes are shown in blue and green in Figure 1. As eparate standard (MACT 2), subpart MM, applies to chemical recovery

processes at kraft, soda, sulfite, and stand- alone semi - chemical mills. These processes are shown in yellow in Figure 1. Boiler MACT and NSPS are also regulations applied to systems within an integrated pulp and paper mill, shown in figure as gray and red outline, respectivel y. Acrolein emissions are commonly formed by combustion sources at pulp and paper facil ities through the burning of organic materials. Emissions were reported in response to the ICR from power boilers, recovery

f urnaces, and lime kilns, all of which are combustion sources; emissions were also reported from paper machines and mechanical pulping, which are not combustion sources. The reported acrolein emissions for both ty pes of sources were based on emission factors, developed b y NC ASI . Acrolein emissions from non - combustion sources, such as paper machines and mechanical pulping, are not completely understood. In the case of mechanical pulping, it is thought that acrolein is formed and released when the wood is heated during the pulping p rocess. Wood chips or logs are processed b y grinding against metal plates, generating heat and, in the case of thermo mechanical pulping, steam is introduced to heat the wood as a pretreatment to reduce processing energy requirements. In papermaking, water is removed from the pulp on a machine utilizing gravity draining, vacuum filtration, pressing, and drying. One hy pothesis is that the acrolein is formed and released when the pulp sheet is dried, as the majority o f test detects occurred at the paper machine dryer. Neither of these processes, mechanical pulping or papermaking, are combustion sources, but acrolein appears to be emitted from them based on limited testing. The formation of acrolein upon heating and drying of the wood products is unknown, as it is not an inherent compound found in wood. Acrolein is potentially f ormed by the breakdown of wood components (e.g., cellulose, hemicelluloses, or lignin) during the drying process; the chemical structure and quantity of the components vary

between wood species, growing location, weather (including wind, sunlight, and rain), season harvested, and growing soil conditions. W e do not currentl y understand the interplay o f these parameters and specifically how the various

### factors impact the amount of acrolein generated during heating and drying of the pulp during

paper making and mechanical pulping. The emission factors for acrolein from paper machines and mechanical pulping were developed by

N CASI using test data on a very l imited number of machines with a set of specific operating conditions. Testing was performed using a test method developed by the trade association, as the EPA has not developed a test method for these sources; the EPA is currently evaluating the NCASImethod as a reference test for acrolein. Acrolein testing of paper machines and mechanical pulping using this method has issues such as difficulty in capturing and quantifying acrolein due to fugitive background sources and building venting (instead of stacks) at large volumes with high mo isture contents and low acrolein concentrations. These difficulties are apparent in the data set used to develop the emission factors, as it contained a majority of test run results below the method detection limit (MDL). NCASI followed the 1997 EPA protoc ol for the emission factor development, which recommended non - detect run data be reported as half of the method detection limit (Procedures for Preparing Emission Factor Documents, EPA - 454/R95 - 015, U.S. Environmental Protection Agency, Research Triangle P ark, NC, May 1 997 ) . However, in the case of acrolein from Subpart S non - combustion sources, this protocol results in emission factors based primarily o n assumed 1/2 - MDLvalues from a majority of test runs where acrolein was not detected which introduced a large number of unknowns into the dataset, thereby multiplying the uncertainties outlined above to an unknown degree. The uncertainty in the initial data set is further magnified when the emission factors are applied across the industry , yi elding a resultant acrolein emission inventory p redicated primarily

o n assumed values and not actual emissions measurements. This magnified uncertainty i s compounded with the additional uncertainty of acrolein emissions from different paper machine operating parameters and different wood species used in pulping, resulting in further exacerbation of the uncertainty. In our judgment, we believe that the industry e fforts to document and confirm acrolein emissions, though informative, highlight the current technological limits in the ability to capture and quantify

acrolein emissions that are specific to paper machines and mechanical pulping processes. B ased on the forgoing issues, we did not use this test data. EPA is working with industry to help refine and improve the test methods to capture this compound from these sources.

### Figure 1: The Pulp and Paper Making Process