From: Spence, Kelley

To: "Cortney_Higgins@omb.eop.gov"

Cc: Eck, Janet; Thundiyil, Karen; Adams, Darryl; Dunkins, Robin; Rush, Alan; Brown, Stephanie N.

Subject: Materials for kraft pulp mills NSPS call

Date: Friday, January 31, 2014 10:07:00 AM

Attachments: OMB_1-pager_1-31-14.docx

Hi Cortney,

I have attached a 1-pager for our call at 10:30am regarding the review of the Kraft Pulp Mill NSPS.

Let me know if you have any questions.

Thanks!

Kelley

Kelley Spence, Ph.D.

U.S. EPA

Natural Resources Group

Sector Policies and Programs Division, OAQPS

109 T.W. Alexander Drive (E143-03)

Research Triangle Park, NC 27709

Phone: 919.541.3158

Fax: 919.541.3470

Email: spence.kelley@epamail.epa.gov
Kraft Pulp Mills New Source Performance Standards Review (Final Rule)

Background

 On May 23, 2013, EPA proposed the Kraft Pulp Mills NSPS Review (a new Subpart BBa)

 Applies to kraft pulp mill equipment constructed, modified, or reconstructed after May 23, 2013.

 The final rule has a court-ordered deadline of March 14, 2014

Overview of Proposal: 

 As a result of the NSPS review, EPA proposed the following changes in Subpart BBa to 

supersede the current NSPS (Subpart BB):

o Reduced particulate matter (PM) limits for new/reconstructed recovery furnaces, lime kilns, 

and smelt dissolving tanks (SDTs) to be consistent with MACT limits; reduced PM limit for 

modified lime kilns to MACT existing limit

o Reduced opacity limit from 35% to 20% for recovery furnaces; added opacity limit of 20% 

for lime kilns

o Reduced opacity monitoring allowance from 6% to 2% for recovery furnaces; added opacity 

monitoring allowance of 1% for lime kilns

o Added ESP monitoring requirements for periods when the opacity monitoring allowance is 

used

o Added upper limits (caps) to the total reduced sulfur (TRS) monitoring allowance for lime 

kilns and recovery furnaces (but did not change the NSPS TRS limits)

o Required repeat testing every 60 months and added EPA Method 202 to measure condensible 

PM; added electronic reporting requirements

o Removed the SSM exemption; added affirmative defense language for malfunctions; 

adjusted parameter monitoring requirements to accommodate S/S 

o Impacts (based on estimate for 5-year period):

 Number of impacted mills: 10

 Nationwide annualized cost: $389,900

Stakeholder Reaction: We received 6 sets of comments (AF&PA, Weyerhaeuser, SSM Coalition, 

NCASI, State of Pennsylvania Department of Environmental Protection, and Center for Biological 

Diversity) summarized as follows:

 Industry groups:

o Need higher opacity allowance than proposed for recovery furnaces (requested 4%)

o No basis to remove SSM exemption

o Requested reanalysis of continuous monitoring data to consider semiannual basis for 

calculating monitoring allowances

o Requested changes to monitoring parameters for S/S

o Removal of SSM negates use of excess emission allowances under subpart S

o Testing issues with Method 202

 State regulating authority:

o Supported semiannual calculation of allowances

o Supported lowering opacity limit

o Additional ESP monitoring parameters redundant

 Environmental groups:

o Supported removal of SSM exemption

o Monitoring and test methods insufficient

o Brown stock washer exemption must be removed (illegal)

o Proposal fails to consider best system of emission reductions