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Pulp and Paper Sector Survey

Overview

Survey coverage. The pulp and paper sector survey is a three-part information request that applies for 

pulp and/or paper/paperboard mills that are a “major source” or “synthetic area source” of hazardous air 

pollutant (HAP) emissions that:

(a) Perform chemical wood pulping (kraft, sulfite, soda, or semi-chemical), or

(b) Perform mechanical, groundwood (e.g., thermomechanical pulping (TMP), refiner mechanical 

pulping (RMP)), secondary fiber, and non-wood pulping, or

(c) Perform bleaching, or

(d) Manufacture paper or paperboard products.

As defined in 40 CFR Part 63, subpart A,

“Major source” means any stationary source or group of stationary sources located within a 

contiguous area and under common control that emits or has the potential to emit considering 

controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per 

year or more of any combination of hazardous air pollutants, unless the Administrator establishes 

a lesser quantity, or in the case of radionuclides, different criteria from those specified in this 

sentence.

A “synthetic area source” is a stationary source which is subject to federally-enforceable conditions that 

limit its potential to emit to below major source thresholds.

Mills exempt from the pulp and paper sector survey. If your mill is not a “major source” or “synthetic 

area source” of HAP emissions, then you should complete the form in Attachment 1 and email (or fax) it 

to Bill Schrock of the U.S. Environmental Protection Agency (EPA) at schrock.bill@epa.gov. If your 

mill is a true area source, then your operating permit should reflect that your mill is not subject to either 

of the pulp and paper national emissions standards for hazardous air pollutants (NESHAP) (40 CFR Part 

63, subpart S or MM). You are not required to complete any part of the pulp and paper sector survey if 

you submit valid documentation of true area source status.

If your mill is a “major source” or “synthetic area source,” but was not operational in 2009 (and remains 

closed) or does not produce pulp, perform bleaching, or manufacture paper or paperboard products, then 

you should complete the form in Attachment 1 and email (or fax) it to Bill Schrock of EPA at 

schrock.bill@epa.gov explaining the status of your mill. You are not required to complete any part of the 

pulp and paper sector survey.

Survey structure and due dates. The pulp and paper sector survey is to be completed in a series of 

Microsoft Excel spreadsheet files that are divided into several worksheets (“tabs” within each 

spreadsheet). You must complete certain portions of the survey, depending on the type of mill you 

operate. Parts I and II apply for all mills, except true area source and non-operational mills, as noted 

above. Parts I and III request process data for the emissions units listed in Attachment 1 of the 

instructions for each part. Part II requests an NEI update for all emissions units. Additional spreadsheets 

are provided for submittal of continuous emissions monitoring system (CEMS) data or control measure 

cost information (for Part I and Part III). 
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The pulp and paper sector survey is divided into three parts, each with different due dates as specified in 

Table 1 below.

Table 1. Components of the Three-Part Pulp and Paper Survey

Part Short Description Deadline1 Contents of Data Submittal

I Mill Overview and Subpart S Data

a. Notification of true area source, non-operational, or 

non-applicable status

20 days -Attachment 1 of survey overview

b. Completion of Part I data submittal 30 days -P&P survey_PI.xls

-P&P CEMS _PI.xls

-P&P costs OPTIONAL_PI.xls

-Flow diagrams

-Test reports

-Water modeling

II NEI Update 100 days -P&P NEI update.xls 

III Chemical Recovery Combustion Sources 180 days -P&P CEMS _PIII.xls

-P&P costs OPTIONAL_PIII.xls

-P&P survey_PIII.xls

-Test reports

1 The deadlines indicated are in terms of calendar days following the date stamped on the Section 114 letter 

accompanying this survey. Specific dates are specified in the letter.

Please complete the survey for the facility listed in the Section 114 letter you received in the mail. If you 

received more than one Section 114 letter for multiple facilities, you must create a separate survey 

response for each facility. If you have not already received or downloaded a copy of the survey 

spreadsheets, they can be downloaded here: https://icr2010.rti.org/Industries/PulpPaper.aspx

Base year for survey data. Use the 2009 calendar year as the base year for all survey responses (e.g., 

2009 emissions inventory, 2009 capacity, 2009 equipment configurations, etc.), unless another year is 

specified in the instructions (e.g., for emissions test data). 

Definitions. For reference, Attachment 2 to this overview contains the regulatory definitions from the 

kraft pulp mill new source performance standards (NSPS) (40 CFR Part 60, subpart BB), chemical 

recovery combustion source NESHAP (40 CFR Part 63, subpart MM), and pulp and paper production

NESHAP (40 CFR Part 63, subpart S), and selected definitions from the NSPS and NESHAP General 

Provisions. 

Acronyms/abbreviations. Attachment 3 to this overview contains acronyms and abbreviations used 

throughout the survey instruction documents and associated spreadsheets.

Certification form. Attachment 4 to this overview contains a certification form that you must complete, 

sign, date, and submit separately with each completed part of the survey, certifying that the statements 

and information provided in your responses to Part I, Part II, and Part III of the survey are (to the best of 

your knowledge) true, accurate, and complete. 
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ATTACHMENT 1

DOCUMENTATION OF TRUE AREA SOURCE, NON-OPERATIONAL, OR 

NON-APPLICABLE STATUS

Facility Name on the 

Letter from EPA:

Corrected Facility 

Name (if applicable):

Address:

Check an explanation below:

□ I certify that the facility listed above is not a “major source” or “synthetic area source” of 

hazardous air pollutant emissions (HAP) emissions. The facility is a “true area source” of 

HAP emissions. Documentation (such as a valid operating permit) confirming the true 

area source status is attached.

□ I certify that that facility listed above was not operational in 2009 (the base year for the 

pulp and paper sector survey), and that the facility remains non-operational (closed). A

brief explanation is provided in the area below: 

□ I certify that the facility listed above does not produce pulp, perform bleaching, or 

manufacture paper or paperboard products. A brief explanation is provided in the area 

below:

Signature: ____________________________________________

Printed name: _________________________________________

Email and/or fax completed form to: Bill Schrock (USEPA)

schrock.bill@epa.gov

Fax: (919) 541-3470
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ATTACHMENT 2

NSPS and NESHAP Definitions

NSPS Subpart BB Definitions (40 CFR Part 60, § 60.281):

(a) Kraft pulp mill means any stationary source which produces pulp from wood by cooking (digesting) wood chips 

in a water solution of sodium hydroxide and sodium sulfide (white liquor) at high temperature and pressure. 

Regeneration of the cooking chemicals through a recovery process is also considered part of the kraft pulp mill. 

(b) Neutral sulfite semichemical pulping operation means any operation in which pulp is produced from wood by

cooking (digesting) wood chips in a solution of sodium sulfite and sodium bicarbonate, followed by mechanical 

defibrating (grinding). 

(c) Total reduced sulfur (TRS) means the sum of the sulfur compounds hydrogen sulfide, methyl mercaptan, 

dimethyl sulfide, and dimethyl disulfide, that are released during the kraft pulping operation and measured by 

Method 16. 

(d) Digester system means each continuous digester or each batch digester used for the cooking of wood in white 

liquor, and associated flash tank(s), blow tank(s), chip steamer(s), and condenser(s). 

(e) Brown stock washer system means brown stock washers and associated knotters, vacuum pumps, and filtrate 

tanks used to wash the pulp following the digester system. Diffusion washers are excluded from this definition. 

(f) Multiple-effect evaporator system means the multiple-effect evaporators and associated condenser(s) and 

hotwell(s) used to concentrate the spent cooking liquid that is separated from the pulp (black liquor). 

(g) Black liquor oxidation system means the vessels used to oxidize, with air or oxygen, the black liquor, and 

associated storage tank(s). 

(h) Recovery furnace means either a straight kraft recovery furnace or a cross recovery furnace, and includes the 

direct-contact evaporator for a direct-contact furnace. 

(i) Straight kraft recovery furnace means a furnace used to recover chemicals consisting primarily of sodium and 

sulfur compounds by burning black liquor which on a quarterly basis contains 7 weight percent or less of the total 

pulp solids from the neutral sulfite semichemical process or has green liquor sulfidity of 28 percent or less. 

(j) Cross recovery furnace means a furnace used to recover chemicals consisting primarily of sodium and sulfur 

compounds by burning black liquor which on a quarterly basis contains more than 7 weight percent of the total 

pulp solids from the neutral sulfite semichemical process and has a green liquor sulfidity of more than 28 percent. 

(k) Black liquor solids means the dry weight of the solids which enter the recovery furnace in the black liquor. 

(l) Green liquor sulfidity means the sulfidity of the liquor which leaves the smelt dissolving tank.

(m) Smelt dissolving tank means a vessel used for dissolving the smelt collected from the recovery furnace. 

(n) Lime kiln means a unit used to calcine lime mud, which consists primarily of calcium carbonate, into quicklime, 

which is calcium oxide. 

(o) Condensate stripper system means a column, and associated condensers, used to strip, with air or steam, TRS 

compounds from condensate streams from various processes within a kraft pulp mill. 
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NESHAP Subpart MM Definitions (40 CFR Part 63, § 63.861):

Bag leak detection system means an instrument that is capable of monitoring PM loadings in the exhaust of a fabric 

filter in order to detect bag failures. A bag leak detection system includes, but is not limited to, an instrument that 

operates on triboelectric, light scattering, light transmittance, or other principle to monitor relative PM loadings. 

Black liquor means spent cooking liquor that has been separated from the pulp produced by the kraft, soda, or 

semichemical pulping process. 

Black liquor gasification means the thermochemical conversion of black liquor into a combustible gaseous product. 

Black liquor oxidation (BLO) system means the vessels used to oxidize the black liquor, with air or oxygen, and the 

associated storage tank(s). 

Black liquor solids (BLS) means the dry weight of the solids in the black liquor that enters the recovery furnace or 

semichemical combustion unit. 

Black liquor solids firing rate means the rate at which black liquor solids are fed to the recovery furnace or the 

semichemical combustion unit. 

Chemical recovery combustion source means any source in the chemical recovery area of a kraft, soda, sulfite or 

stand-alone semichemical pulp mill that is an NDCE recovery furnace, a DCE recovery furnace system, a smelt 

dissolving tank, a lime kiln, a sulfite combustion unit, or a semichemical combustion unit. 

Chemical recovery system means all existing DCE and NDCE recovery furnaces, smelt dissolving tanks, and lime 

kilns at a kraft or soda pulp mill. Each existing recovery furnace, smelt dissolving tank, or lime kiln is considered 

a process unit within a chemical recovery system. 

Direct contact evaporator (DCE) recovery furnace means a kraft or soda recovery furnace equipped with a direct 

contact evaporator that concentrates strong black liquor by direct contact between the hot recovery furnace 

exhaust gases and the strong black liquor. 

Direct contact evaporator (DCE) recovery furnace system means a direct contact evaporator recovery furnace and 

any black liquor oxidation system, if present, at the pulp mill. 

Dry electrostatic precipitator (ESP) system means an electrostatic precipitator with a dry bottom (i.e., no black 

liquor, water, or other fluid is used in the ESP bottom) and a dry particulate matter return system (i.e., no black 

liquor, water, or other fluid is used to transport the collected PM to the mix tank). 

Fabric filter means an air pollution control device used to capture PM by filtering a gas stream through filter media; 

also known as a baghouse. 

Hazardous air pollutants (HAP) metals means the sum of all emissions of antimony, arsenic, beryllium, cadmium, 

chromium, cobalt, lead, manganese, mercury, nickel, and selenium as measured by EPA Method 29 (40 CFR part 

60, appendix A) and with all nondetect data treated as one-half of the method detection limit. 

Hog fuel dryer means the equipment that combusts fine particles of wood waste (hog fuel) in a fluidized bed and 

directs the heated exhaust stream to a rotary dryer containing wet hog fuel to be dried prior to combustion in the 

hog fuel boiler at Weyerhaeuser Paper Company’s Cosmopolis, Washington facility. The hog fuel dryer at 

Weyerhaeuser Paper Company’s Cosmopolis, Washington facility is Emission Unit no. HD–14. 

Kraft pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a 

solution of sodium hydroxide and sodium sulfide. The recovery process used to regenerate cooking chemicals is 

also considered part of the kraft pulp mill. 

Kraft recovery furnace means a recovery furnace that is used to burn black liquor produced by the kraft pulping 

process, as well as any recovery furnace that burns black liquor produced from both the kraft and semichemical 

pulping processes, and includes the direct contact evaporator, if applicable. Includes black liquor gasification. 

Lime kiln means the combustion unit (e.g., rotary lime kiln or fluidized-bed calciner) used at a kraft or soda pulp 

mill to calcine lime mud, which consists primarily of calcium carbonate, into quicklime, which is calcium oxide 

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Lime production rate means the rate at which dry lime, measured as CaO, is produced in the lime kiln. 

Method detection limit means the minimum concentration of an analyte that can be determined with 99 percent 

confidence that the true value is greater than zero. 

Modification means, for the purposes of § 63.862(a)(1)(ii)(E)(1), any physical change (excluding any routine part 

replacement or maintenance) or operational change (excluding any operational change that occurs during a startup, shutdown, or malfunction) that is made to the air pollution control device that could result in an increase in 

PM emissions. 

Nondetect data means, for the purposes of this subpart, any value that is below the method detection limit. 

Nondirect contact evaporator (NDCE) recovery furnace means a kraft or soda recovery furnace that burns black 

liquor that has been concentrated by indirect contact with steam. 

Particulate matter (PM) means total particulate matter as measured by EPA Method 5, EPA Method 17 (§ 

63.865(b)(1)), or EPA Method 29 (40 CFR part 60, appendix A). 

Process unit means an existing DCE or NDCE recovery furnace, smelt dissolving tank, or lime kiln in a chemical 

recovery system at a kraft or soda mill. 

Recovery furnace means an enclosed combustion device where concentrated black liquor produced by the kraft or 

soda pulping process is burned to recover pulping chemicals and produce steam. Includes black liquor 

gasification. 

Regenerative thermal oxidizer (RTO) means a thermal oxidizer that transfers heat from the exhaust gas stream to the 

inlet gas stream by passing the exhaust stream through a bed of ceramic stoneware or other heat-absorbing 

medium before releasing it to the atmosphere, then reversing the gas flow so the inlet gas stream passes through 

the heated bed, raising the temperature of the inlet stream close to or at its ignition temperature. 

Semichemical combustion unit means any equipment used to combust or pyrolyze black liquor at stand-alone 

semichemical pulp mills for the purpose of chemical recovery. Includes black liquor gasification. 

Similar process units means all existing DCE and NDCE recovery furnaces, smelt dissolving tanks, or lime kilns at 

a kraft or soda pulp mill. 

Smelt dissolving tanks (SDT) means vessels used for dissolving the smelt collected from a kraft or soda recovery 

furnace. 

Soda pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a 

sodium hydroxide solution. The recovery process used to regenerate cooking chemicals is also considered part of 

the soda pulp mill. 

Soda recovery furnace means a recovery furnace used to burn black liquor produced by the soda pulping process 

and includes the direct contact evaporator, if applicable. Includes black liquor gasification. 

Stand-alone semichemical pulp mill means any stationary source that produces pulp from wood by partially 

digesting wood chips in a chemical solution followed by mechanical defibrating (grinding), and has an onsite 

chemical recovery process that is not integrated with a kraft pulp mill. 

Startup means, for the chemical recovery system employing black liquor gasification at Georgia-Pacific’s facility in 

Big Island, Virginia only, the end of the gasification system commissioning phase. Commissioning is that period 

of time in which each part of the new gasification system will be checked and operated on its own to make sure it 

is installed and functions properly. Commissioning will conclude with the successful completion of the 

gasification technology supplier’s performance warranty demonstration, which proves the technology and 

equipment are performing to warranted levels and the system is ready to be placed in active service. For all other 

affected sources under this subpart, startup has the meaning given in § 63.2. 

Sulfite combustion unit means a combustion device, such as a recovery furnace or fluidized-bed reactor, where spent 

liquor from the sulfite pulping process (i.e., red liquor) is burned to recover pulping chemicals. 
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Sulfite pulp mill means any stationary source that produces pulp from wood by cooking (digesting) wood chips in a 

solution of sulfurous acid and bisulfite ions. The recovery process used to regenerate cooking chemicals is also 

considered part of the sulfite pulp mill. 

Total hydrocarbons (THC) means the sum of organic compounds measured as carbon using EPA Method 25A (40 

CFR part 60, appendix A). 
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NESHAP Subpart S Definitions (40 CFR Part 63, § 63.441): 

Acid condensate storage tank means any storage tank containing cooking acid following the sulfur dioxide gas 

fortification process. 

Black liquor means spent cooking liquor that has been separated from the pulp produced by the kraft, soda, or semichemical pulping process. 

Bleaching means brightening of pulp by the addition of oxidizing chemicals or reducing chemicals. 

Bleaching line means a group of bleaching stages arranged in series such that bleaching of the pulp progresses as the 

pulp moves from one stage to the next. 

Bleaching stage means all process equipment associated with a discrete step of chemical application and removal in 

the bleaching process including chemical and steam mixers, bleaching towers, washers, seal (filtrate) tanks, 

vacuum pumps, and any other equipment serving the same function as those previously listed. 

Bleaching system means all process equipment after high-density pulp storage prior to the first application of 

oxidizing chemicals or reducing chemicals following the pulping system, up to and including the final bleaching 

stage. 

Boiler means any enclosed combustion device that extracts useful energy in the form of steam. A boiler is not 

considered a thermal oxidizer. 

Chip steamer means a vessel used for the purpose of preheating or pretreating wood chips prior to the digester, using 

flash steam from the digester or live steam. 

Closed-vent system means a system that is not open to the atmosphere and is composed of piping, ductwork, 

connections, and, if necessary, flow-inducing devices that transport gas or vapor from an emission point to a 

control device. 

Combustion device means an individual unit of equipment, including but not limited to, a thermal oxidizer, lime 

kiln, recovery furnace, process heater, or boiler, used for the thermal oxidation of organic hazardous air pollutant 

vapors. 

Decker system means all equipment used to thicken the pulp slurry or reduce its liquid content after the pulp 

washing system and prior to high-density pulp storage. The decker system includes decker vents, filtrate tanks, 

associated vacuum pumps, and any other equipment serving the same function as those previously listed. 

Digester system means each continuous digester or each batch digester used for the chemical treatment of wood or 

non-wood fibers. The digester system equipment includes associated flash tank(s), blow tank(s), chip steamer( s) 

not using fresh steam, blow heat recovery accumulator(s), relief gas condenser(s), prehydrolysis unit(s) preceding 

the pulp washing system, and any other equipment serving the same function as those previously listed. The 

digester system includes any of the liquid streams or condensates associated with batch or continuous digester 

relief, blow, or flash steam processes. 

Emission point means any part of a stationary source that emits hazardous air pollutants regulated under this subpart, 

including emissions from individual process vents, stacks, open pieces of process equipment, equipment leaks, 

wastewater and condensate collection and treatment system units, and those emissions that could reasonably be 

conveyed through a stack, chimney, or duct where such emissions first reach the environment. 

Evaporator system means all equipment associated with increasing the solids content and/or concentrating spent 

cooking liquor from the pulp washing system including pre-evaporators, multi-effect evaporators, concentrators, 

and vacuum systems, as well as associated condensers, hotwells, and condensate streams, and any other 

equipment serving the same function as those previously listed. 

Flow indicator means any device that indicates gas or liquid flow in an enclosed system. 

HAP means a hazardous air pollutant as defined in § 63.2 of subpart A of this part. 

High volume, low concentration or HVLC collection system means the gas collection and transport system used to 

convey gases from the HVLC system to a control device. 
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High volume, low concentration or HVLC system means the collection of equipment including the pulp washing, 

knotter, screen, decker, and oxygen delignification systems, weak liquor storage tanks, and any other equipment 

serving the same function as those previously listed. 

Knotter system means equipment where knots, oversized material, or pieces of uncooked wood are removed from 

the pulp slurry after the digester system and prior to the pulp washing system. The knotter system equipment 

includes the knotter, knot drainer tanks, ancillary tanks, and any other equipment serving the same function as 

those previously listed. 

Kraft pulping means a chemical pulping process that uses a mixture of sodium hydroxide and sodium sulfide as the 

cooking liquor. 

Lime kiln means an enclosed combustion device used to calcine lime mud, which consists primarily of calcium 

carbonate, into calcium oxide.

Low volume, high concentration or LVHC collection system means the gas collection and transport system used to 

convey gases from the LVHC system to a control device. 

Low volume, high concentration or LVHC system means the collection of equipment including the digester, 

turpentine recovery, evaporator, steam stripper systems, and any other equipment serving the same function as 

those previously listed. 

Mechanical pulping means a pulping process that only uses mechanical and thermo-mechanical processes to reduce 

wood to a fibrous mass. The mechanical pulping processes include, but are not limited to, stone groundwood, 

pressurized groundwood, refiner mechanical, thermal refiner mechanical, thermo-mechanical, and tandem 

thermomechanical. 

Non-wood pulping means the production of pulp from fiber sources other than trees. The non-wood fiber sources 

include, but are not limited to, bagasse, cereal straw, cotton, flax straw, hemp, jute, kenaf, and leaf fibers. 

Oven-dried pulp or ODP means a pulp sample at zero percent moisture content by weight. Pulp samples for 

applicability or compliance determinations for both the pulping and bleaching systems shall be unbleached pulp. 

For purposes of complying with mass emission limits in this subpart, megagram of ODP shall be measured to 

represent the amount of pulp entering and processed by the equipment system under the specified mass limit. For 

equipment that does not process pulp, megagram of ODP shall be measured to represent the amount of pulp that 

was processed to produce the gas and liquid streams. 

Oxygen delignification system means the equipment that uses oxygen to remove lignin from pulp after high-density 

stock storage and prior to the bleaching system. The oxygen delignification system equipment includes the blow

tank, washers, filtrate tanks, any interstage pulp storage tanks, and any other equipment serving the same function 

as those previously listed. 

Primary fuel means the fuel that provides the principal heat input to the combustion device. To be considered 

primary, the fuel must be able to sustain operation of the combustion de without the addition of other fuels. 

Process wastewater treatment system means a collection of equipment, a process, or specific technique that removes 

or destroys the HAPs in a process wastewater stream. Examples include, but are not limited to, a steam stripping 

unit, wastewater thermal oxidizer, or biological treatment unit. 

Pulp washing system means all equipment used to wash pulp and separate spent cooking chemicals following the 

digester system and prior to the bleaching system, oxygen delignification system, or paper machine system (at 

unbleached mills). The pulp washing system equipment includes vacuum drum washers, diffusion washers, 

rotary pressure washers, horizontal belt filters, intermediate stock chests, and their associated vacuum pumps, 

filtrate tanks, foam breakers or tanks, and any other equipment serving the same function as those previously 

listed. The pulp washing system does not include deckers, screens, knotters, stock chests, or pulp storage tanks 

following the last stage of pulp washing. 

Pulping line means a group of equipment arranged in series such that the wood chips are digested and the resulting 

pulp progresses through a sequence of steps that may include knotting, refining, washing, thickening, blending, 

storing, oxygen delignification, and any other equipment serving the same function as those previously listed. 
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Pulping process condensates means any HAP-containing liquid that results from contact of water with organic 

compounds in the pulping process. Examples of process condensates include digester system condensates, 

turpentine recovery system condensates, evaporator system condensates, LVHC system condensates, HVLC 

system condensates, and any other condensates from equipment serving the same function as those previously 

listed. Liquid streams that are intended for byproduct recovery are not considered process condensate streams. 

Pulping system means all process equipment, beginning with the digester system, and up to and including the last 

piece of pulp conditioning equipment prior to the bleaching system, including treatment with ozone, oxygen, or 

peroxide before the first application of a chemical bleaching agent intended to brighten pulp. The pulping system 

includes pulping process condensates and can include multiple pulping lines. 

Recovery furnace means an enclosed combustion device where concentrated spent liquor is burned to recover 

sodium and sulfur, produce steam, and dispose of unwanted dissolved wood components in the liquor. 

Screen system means equipment in which oversized particles are removed from the pulp slurry prior to the bleaching 

or papermaking system washed stock storage. 

Secondary fiber pulping means a pulping process that converts a fibrous material, that has previously undergone a 

manufacturing process, into pulp stock through the addition of water and mechanical energy. The mill then uses 

that pulp as the raw material in another manufactured product. These mills may also utilize chemical, heat, and 

mechanical processes to remove ink particles from the fiber stock. 

Semi-chemical pulping means a pulping process that combines both chemical and mechanical pulping processes. 

The semi-chemical pulping process produces intermediate yields ranging from 55 to 90 percent. 

Soda pulping means a chemical pulping process that uses sodium hydroxide as the active chemical in the cooking 

liquor. 

Spent liquor means process liquid generated from the separation of cooking liquor from pulp by the pulp washing 

system containing dissolved organic wood materials and residual cooking compounds. 

Steam stripper system means a column (including associated stripper feed tanks, condensers, or heat exchangers) 

used to remove compounds from wastewater or condensates using steam. The steam stripper system also contains 

all equipment associated with a methanol rectification process including rectifiers, condensers, decanters, storage 

tanks, and any other equipment serving the same function as those previously listed.

Strong liquor storage tanks means all storage tanks containing liquor that has been concentrated in preparation for 

combustion or oxidation in the recovery process. 

Sulfite pulping means a chemical pulping process that uses a mixture of sulfurous acid and bisulfite ion as the 

cooking liquor. 

Temperature monitoring device means a piece of equipment used to monitor temperature and having an accuracy of 

±1.0 percent of the temperature being monitored expressed in degrees Celsius or ±0.5 degrees Celsius (C), 

whichever is greater. 

Thermal oxidizer means an enclosed device that destroys organic compounds by thermal oxidation. 

Turpentine recovery system means all equipment associated with recovering turpentine from digester system gases 

including condensers, decanters, storage tanks, and any other equipment serving the same function as those 

previously listed. The turpentine recovery system includes any liquid streams associated with the turpentine 

recovery process such as turpentine decanter underflow. Liquid streams that are intended for byproduct recovery 

are not considered turpentine recovery system condensate streams. 

Weak liquor storage tank means any storage tank except washer filtrate tanks containing spent liquor recovered 

from the pulping process and prior to the evaporator system. 
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Selected definitions from 40 CFR Part 60 subpart A (NSPS General Provisions):

Commenced means, with respect to the definition of new source in section 111(a)(2) of the Act, that an owner or 

operator has undertaken a continuous program of construction or modification or that an owner or operator has 

entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program 

of construction or modification. [§60.2]

Construction means fabrication, erection, or installation of an affected facility. [§60.2]

Modification means any physical change in, or change in the method of operation of, an existing facility which 

increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by that facility 

or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not 

previously emitted. [§60.2]

Reconstruction means the replacement of components of an existing facility to such an extent that: (1) The fixed 

capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to 

construct a comparable entirely new facility, and (2) It is technologically and economically feasible to meet the 

applicable standards set forth in this part. [§60.15(b)]

Selected definitions from 40 CFR Part 63 subpart A (NESHAP General Provisions):

Commenced means, with respect to construction or reconstruction of an affected source, that an owner or operator 

has undertaken a continuous program of construction or reconstruction or that an owner or operator has entered 

into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of 

construction or reconstruction. [§63.2]

Construction means the on-site fabrication, erection, or installation of an affected source. Construction does not 

include the removal of all equipment comprising an affected source from an existing location and reinstallation of 

such equipment at a new location. The owner or operator of an existing affected source that is relocated may elect 

not to reinstall minor ancillary equipment including, but not limited to, piping, ductwork, and valves. However, 

removal and reinstallation of an affected source will be construed as reconstruction if it satisfies the criteria for 

reconstruction as defined in this section. The costs of replacing minor ancillary equipment must be considered in 

determining whether the existing affected source is reconstructed. [§63.2]

Major source means any stationary source or group of stationary sources located within a contiguous area and under 

common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or 

more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants, 

unless the Administrator establishes a lesser quantity, or in the case of radionuclides, different criteria from those 

specified in this sentence. [§63.2]

Reconstruction, unless otherwise defined in a relevant standard, means the replacement of components of an 

affected or a previously nonaffected source to such an extent that: (1) The fixed capital cost of the new 

components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable new 

source; and (2) It is technologically and economically feasible for the reconstructed source to meet the relevant 

standard(s) established by the Administrator (or a State) pursuant to section 112 of the Act. Upon reconstruction, 

an affected source, or a stationary source that becomes an affected source, is subject to relevant standards for new 

sources, including compliance dates, irrespective of any change in emissions of hazardous air pollutants from that 

source. [§63.2]
Survey Overview Document Form Approved __/__/__

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ATTACHMENT 3

Acronyms and Abbreviations

acfm actual cubic foot (feet) per minute 

ADTBP air-dried ton(s) of bleached pulp

ADTFP air-dried ton(s) of finished paper

ADTP air-dried ton(s) of pulp

APCD air pollution control device(s)

As arsenic

AS activated sludge

ASB aerated stabilization basin(s)

atm atmosphere(s)

Be beryllium

BLO black liquor oxidation

BLS black liquor solids

BOD biochemical oxygen demand

BOD5 5-day BOD

Btu British thermal unit(s)

°C degrees Celsius

Ca calcium

CaO calcium oxide (lime)

CBI confidential business information

CCA Clean Condensate Alternative

Cd cadmium

CDD chlorinated dibenzo-p-dioxin

CDF chlorinated dibenzofuran

CEMS continuous emissions monitoring system(s)

CERCLA Comprehensive Environmental Response, 

Compensation, & Liability Act

cfm cubic feet per minute

CFR Code of Federal Regulations

Cl2 chlorine

ClO2 chlorine dioxide

Co cobalt

CO carbon monoxide

CO2 carbon dioxide

COMS continuous opacity monitoring system(s)

Cr chromium

cu ft cubic foot (feet)

CY calendar year

d day(s)

DCE direct contact evaporator 

dscf dry standard cubic foot (feet)

dscfm dry standard cubic feet per minute

ECF elemental chlorine free

EIS Emissions Inventory System

EPA U.S. Environmental Protection Agency

ESP electrostatic precipitator(s)

°F degrees Fahrenheit

ft foot (feet)

ft2square foot (feet)

g gram(s)

gal gallon(s)

gpm gallon(s) per minute

gr grain(s)

GW groundwood

H2O water

H2S hydrogen sulfide

HAP hazardous air pollutant(s)

HCl hydrochloric acid

Hg mercury

HHV higher heating value

hr hour(s)

HVLC high volume low concentration

HW hardwood 

in. inch(es)

ISIS Industrial Sector Integrated Solutions

kg kilogram(s)

KMNO4 potassium permanganate

KOH potassim hydroxide

kWh kilowatt-hour(s)

l liter(s)

lb pound(s)

LK lime kiln(s)

LVHC low volume high concentration

MACT maximum achievable control technology

MDL method detection limit

MEE multiple-effect evaporator(s)

mg milligram(s)

Mg megagram(s); magnesium

MLVSS mixed liquor volatile suspended solids

MMBtu million Btu

mmscf million standard cubic feet

Mn manganese

NA Not Applicable

NAICS North American Industry Classification 

System

NaOH sodium hydroxide

NATA National-Scale Air Toxics Assessment

NCASI National Council of the Paper Industry for 

Air and Stream Improvement

NCG noncondensable gas(es)

NDCE nondirect contact evaporator

NEC Not Elsewhere Classified

NEI National Emissions Inventory

NESHAP National emissions standard(s) for 

hazardous air pollutants

NH3 ammonia

Ni nickel

No. number

NOX nitrogen oxides

NSPS new source performance standard(s)

NSSC neutral sulfite semichemical

O2 oxygen

O3 ozone 

OCC Old Corrugated Container

ODP oven-dried pulp 
Survey Overview Document Form Approved __/__/__

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ODT oven dried ton(s)

ONP Old News Print

OTM Other Test Method

PAH polycyclic aromatic hydrocarbons

Pb lead

PCC precipitated calcium carbonate

PCF processed chlorine free

PM particulate matter

PM10 PM with an aerodynamic diameter of up to 

10 μm

PM2.5 PM with an aerodynamic diameter of up to 

2.5 μm

POM polycyclic organic matter

ppm part(s) per million

ppmdv part(s) per million dry volume

ppmdw part(s) per million dry weight

ppmv part(s) per million by volume

ppmw part(s) per million by weight

RF recovery furnace(s)

RMP refiner mechanical pulping

RTO regenerative thermal oxidizer(s)

RTR residual risk and technology review

Sb antimony

SCA specific collecting area

SCC Source Classification Code

scf standard cubic foot (feet)

scfm standard cubic feet per minute

SDT smelt dissolving tank(s)

Se selenium

sec second(s)

SIC Standard Industrial Classification

SO2 sulfur dioxide

SOG stripper offgas(es)

SSM startup, shutdown, and malfunction

st short ton(s)

SW softwood

TBD To Be Determined

TCF totally chlorine free

TCDD tetrachlorodibenzo-p-dioxin

TEQ 2,3,7,8-TCDD toxic equivalent

THC total hydrocarbon

TMP thermomechanical pulping

ton ton(s)

tph ton(s) per hour

tpy ton(s) per year

TRI Toxics Release Inventory 

TRS total reduced sulfur

UK Unknown

U.S. United States

VOC volatile organic compound

WESP wet ESP

WS wet scrubber

Wt% weight-percent 

WW wastewater

WWT wastewater treatment 

WWTP wastewater treatment plant

Y/N yes/no

yr year

μg micrograms

μm micrometer(s)
Survey Overview Document Form Approved __/__/__

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ATTACHMENT 4

SIGNED CERTIFICATION FORM

Instructions: Submit a hard (or electroinic) copy this completed form with each part of 

your survey response (Part I, Part II, and Part III).

Check the appropriate certification statement below for the part of the survey being 

submitted:

□ Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information provided in my response to Part I of this survey are (to the 

best of my knowledge) true, accurate, and complete.

□ Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information provided in my response to Part II of this survey are (to the 

best of my knowledge) true, accurate, and complete.

□ Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information provided in my response to Part III of this survey are (to the 

best of my knowledge) true, accurate, and complete.

Signature: ____________________________________________

Printed name: _________________________________________

Title: _________________________________________________

Company: _____________________________________________

Date signed: ___________________________________________