1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

SECTOR POLICIES AND PROGRAMS DIVISION

OFFICE OF AIR QUALITY PLANNING AND STANDARDS

OFFICE OF AIR AND RADIATION

January 31, 2013

MEMORANDUM

SUBJECT: Meeting notes for the December 13, 2012 meeting with Stephen Woock of 

Weyerhaeuser

FROM: Kelley Spence (EPA/OAR/OAQPS/SPPD/NRG)

TO: Docket EPA-HQ-OAR-2012-0640

This memorandum summarizes the meeting between Stephen Woock of Weyerhaeuser and the 

EPA on December 13, 2012. This meeting was requested in response to the review of the Kraft 

Pulp Mills New Source Performance Standards (NSPS). The OAQPS kraft pulping NSPS review 

presentation is provided in Attachment 1. 

Meeting Attendees:

John Bradfield, EPA

Kelley Spence, EPA

Nick Swanson, EPA

Stephen Woock, Weyerhaeuser 

Discussion Points:

• Subpart S and excess emission allowances update

• NSPS update

o Review of Attachment 1

o Weyerhaeuser noted the need to make monitoring and reporting more efficient between 

the other rules that impact the sector

o Discussion of best practices for monitor downtime
2

Attachment 2

EPA Status of the Kraft NSPS
Status of the Kraft Pulping NSPS 

Review (40 CFR Subpart BB)

December 13, 2012

1
Overview of Activities

• Current Activities

– Assembly and analysis of emissions data and 

permit limits

– Identification of regulatory options

• Next Steps

– Estimate impacts of options

– Draft rule for internal review

• Propose by May 15, 2013

• Promulgate by March 14, 2014

PRELIMINARY ANALYSIS OF ICR DATA 

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Affected Source Projections

• Projections of new, modified, and 

reconstructed emission units.

• Estimate impacts for 5 years after applicability 

date of NSPS review (2013 proposal)

• Created inventory of DCE (and associated 

BLO), NDCE, LK, and SDT systems from Part III 

ICR data

 

PRELIMINARY ANALYSIS OF ICR DATA 

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Affected Source Projections

PRELIMINARY ANALYSIS OF ICR DATA 

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Equipment Type

Recovery furnaces

DCE NDCE LK SDT

Historical Data

Number of units in ICR data base 43 108 131 164

New installations triggering NSPS 2 48 46 56

Modifications/reconstructions triggering NSPS1 1 27 16 14

Total number that triggered NSPS since 1976 3 75 62 70

Average number of new installations per year (over 33 yrs) 0.06 1.45 1.39 1.70

Average number of modified/reconstructed emission units per year (over 33 yrs) 0.03 0.82 0.48 0.42

Projection for Next 5 Years

Projected number of new installations2 0 7 7 8

Projected number of modified/reconstructed emission units2 0 4 2 2

1. Any NSPS units not specifically labeled as “new” or “replacement” were considered to trigger NSPS through modification or reconstruction, 

even if not specifically labeled as modified or reconstructed.

2. Calculated as the average number per year x 5 years, rounded to nearest whole number. 
Recovery Furnaces

• 151 recovery furnaces: 43 DCE, 108 NDCE

– DCEs controlled by DBESP (10), DBESP/SCBR (1), 

DBESP-WPR (3), WBESP (27), and WBESP/SCBR (2)

– NDCE controlled by DBESP (78), DBESP/SCBR (1), 

DBESP-WPR (13), 2-sided DB-WBESP (1), SCBR (2), 

and WBESP (13)

– Counts subject to change (e.g., adjustments for 

recent DCE -> NDCE conversions and/or nonoperational units)

PRELIMINARY ANALYSIS OF ICR DATA 

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Recovery Furnace PM

• Current NSPS and existing source MACT limit 

is 0.044 gr/dscf @ 8% O2

• MACT new limit is 0.015 gr/dscf @ 8% O2

• Permit limits:

– About half of the RFs have PM permit limits below 

0.044 gr/dscf @ 8% O2 

– A few pre-NSPS units have limits above 0.044 

(e.g., MACT PM bubble mills)

PRELIMINARY ANALYSIS OF ICR DATA 

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Recovery Furnace PM Stack Data

• 206 PM stack tests on 136 recovery furnaces 

– Method 5 filterable PM (few ODEQ M5)

– 2002 to 2011 stack tests

– Multiple tests for some furnaces

– 62 DCE tests: 

• 18 DBESP, 4 DBESP-WPR, 36 WBESP, 1 DBESP/SCBR and 

3 WBESP/SCBR

– 144 NDCE tests:

• 95 DBESP, 18 DBESP-WPR, 22 WBESP, 7 DBESP/SCBR, 

1 DB-WBESP [2-sided, dry and wet], and 1 SCBR

PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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8
PRELIMINARY ANALYSIS OF ICR DATA 

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9
PRELIMINARY ANALYSIS OF ICR DATA 

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RF PM Stack Data Observations

• NDCE and DCE similar results for PM

• Two-thirds of the DCEs and NDCEs have 

performance levels at or below 0.015 

gr/dscf using typical recovery furnace 

controls such as DBESP, WBESP, or 

DBESP-WPR.

PRELIMINARY ANALYSIS OF ICR DATA 

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Recovery Furnace Opacity

• 160 RF COMS data sets analyzed

– Some RFs have two COMS in separate stacks 

– Primarily 6-min average analyzed

– Some highest 6-min average per hour or hourly average

• Current NSPS limit is 35% opacity

– 6% of averages per quarter excluding SSM can exceed 

without violating standard

• MACT new limit is 20% opacity

– 6% of quarterly operating time allowance

• Many permits with limits below 35% opacity; 20% 

opacity common

PRELIMINARY ANALYSIS OF ICR DATA 

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10

12

14

16

18 Annual Average Opacity (including exceedances)

Annual Average Opacity - DCE vs. NDCE (Showing APCD)

DCE - DBESP DCE - DBESP-WPR DCE - WBESP

NDCE - DBESP NDCE - DBESP-WPR NDCE - DBESP-WPR/DBESP/DBESP

NDCE - DB-WBESP [2-sided dry and wet] NDCE - WBESP

PRELIMINARY ANALYSIS OF ICR DATA 

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10

15

20

25

30

35

40

45

50 99th Percentile

99th Percentile - DCE vs. NDCE (Showing APCD)

DCE - DBESP DCE - DBESP-WPR DCE - WBESP

NDCE - DBESP NDCE - DBESP-WPR NDCE - DBESP-WPR/DBESP/DBESP

NDCE - DB-WBESP [2-sided dry and wet] NDCE - WBESP

Current NSPS opacity limit = 35%

MM new = 

20%

Highest 6-min average 

provided for each hour

PRELIMINARY ANALYSIS OF ICR DATA 

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15PRELIMINARY ANALYSIS OF ICR DATA 

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0%

1%

2%

3%

4%

5%

6%

7%

8%

9%

10% Percent of Averaging Periods Exceeding 20%

Percent of Averaging Periods Exceeding 20% - DCE vs. NDCE (Showing APCD)

DCE - DBESP DCE - DBESP-WPR DCE - WBESP

NDCE - DBESP NDCE - DBESP-WPR NDCE - DBESP-WPR/DBESP/DBESP

NDCE - DB-WBESP [2-sided dry and wet] NDCE - WBESP

Note: One non-NSPS NDCE with DBESP exceeding 20% 

opacity for 27.6% of time omitted from chart. (606.RB4)
Recovery Furnace TRS

• 141 RF TRS CEMS data sets analyzed

– Primarily 12-hour average; a few 24-hour average for non-NSPS 

furnaces

• Current NSPS limits:

– 5 ppmdv @ 8% O2[straight RF]; 25 ppmdv @ 8% O2[cross RF]

– Allowance for 1% of quarterly averages to exceed limit 

• Only 1 “cross” recovery furnace exists, and it is subject to 

the lower 5 ppm TRS limit for “straight” recovery furnaces 

(not 25 ppm)

• Straight RF NSPS limit based on use of process controls and 

NDCE or process controls and 2-stage BLO for DCE

• Most NDCEs have 5 ppm TRS permit limit and most DCEs 

have 20 ppm limit (emission guidelines)

PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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10

11

12

13

14

15

16

17

18 TRS, ppmdv @ 8% O2

Annual Average of the TRS Averaging Periods (NSPS and Non-NSPS Furnaces)

Values are mostly 12-hr averages, with some 24-hr averages for non-NSPS units. 

Note that compliance is based on each 12-hr average, not the annual average.

DCE NDCE

Current NSPS limit for straight RF (DCE and NDCE) = 5 ppm @ 8%O2

Emission guidelines (8% O2) = 5 ppm for 

NDCE and 20 ppm for DCE

Current NSPS limit for cross RF (DCE and NDCE) = 25 ppm @ 8%O2. Only 1 cross RF 

exists and it is permitted to meet the straight RF TRS limit.
PRELIMINARY ANALYSIS OF ICR DATA 

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10

15

20

25

30 TRS, ppmdv @ 8% O2

99th Percentile of the TRS Averaging Periods (NSPS and Non-NSPS Furnaces)

DCE NDCE

Current NSPS limit for straight RF (DCE and NDCE) = 5 ppm @ 8%O2

Emission guidelines (8% O2) = 5 ppm for 

NDCE and 20 ppm for DCE

Current NSPS limit for cross RF (DCE and NDCE) = 25 ppm @ 8%O2. Only 1 cross RF 

exists and it is permitted to meet the straight RF TRS limit.

Two 99th percentile outliers omitted: non-NSPS DCE (126 ppm), and 

NSPS NDCE (43 ppm)
PRELIMINARY ANALYSIS OF ICR DATA 

DRAFT - SUBJECT TO CHANGE 19 0% 0.3% 0% 0% 0%0%0% 1% 1% 0.3% 1% 1% 0%0% 7% 0.1%0%0% 3% 0% 2% 0% 0.3% 2% 0% 0.1%0% 0.1%0% 0.3% 0.3% 0%0%0%0%0%0%0%0%0%0% 0.1%0%0%0%0%0%0%0% 1% 0%0%0%0%0% 0.3% 2% 0%0%0%0%0% 1% 3% 0% 1% 0.3% 0.5% 0.4%0.1% 1% 0%0% 0.3% 0%0%0%0%

0%

1%

2%

3%

4%

5%

6%

7%

8% Percent of Averaging Periods, %

Percent of TRS 12-hour Averaging Periods in Excess of 5 ppmdv @ 8% O2 (NSPS Furnaces)

DCE NDCE

Current monitoring allowance 

forrecovery furnace TRS is 1%.

One NSPS DCE with 46% of averaging 

periods exceeding 5 ppmdv is omitted 

from the graph.
Lime Kilns

• 131 lime kilns

– Controls include Scrubber (92), ESP (29) and 

ESP/scrubber (10)

• Use of ESP and ESP/scrubber systems is a 

development since 1986 NSPS review 

– Reviewing monitoring options to include in the 

NSPS for these systems 

PRELIMINARY ANALYSIS OF ICR DATA 

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Lime Kiln PM

• Current limits (all @ 10% O2):

– NSPS: 0.066 gr/dscf (gas) and 0.13 gr/dscf (oil)

– MACT (Subpart MM): 

• Existing: 0.064 gr/dscf

• New: 0.010 gr/dscf

• Gas/oil and gas/pet coke combinations are not 

addressed in the current NSPS

• Test data do not show a clear distinction in 

fuel type vs. PM emissions

PRELIMINARY ANALYSIS OF ICR DATA 

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Lime Kiln PM Stack Data

• 255 PM stack tests on 110 kilns reviewed

– Method 5 filterable PM

– 2001 to 2011 stack tests

– ESP (113), ESP/scrubber (26), and scrubber (116) 

controls

– Gas (111), oil (55), gas/oil (9), gas/pet coke (13), 

and unspecified (67) fuels

PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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Kiln PM Stack Data Observations

• ESP and ESP/scrubber controls out-perform 

scrubbers alone and are the only systems 

expected to achieve a new source limit of 0.01 

(the MACT new limit).

• The majority of kilns with ESP and 

ESP/scrubber meet performance levels of 

0.01, regardless of permitted limit.

PRELIMINARY ANALYSIS OF ICR DATA 

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Lime Kiln Opacity (ESP Control)

• NSPS currently specifies no LK ESP monitoring 

requirements 

• 20% opacity required in majority of permits

• MACT requires 20% opacity

– 6% of quarterly operating time allowance

• 29 LK COMS data sets analyzed

– Primarily 6-min average; two hourly average

– Included COMS on 5 ESP/scrubber systems

PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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10

12

14

16

18

20 Annual Average Opacity

Lime Kiln Annual Average Opacity

Calculated as the average of the averaging periods for all COMS data sets.

ESP ESP/SCBR

MACT violation level = 20% opacity for more than 6% of quarterly operating time
PRELIMINARY ANALYSIS OF ICR DATA 

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10

15

20

25

30 99th Percentile Opacity

99th Percentile of Lime Kiln COMS Data Sets

Calculated as the 99th percentile of the averaging periods for all COMS data sets.

ESP ESP/SCBR

MACT violation level = 20% opacity for more than 6% of quarterly operating time

These kilns exceeded 20% opacity for 

less than 6 percent of annual 

operating time.
PRELIMINARY ANALYSIS OF ICR DATA 

DRAFT - SUBJECT TO CHANGE 31 0.03% 0.11% 0.06% 0.01% 0.005% 0.06% 0.34% 1.2% 0% 0.04% 0.01% 0.01%0% 0.37%0.005% 0.002% 0.01% 0.003% 0.01% 2.2% 0.1% 0.4%0.11%0% 0.03% 0.54% 0.00% 0.28% 2.6%

0%

1%

2%

3%

4%

5%

6% Percent of Averaging Periods

Percent of Lime Kiln COMS Averaging Periods Exceeding 20%

MACT allowance = 6% of quarterly operating 

ESP ESP/SCBR
Lime Kiln TRS

• 112 TRS CEMS data sets analyzed

– Primarily 12-hour average

– Some 24-hour average (e.g., non-NSPS kilns)

• Current NSPS limit is 8 ppmdv @ 10% O2

– Based on process control, good mud washing, and 

caustic scrubbing

– No allowance for exceedances

• Approximately half of the units have a permit 

limit of 8 ppmdv and half have limits of 20 ppmdv

(emission guidelines)

PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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10

12

14

16 TRS, ppm at 10% O2

Annual Average TRS CEMS Data for Lime Kilns (Including non-NSPS Kilns) -Calculated as the average of the values for each 12- or 24-hr averaging period -Note that compliance is based on each individual averaging period, not the annual average. 

ESP ESP/SCBR SCBR

Current NSPS Limit = 8 ppm at 10% O2

24-hr average points have orange outline.
PRELIMINARY ANALYSIS OF ICR DATA 

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0.0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

9.0 TRS, ppm at 10% O2

Annual Average TRS CEMS Data for Lime Kilns (NSPS Kilns Only) -Calculated as the average of the values for each 12- or 24-hr averaging period -Note that compliance is based on each individual averaging period, not the annual average. 

ESP ESP/SCBR SCBR

Current NSPS Limit = 8 ppm at 10% O2

All are based on 12-hr averaging period except for first scrubber.
PRELIMINARY ANALYSIS OF ICR DATA 

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0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

16.0 TRS, ppm at 10% O2

99th Percentile of TRS CEMS Data Averaging Periods for Lime Kilns (NSPS Kilns Only)

ESP ESP/SCBR SCBR

Current NSPS Limit = 8 ppm at 10% O2 2 NSPS kilns with 99th percentile exceeding 100 are 

omitted from this chart (1 ESP and 1 SCBR) .

All are based on 12-hr averaging period except for first scrubber.
PRELIMINARY ANALYSIS OF ICR DATA 

DRAFT - SUBJECT TO CHANGE 36 0%0%0% 0.29%0%0% 0.42% 1.2%0%0% 1.7% 0% 1.0%0% 4.0% 0.0% 0.15%0%0% 1.0% 0.22%0%0%0%0%0% 0.15% 0.14% 0.14% 0.0% 0.0% 11.1% 0.41% 2.8% 5.6% 0.32%0% 0.58% 4.1% 0%0% 22.8% 0% 0.27%0% 0.14%0%0%0%0%0% 0.28%0%0% 0.14%0% 0.27% 0.15%0%

0%

5%

10%

15%

20%

25% Percent of averageing periods exceeding 8 ppm

Percent of Periods Exceeding TRS 8 ppm Limit for Lime Kilns (NSPS Kilns Only)

Note: The NSPS has no allowance for lime kiln TRS (e.g., any average that is an exceedance is a violation).

ESP ESP/SCBR SCBR All are based on 12-hr averaging period except for first scrubber.
Smelt Dissolving Tanks (SDTs)

• 164 SDTs

– Controlled by mist eliminator (5), scrubber (156), 

or incineration in recovery furnace (3)

– Incineration control is a new development since 

the 1986 NSPS review, but no PM or TRS test data 

are available to determine performance (comingled exhaust)

• Scrubbers are predominant control

• Monitor scrubber parameters (not opacity)

PRELIMINARY ANALYSIS OF ICR DATA 

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SDT PM and TRS Stack Data

• PM and TRS limits are in lb/ton BLS 

– Needed tests with production data to compare to limits

• 182 PM stack tests reviewed

– Method 5 filterable PM

– 2001 to 2011 stack tests

– 4 mist eliminator, 20 packed bed scrubber, and 158 scrubber 

tests

• 100 TRS stack tests reviewed

– Methods 16 or 16A/B/C

– 1987 to 2011 (all but 7 tests were 2004 or more recent)

– Emissions converted to “as H2S” basis consistent with NSPS limit

– 91 scrubber, 6 packed bed scrubber, and 3 mist eliminator tests

• No stack data for SDTs venting through recovery furnaces

PRELIMINARY ANALYSIS OF ICR DATA 

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Smelt Dissolving Tank PM

• NSPS and MACT (existing) limit is 0.2 lb/ton 

BLS

• MACT (new) limit is 0.12 lb/ton BLS

• Permit limits:

– Most SDTs have limits of 0.2 lb/ton BLS

– About 20 percent of SDTs have limits below 0.2; 

most around 0.12 lb/ton BLS

PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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0.05

0.1

0.15

0.2

0.25

0.3

0.35 PM, lb/ton BLS

SDT PM Stack Test Performance Levels

(Performance levels are based on the max of multiple stacks; and average of multiple tests on the same SDT)

Mist Eliminator Scrubber Packed Bed Scrubber

NSPS limit =

MACT (existing) = 

0.2 lb/ton BLS

MACT (new) =

0.12 lb/ton BLS

All SDTs above 0.2 participate in the 

PM MACT bubble except these two.
Smelt Dissolving Tank TRS

• Original NSPS limit was 0.0168 lb/ton BLS

• During the 1986 NSPS review the limit was 

increased to 0.033 lb “as H2S”/ton BLS

• Emission guideline document developed prior 

to 1986 NSPS review had 0.0168 lb/ton BLS

• Most SDTs have permit limits of 0.033

– Approximately 20% of the units are required to 

meet 0.0168 lb/ton BLS

PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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0.005

0.01

0.015

0.02

0.025

0.03

0.035 TRS as H2S, lb/ton BLS

SDT TRS Stack Test Performance Levels

(Performance levels are based on the max of multiple stacks; and average of multiple tests on the same SDT)

Mist Eliminator Scrubber Packed Bed Scrubber

NSPS limit =

0.033 lb as H2S/ton BLS