Multi-Pollutant Sector Rule for the Pulp and Paper Industry

Response to Comments Received on

Information Collection Request

Submitted for OMB Review

(Published on December 7, 2010)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

Natural Resources and Commerce Group

Research Triangle Park, NC 27711

February 4, 2011
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Table of Contents

Page

1.0 Introduction..........................................................................................................................1

2.0 Requirement to Collect Information ....................................................................................2

2.1 New Source Performance Standards (NSPS) ......................................................... 2

2.2 National Emissions Standards for Hazardous Air Pollutants (NESHAP) .............. 6

3.0 Facilities Required to Respond ............................................................................................7

4.0 Burden of the ICR................................................................................................................8

5.0 Power Boiler Information ..................................................................................................10

6.0 SSM Data...........................................................................................................................12

7.0 Request for Webinar ..........................................................................................................13

8.0 Technical Comments .........................................................................................................14

8.1 Survey Instructions ............................................................................................... 14

8.1.1 Overall Survey Instructions ...................................................................... 14

8.1.2 Survey Instructions for Part I.................................................................... 15

8.1.2 Survey Instructions for Part II................................................................... 16

8.2 Excel Survey ......................................................................................................... 17

8.2.1 Overall Excel Survey ................................................................................ 17

8.2.2 Part I of the Survey (Excel File) ............................................................... 19

8.2.3 Part II of the Survey (Excel File).............................................................. 25

8.2.4 Part III of the Survey (Excel File)............................................................. 25

List of Tables

Page

Table 1. List of Commenters on OMB Review Version of ICR for Pulp and Paper Sector 

NSPS and NESHAP Residual Risk and Technology Review .............................................1
ii

Acronyms and Abbreviations

AF&PA American Forest & Paper Association

BACT Best available control technology

BLS Black liquor solids

Btu British thermal unit(s)

CAA Clean Air Act

CBI Confidential business information

CCA Clean Condensate Alternative

CEMS Continuous emissions monitoring system

dscf Dry standard cubic foot (feet)

EPA U.S. Environmental Protection Agency

FR Federal Register

GHG Greenhouse gas

gpm Gallon(s) per minute

gr Grain(s)

HAP Hazardous air pollutant(s)

HCl Hydrogen chloride

HHV Higher heating value

hr Hour(s)

ICR Information collection request

lb Pound(s)

MACT Maximum achievable control technology

MM Million

NCASI National Council for Air and Stream Improvement, Inc.

NCG Noncondensible gas

NEI National Emissions Inventory

NESHAP National emissions standards for hazardous air pollutant

NOX Nitrogen oxides

NSPS New source performance standards

OMB Office of Management and Budget

PCC Precipitated calcium carbonate

PM Particulate matter

PSD Prevention of Significant Deterioration

RTR Residual risk and technology review

SARA Superfund Amendments and Reauthorization Act

SOG Stripper offgas

SSM Startup, shutdown, and malfunction

TRI Toxics Release Inventory

TRS Total reduced sulfur
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1.0 Introduction

On December 7, 2010, the U.S. Environmental Protection Agency (EPA) submitted for 

Office of Management and Budget (OMB) review (75 FR 76005) an information collection 

request (ICR) for the pulp and paper multi-pollutant sector rule (EPA ICR No. 2393.01). The 

sector rule includes both the new source performance standards (NSPS) review and the national 

emission standards for hazardous air pollutants (NESHAP) residual risk and technology review 

(RTR). The respondents affected by this action are owners/operators of mills that are major 

sources of hazardous air pollutant (HAP) emissions, as defined in 40 CFR 63.2. These major 

source mills include: 

• Mills that perform chemical wood pulping (kraft, soda, sulfite, or semichemical)

• Mills that perform mechanical, groundwood, secondary fiber, and non-wood pulping

• Mills that perform bleaching

• Mills that manufacture paper or paperboard products

A 30-day comment period (ending January 6, 2011) was provided for the public to 

submit comments to EPA regarding the new data collection. Two comments were received by 

EPA regarding the information collection request. (See www.regulations.gov, docket ID no. 

EPA-HQ-OAR-2007-0544, for the complete comments.) Table 1-1 lists the names of the 

commenters, the commenters’ affiliations, and the docket item number assigned to each of the 

comments submitted to EPA. 

Table 1. List of Commenters on OMB Review Version of ICR for Pulp and Paper Sector 

NSPS and NESHAP Residual Risk and Technology Review

Docket No.

EPA-HQ-OAR2007-0544 Date Posted Commenter Name and Affiliation

0021 12/20/2010

Timothy G. Hunt

Senior Director, Air Quality Programs

American Forest & Paper Association (AF&PA)

0022 1/6/2011

Stephen E. Woock

EHS&S Federal Regulatory Affairs Manager,

Weyerhaeuser

This document summarizes the substantive comments received by EPA on the OMB 

review version of the ICR and presents EPA’s response to each of those comments. The 

comment summaries and responses are grouped by topic in the following sections.
2

2.0 Requirement to Collect Information

2.1 New Source Performance Standards (NSPS)

Comment: Commenter 0021 noted that, in the Federal Register notice for the ICR, EPA 

asserts that the information being solicited in the industry questionnaire is necessary in order to 

meet Clean Air Act (CAA) requirements. As the commenter stated in his comments on the draft 

ICR, EPA substantially overstates what it is required to do under the CAA. According to the

commenter, to a significant extent, the questionnaire is directed at obtaining information that 

would support EPA rulemaking that is not required and that, in the context of the large number 

of additional CAA requirements being imposed on the industry, should not be undertaken at this 

time. Thus, the commenter concluded that much of the paperwork burden EPA proposes to 

impose through this ICR is unnecessary.

Commenter 0021’s comments on the draft ICR noted several points as to why NSPS 

information should not be required. Specifically:

• The commenter noted that review of NSPS is not required of “any such standard if the 

Administrator determines that such review is not appropriate in light of readily available 

information on the efficacy of such standard.” [CAA section 111(b)(1)(B)]

• The commenter noted that the existing NSPS require, among other things, collection and 

incineration of most sources of total reduced sulfur (TRS) compound emissions at kraft 

pulp mills. According to the commenter, the NSPS thus already require a high level of 

reduction of TRS. In addition, the commenter noted that the pulp and paper maximum 

achievable control technology (MACT) standards also require incineration or similarly 

highly effective means of controlling the organic gas streams from kraft pulp mills, which 

also contain TRS.

• While particulate control technology has improved since the Kraft Pulp Mill NSPS were 

promulgated, the commenter noted that EPA, since that time, has also promulgated 

stringent particulate emission limits in the MACT standards for new pulp mill 

combustion sources as a surrogate for metallic HAP. According to the commenter, these 

MACT standards are much lower than the NSPS limits: 0.015 vs. 0.044 grain per dry 

standard cubic foot (gr/dscf) for recovery furnaces, 0.12 vs. 0.2 pounds per ton of black 

liquor solids (lb/ton BLS) for smelt dissolving tanks, and 0.01 vs. 0.067 or 0.13 gr/dcsf 

for lime kilns. Thus, the commenter argued that EPA should conclude that review of the 

NSPS particulate limits would not be productive.

• As for other pollutants that are emitted by kraft pulp mills but not covered by the Kraft 

Pulp Mill NSPS, the commenter stated that EPA is under no obligation to add pollutants 

to those already regulated by the Kraft Pulp Mill NSPS. According to the commenter, 

nothing in CAA section 111 requires that NSPS cover all pollutants emitted by a source, 

and EPA has never interpreted it that way. See, e.g., 74 Fed. Reg. 51,950, 51,957 (Oct. 8, 

2009) (“The statutory scheme thus provides EPA with significant discretion to determine 

which pollutant(s) should be regulated under the NSPS. “); National Lime Ass’n v. EPA, 

627 F.2d 416, 426 (D.C. Cir. 1980) (observing that, while “lime plants were determined 

to be sources of nitrogen oxides, carbon monoxide and sulfur dioxide as well as 

particulates, standards of performance were proposed and ultimately promulgated only 

with respect to particulate matter.”); 70 Fed. Reg. 9706, 9711 (Feb. 28, 2005) (where 

EPA declined to set nitrogen oxide (NOx) limits for boilers below 100 million British 
3

thermal units per hour (MMBtu/hr) heat input, based on current emission levels, 

available technologies, and costs). In fact, before expanding the Kraft Pulp Mill NSPS to 

cover additional pollutants, the commenter argued that EPA would have to justify its 

departure from its prior decisions about which pollutants the NSPS should cover.

Commenter 0021 disagreed with EPA’s statement that data are either not readily 

available or outdated for the Agency to conclude that a review of NSPS is not necessary, and that 

a survey would be an efficient way to obtain the necessary data for review of NSPS Subpart BB. 

The commenter reiterated the point made previously that the control of sources that contain TRS 

compounds (and other HAP emissions) was already at a high level for NSPS and only increased 

with MACT requirements. In addition, the commenter noted that MACT PM limits for new 

sources are much lower than NSPS limits.

According to commenter 0021, EPA has a great deal of information about emissions of 

kraft pulping vent gases and emissions from kraft pulp mill chemical recovery systems, as well 

as the emission controls used for these sources, from the subparts S and MM rulemakings and 

from the compliance demonstrations and continuous monitoring required by those regulations. 

While much of the data is submitted to state agencies that are the delegated authority, the 

commenter noted that EPA can request this information from the state and/or local agencies. In 

addition, the commenter noted that EPA also has been considering these emissions recently in 

connection with its ongoing evaluation of residual risk for pulping and chemical recovery 

sources. The commenter also noted that NCASI publications related to the latest information on 

kraft pulp mill emissions and configurations are available to EPA and represent the latest 

research being conducted in our industry. Further, the commenter noted that a large percentage 

of the data that EPA will receive through this survey will be based on NCASI data. The 

commenter concluded that EPA could, on the basis of “readily available information,” determine 

that review of the kraft pulp mill NSPS, or a portion thereof, is not necessary. 

Response: Three federal emission standards are the subject of the pulp and paper 

information collection:

Standard Promulgation date

Standards of Performance for Kraft Pulp Mills (40 CFR part 60, 

subpart BB)

1978 

(reviewed 1986)

National Emission Standards for Hazardous Air Pollutants from 

the Pulp and Paper Industry (40 CFR part 63, subpart S)

1998

National Emission Standards for Hazardous Air Pollutants for 

Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, 

and Stand-Alone Semichemical Pulp Mills (40 CFR part 63, 

subpart MM

2001

Section 111(b)(1)(B) of the CAA mandates that EPA review and, if appropriate, revise 

existing NSPS at least every 8 years. Section 112(f)(2) of the CAA directs 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 review and revise the MACT standards, as 

necessary, taking into account developments in practices, processes, and control technologies. 

The section 112(f)(2) residual risk and section 112(d)(6) technology reviews are to be done 8 
4

years after NESHAP promulgation. Thus, all three of the emission standards listed above are 

due for review according to dates set forth in the CAA. While we understand that the pulp and 

paper industry is currently facing a large number of additional CAA requirements, EPA cannot 

base its decisions (whether about issuing a survey or developing a rulemaking) on what other 

rulemakings are underway for a particular industry, but on what is required under the CAA. 

The EPA has entered into a proposed Consent Decree (to address a lawsuit filed by Sierra 

Club) that would require proposal of the subpart S RTR by June 15, 2011 and final action by 

December 16, 2011. In addition, EPA has received a notice of intent (NOI) to sue from 

Californians for Alternatives to Toxics (CATs) and the Center for Biological Diversity (CBD), 

contending that EPA has failed to review the NSPS for kraft pulp mills within the statutory 

deadline under CAA section 111(b)(1)(B). The EPA received a petition for rulemaking in 

January 2009 requesting that EPA revise various NESHAP, including the NESHAP for chemical 

recovery combustion sources at pulp mills, to make the NESHAP consistent with CAA precedent 

established in recent judicial rulings. Also, in December 2008, the U.S. Court of Appeals for the 

D.C. Circuit vacated the startup, shutdown, and malfunction provisions contained in the 

NESHAP General Provisions that apply to pulp and paper mills. To the extent that these legal 

actions need to be addressed in the pulp and paper NESHAP, EPA intends to collect the 

information needed to investigate potential rule revisions at the same time as collecting 

information for the CAA-required statutory reviews. 

In the context of NSPS review, we acknowledge that CAA section 111(b)(1)(B) states 

that “the Administrator need not review any such standard if the Administrator determines that 

such review is not appropriate in light of readily available information on the efficacy of such 

standard.” (emphasis added) As discussed below, however, much of the information EPA has 

available for the pulp and paper industry is nearly 20 years old. At present, EPA is seeking data 

reflecting the post-MACT and post-effluent guidelines configurations of pulp and paper emission 

units and air pollution control systems. The EPA is also seeking additional updated information 

to use in the residual risk and technology review (RTR) regulatory analyses required under CAA 

sections 112(d) and 112(f)(2). There is considerable overlap in the emission units regulated 

under NSPS subpart BB and the two NESHAP for the pulp and paper industry. As a matter of 

administrative efficiency, EPA intends to use a single collection of information to seek updated 

information for use in the RTR for both NESHAP and in reviewing the NSPS (as required under 

CAA section 111(b)). 

We acknowledge that the industry provided volumes of useful information for purposes 

of NESHAP development. However, this information used to support the subpart S and MM 

rulemakings is now outdated and may no longer be representative of the latest post-MACT 

developments in practices, processes, and control technologies for the pulp and paper industry. 

(The survey collecting pre-MACT information was sent out in February 1992.) Further, EPA’s 

Office of Air Quality Planning and Standards (OAQPS) does not receive the results from most 

compliance demonstrations and continuous monitoring being requested in the ICR (e.g., because 

these data, if submitted at all, are typically submitted to State agencies delegated authority to 

administer federal standards). Requesting this information from States would:

• Be more burdensome for EPA because the information obtained would not be in a 

consistent electronic format (as would the proposed information collection), 

• Impose burden on the States, and

• Be unlikely to meet EPA’s court-ordered timeframe for the Subpart S RTR, and
5

• Ultimately result in data gaps and information of lower practical utility (e.g, because 

States are not expected to have all of the information requested in the proposed survey).

Section 3a of the supporting statement for the proposed survey explains in greater detail 

why collection of information from States is not preferred for the pulp and paper sector 

information collection effort. Section 3a also explains why NCASI publications (a valuable 

resource for the pulp and paper industry and regulators alike) are not a substitute for the 

information collection. Furthermore, the preliminary information that EPA has received from 

some mills recently for its evaluation of residual risk for the subpart S RTR is only a small 

fraction of the information needed to assess all of the required regulatory reviews. In sum, the 

information requested relevant to the current (post-MACT) equipment configuration and 

operation, regulatory alternatives, emissions data, and effectiveness of various control systems at 

removing HAP is not readily available from other sources. In the absence of an industry data 

collection, the EPA would be forced to try to obtain permits, compliance reports, and emissions 

test reports from States; extract information from these reports (which vary in detail); and then to 

fill data gaps where information is not available from the reports obtained. This process of 

acquiring and extracting data from existing reports would require more time than an industry 

data collection, and ultimately would be expected to yield incomplete information. Information 

collected directly from pulp and paper mills would provide the most timely and complete postMACT data set with the greatest practical utility for purposes of performing the NSPS and RTR 

reviews that are due to be completed under CAA sections 111(b) and 112(d) and (f)(2).

The EPA believes that the most appropriate and efficient way to assess the latest 

technological developments for the pulp and paper industry is to gather updated information 

through a CAA section 114 ICR. The survey would also reveal if there have been no advances 

in technologies (as the commenters assert). Information collected directly from pulp and paper 

mills will have the greatest practical utility for purposes of performing the RTR and NSPS 

reviews as information from the affected industry will contain the most up-to-date, accurate, and 

reliable equipment and operational data for each mill. CAA section 114(a) states that the 

Administrator may require any owner or operator subject to any requirement of this Act to: (A) 

Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such 

monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions 

(in accordance with such procedures or methods, at such locations, at such intervals, during 

such periods, and in such manner as the Administrator shall prescribe); (E) keep records on 

control equipment parameters, production variables or other indirect data when direct 

monitoring of emissions is impractical; (F) submit compliance certifications in accordance with 

section 114(a)(3); and (G) provide such other information as the Administrator may reasonably 

require.

We do not wish to prejudge the outcome of our regulatory reviews prior to collecting 

information upon which to base these reviews. More information will allow us to determine 

whether a review of NSPS is necessary at this time. The aforementioned NOI asserted that EPA 

must provide standards for all air pollutants that endanger public health and welfare when 

reviewing and revising the NSPS for kraft pulp mills. We will not know whether if is prudent to 

extend the NSPS to additional pollutants until we have collected and reviewed updated 

information to make definitive determinations.
6

2.2 National Emissions Standards for Hazardous Air Pollutants (NESHAP)

Comment: Commenter 0021 argued that EPA’s claimed basis for needing information 

to review and revise NESHAP is overstated. The commenter noted that the Federal Register 

preamble states that “recent case law and legal petitions suggest the need to review the pulp and 

paper NESHAP” and claims a need “to make the NESHAP consistent with CAA precedent 

established in recent judicial rulings.” 75 Fed. Reg. at 35,794. The commenter stated that these 

statements appear to be in direct conflict with the judicial review and emission standard review 

provisions Congress has included in the CAA. The commenter noted that, under CAA section 

307, NESHAP must be challenged through a petition for review filed in the courts of appeals 

within 60 days after publication of the rule. According to the commenter, neither the subpart S 

nor the subpart MM NESHAP was challenged in that manner. The commenter argued that EPA 

is under no obligation to conform these regulations, which have been in effect for many years, 

and which pulp and paper mills have relied on in making their compliance expenditures and 

other capital investments, to principles announced in some cases involving challenges to other 

NESHAPs. According to the commenter, Congress established a system designed to provide 

certainty and clarity: anyone objecting to a rule must challenge it within 60 days; otherwise it 

remains in effect.1 The commenter stated that there is no provision for continued revision of the 

MACT standards in Subparts S and MM and argued that those standards are to remain in place 

unless EPA determines more stringent limits are necessary to avoid unacceptable residual risk 

under CAA section 112(f), or EPA determines that there have been significant advances in 

hazardous air pollutant control technology, pursuant to CAA section 112(d)(6).

Commenter 0021 noted that EPA did not directly respond to this comment but instead 

noted that the Agency was under a Consent Decree for subpart S RTR and “received a petition 

for rulemaking in January 2009 requesting that EPA revise various NESHAP” including subpart 

MM. The commenter responded to that petition in July of 2009, making the arguments repeated 

above, that reopening the MACT rules was both illegal and unnecessary.2

Response: We acknowledge this comment on the broader legal aspects of EPA’s 

NESHAP (MACT) and RTR programs. Regardless of how recent case law and legal petitions 

are ultimately interpreted, EPA’s need for information upon which to base the regulatory actions 

due to be completed remains. As discussed in Section 2.1 above, the required regulatory actions 

(the subpart BB NSPS review, subpart S and MM NESHAP technology reviews, and subpart S 

and MM NESHAP residual risk reviews) are all due to be completed. As a matter of efficiency, 

EPA intends to use a single collection of information to seek updated information for use in all 

of these reviews.

 1 According to commenter 0021, there is a provision allowing challenges later if the challenge is based on grounds 

that arose after the 60-day period has run that affect the rule’s provisions or how it is implemented. The commenter 

stated that would allow challenges based on new facts (such as the fact that another rule that the challenged rule 

relied upon no longer is in effect such as the 2008 SSM case), but not challenges on legal grounds that could have 

been raised, but were not raised, during the initial 60-day period. 2 See July 21, 2009 letter from AF&PA, API and ACC to EPA Administrator Lisa Jackson on the petition or 

rulemaking by NRDC
7

3.0 Facilities Required to Respond

Comment: Commenter 0021 noted in comments to the draft ICR that the preamble 

again glosses over the fact that, even if EPA were required to review existing pulp and paper 

NESHAP to address prior case law, that would not provide any justification for seeking 

information from the majority of the estimated 386 mills to which the questionnaire would be 

directed, since most of those mills are not currently subject to subpart S or MM. The commenter 

stated that EPA responded by only requiring those facilities that are major or synthetic area 

sources to complete the survey. However, the commenter believes that only major sources 

should respond to the survey. According to the commenter, synthetic minor facilities are not 

subject to MACT rules and do not monitor compliance and, therefore, do not have information to 

offer on the impact of MACT implementation.

Response: With this comment, we believe the commenter is referring to non-integrated 

mills that only manufacture paper (but not pulp). Mills that do not manufacture pulp are 

included in the pulp and paper survey because they are part of the subpart S source category for 

which MACT standards were considered. These mills are included in the survey for RTR 

purposes. Some of these mills may be true area sources of HAP emissions, and therefore exempt 

from the pulp and paper survey. Criteria for exemption from the pulp and paper sector survey 

are as follows: 

• The mill is not a major source or synthetic area source of HAP emissions, or

• The mill was not operational in 2009 (and remains closed), or 

• The mill does not produce pulp, perform bleaching, or serve as a primary manufacturer of 

paper or paperboard products.

Upon further consideration, we have eliminated synthetic area sources from inclusion in Part 

II of the pulp and paper survey. The Part II instructions were revised to indicate that synthetic 

area sources are not required to complete Part II. However, we maintain that it is appropriate to 

include synthetic area sources in the scope of Parts I and III of the pulp and paper survey for 

essentially the same reason that synthetic area sources are included in MACT determination (i.e., 

because these sources may employ emission-reducing control technologies that are applicable to 

major sources). We recognize that there are a number of reasons mills can be synthetic area 

sources (e.g., federally enforceable limitation of production, or inherently low emissions due to 

the products produced). Nevertheless, the possibility of emission-reducing controls or process 

changes cannot be ruled out until we explore that possibility as part of a thorough regulatory 

review process. Furthermore, there is no major-area source applicability cutoff for NSPS, so 

while synthetic area sources may not be covered under MACT RTR it is possible that these 

sources could be affected by NSPS revisions. 

We recognize that synthetic area sources will not have information relevant to MACT 

compliance. Unless otherwise specified, these sources should answer “NA” for not applicable or 

select “NA-synthetic area source” on survey questions related to MACT implementation and 

compliance options. We have revised the survey instructions to clarify where it is appropriate 

for synthetic area sources to respond “NA” and we have added menu choices of “NA (synthetic 

area source)” where appropriate. The instructions have also been revised to state that two survey 

tabs (Kraft condensates and CCA) are not applicable synthetic area sources. 
8

4.0 Burden of the ICR

Comment: Commenter 0021 noted that, in the supporting statement, EPA estimated the 

average burden for a facility responding to the questionnaire to be 476 hours, or 59 8-hour 

working days (see EPA-HQ-OAR-2007-0544-0002; total hour burden of 183,746 hours for 386 

facilities). The commenter noted that the survey is now divided into three parts, with Part I

(Subpart S) due within 30 days, Part II (NEI Update) due within 100 days, and Part III (Subpart 

MM) due within 180 days.

Commenter 0021 stated that, while the proposed approach is an improvement over the draft 

ICR, this is still a very short timeline for a facility to get clarification on any necessary items that 

are not understood, collect the information requested (assuming all of the information requested 

is available), arrange it in a format for inclusion in the spreadsheets, quality-assure the 

information after entry into the spreadsheets, and get management review of the information to 

be submitted. The commenter also noted that companies may be having to respond to the ICR 

during the first part of 2011, which is a time when mill and company personnel who would be 

involved in responding to the ICR also are responsible for preparing numerous other reports to 

state and federal authorities (e.g., state annual emission inventories, Title V permit annual 

compliance reports, SARA Title III reports, etc.). In addition, the commenter noted, by March 

31, these facilities are required to report GHG emissions to EPA under a completely new 

regulatory and reporting structure.

According to commenter 0021, the estimate for Part I alone is 210 hours or 26 eight-hour 

working days, with only 30 calendar days to respond (see Attachment 2 of Standard Form 81-I 

Supporting Statement, dated November 16, 2010). The commenter recommended the following 

adjustments to assist in providing the information necessary, while focusing on the critical 

information for subpart S in Parts I and II of the survey.

• The commenter noted that, for the Coal- and Oil-Fired Electric Utility Steam Generating 

Unit ICR, EPA granted a split timeline for companies that had multiple facilities. Due to 

the short time frame for Part I of the survey, the commenter recommended a similar 

approach: specifically, 60 percent of a company’s facilities respond within 30 days, and 

all facilities must respond within 45 days.

• If the Agency determines that it will not remove the NSPS data requests from the 

surveys, the commenter recommended that any continuous emissions monitoring system 

(CEMS) data or test data that are not required for subpart S may be submitted with Part 

III of the survey.

In addition, commenter 0022 requested that Part I be extended to 60 days and the survey 

initiation moved to no sooner than April 2011. The commenter noted that EPA’s timeline, 

especially for the collection of information pertaining to equipment, compliance strategies and 

emissions under Part I related to the NESHAP Subpart S, is in part driven by a consent decree

EPA negotiated with a third party to the exclusion of the pulp and paper industry which contains 

a June 15, 2011 proposal deadline. The commenter stated that this extremely short deadline is an 

unreasonable burden to place on our facilities and those of the industry generally. The 

commenter believes 60 days is a more reasonable period of time to complete that part of the 

survey. The commenter recommended that EPA provide that amount of time and direct its 

attention to renegotiating the Subpart S risk and technology review schedule with the third party

petitioner if the amount of time the Agency needs is too short to process and evaluate the 
9

information and then prepare a rule proposal. The commenter noted that facilities are facing a 

significant number of continuing and new compliance and reporting obligations in the early part 

of 2011. For example, the commenter’s pulp mills are working to compile, calculate, organize 

and report their 2010 greenhouse gas emissions as required under the EPA’s Mandatory 

Greenhouse Gas Reporting rule. This is a new obligation with a March deadline that requires 

significant additional effort as a first time activity, including gaining access to and learning 

EPA’s online “electronic Greenhouse Gas Reporting tool” (e-GGRT) which become available as 

of December 15, 2010. The commenter noted that resources at their facilities are simply not 

available to meet these existing obligations and to provide a thorough, well-developed response 

to Part I of the survey in early 2011 and within such a short timeframe.

Response: We understand the commenters’ concerns regarding the timing of the survey. 

Unfortunately, the deadlines in the consent decree for subpart S RTR dictate the timing for the 

subpart S portion of the survey (Part I) and the NEI update (Part II). We broke the survey into 

three phases following the first public comment period on the draft ICR in order to ease the 

timing burden associated with the survey. While Part I of the survey (Mill Overview and 

Subpart S Data) would be due after 30 days, we are providing additional time for the industry to 

complete the remaining parts of the survey: Part II - NEI update (100 days) and Part III -

chemical recovery combustion unit data (180 days).

Although we are unable to accommodate a longer response time for all facilities, as part 

of this second public review, we are providing additional time for companies with multiple 

facilities as requested. Table 1 in the Survey Overview Document was revised to state:

“An additional 15 days is provided for up to 40 percent of the mills owned by pulp and 

paper companies operating multiple (more than two) mills. For example, for a company 

owning 10 pulp and paper mills, the Part I survey response deadline for 4 of these mills 

may be extended until 45 days following the date stamped on the Section 114 letter.”

Thus, 60 percent of the Part I responses are due within 30 days and 40 percent are postponed 

until 45 days for companies with multiple mills. 

We also added a footnote to Table 1 in the Survey Overview Document that allows mills 

subject to Part III of the survey to postpone submittal of criteria air pollutant emission test data 

and CEMS data until the Part III due date. The footnote states:

“Mills required to complete Part III may postpone until the deadline for Part III 

submittal of emissions test data and CEMS data required for the emission units listed in 

Part I Attachment 1 for the following pollutants: PM, PM2.5, TRS, NOx, SO2, and CO.”

We have also reduced, clarified, or eliminated a number of survey questions as a result of 

comments on this second public review of the survey. Details on these changes are provided in 

the sections below. 

Revised burden estimates associated with the ICR are included in the supporting 

statement for OMB approval. The revised burden estimates reflect:

• Changes made in response to this second public review, 

• Updated information on the population of facilities affected by the survey, and 

• Updated information on the number of mills with pre-existing NEI data. 
10

5.0 Power Boiler Information

Comment: Commenter 0021 noted that, throughout the ICR, EPA requests information 

on power boilers and other incineration devices, as these units can be used to treat 

noncondensible gas (NCG) vents regulated under 40 CFR part 60, subpart BB and 40 CFR part 

63, subpart S. While the commenter acknowledged that these units can be part of the compliance 

approach for these regulations, the commenter does not believe that EPA should collect detailed 

information related to the fuels and capacities of power boilers under this ICR. The commenter

noted that any add-on control information for these units is not necessary since the NCGs are 

presumed to be destroyed by the boiler (see page 14 of the instructions for Part I of the survey, 

EPA-HQ-OAR-2007-0544-0003). In addition, the commenter noted that their facilities have 

recently completed an ICR for the Boiler MACT regulations and that this database contains 

detailed information for each boiler; therefore, the commenter argued that it should not be 

requested again in this ICR. The commenter suggested that the information requested be limited 

to the type of unit used to control NCGs and stripper offgases (SOGs) (boiler, oxidizer, kiln, 

etc.), if the facility has a back-up control device, and how often the mill has bypassed these 

control devices due to their unavailability.

Response: We reduced the scope of the questions related to power boiler fuel use as a 

result of comments received during the first public review of the ICR (but retained enough 

information useful for emissions calculations). The power boiler questions remaining in the pulp 

and paper survey appear in Part I (PI Equip detail tab), and Part II (NEI Update). The EPA is 

interested in boilers because they contribute to the facility-wide risk at pulp and paper mills. 

Boilers may also be used as a control device for pulp mill NCGs or SOGs. Further, boilers are 

one of the larger sources of air pollutants at pulp and paper mills, and information on boilers 

would aid in understanding mill-wide emissions (and in putting pulp and paper process-related 

emissions into perspective).

In our response to comments received during the first public review of the ICR, we noted 

that the scope of the pulp and paper information request for boiler information is more limited 

than the information requested in the 2008 Boiler MACT survey. We also noted that collection 

of limited information through the pulp and paper survey would ensure all data were for a 

consistent (2009) base year, would simplify calculations, and would - most importantly - avoid 

the time-consuming exercise for EPA to attempt to match the Boiler MACT equipment IDs with 

the NEI emission unit IDs provided in the pulp and paper survey’s NEI update. 

In response to comments on this second public review, we are including a form (Boiler 

MACT Code Lookup.xls) that allows mills to supply the Boiler MACT survey identification 

codes (Boiler MACT Facility ID and Unit ID) for their boilers. This will allow EPA to readily 

extract data from the boiler MACT data base for pulp and paper mill boilers and associate these 

boilers with their corresponding NEI Emission Unit ID codes. We have added two columns to 

the PI Equip detail tab of the pulp and paper survey where mills are given the option to specify 

their Boiler MACT ID codes. Mills that provide Boiler MACT survey IDs in the initial columns 

of PI Equip detail do not need to complete following portions of PI Equip detail for the boilers: 

year installed, operating hr/yr, emission unit exhaust parameters, combustion 

modifications/controls, process controls, air pollution controls, fuel-fired equipment, primary 

fuels, supplemental fuels, or emission unit startup/shutdown. However, these mills are still 

asked to complete the Subpart BB and Subpart S applicability columns and “equipment 
11

incinerating NCG or SOG” columns for boilers burning pulp mill NCG or SOG. Mills that do 

not supply boiler MACT survey codes will need to complete the details requested in PI Equip 

detail for their boilers.

We are providing a new file along with Part I, Boiler MACT Code Lookup.xls, for the 

convenience of mills that wish to supply their Boiler MACT ID codes. This file contains the 

FacilityID and UnitID codes extracted from the Boiler MACT survey data base for pulp and 

paper mills (i.e., NAICS 322 mills).

As a result of comments following the current and first public review, boiler information 

is only requested in the PI Equip detail tab. We have further clarified in the Part I survey 

instructions that boiler information is not sought in the PI Permit limits tab. 
12

6.0 SSM Data

Comment: Members of commenter 0021’s organization understand the need for the 

Agency to collect startup, shutdown and malfunction (SSM) data in order to develop work 

practice requirements where numerical limits are not an option. However, the commenter noted 

that much of the data that are requested are not measured or available to the industry or its 

individual facilities (i.e., facilities do not conduct performance tests during periods of SSM; 

facilities only keep track of the number of minutes for each SSM period). The commenter 

recommended that the Agency form an SSM Workgroup to continue the work from the past 2

years on SSM. The commenter indicated that industry can share what procedures are in place to 

minimize emissions and what sources are covered by SSM Plans. The commenter would like to 

have representatives from its members serve on the Workgroup. For this reason, the commenter 

recommended that all SSM questions be noted as “Optional” in the survey and that an SSM 

Workgroup be convened to address these issues.

Response: We intend to work with pulp and paper industry representatives as part of a 

workgroup focused on startup/shutdown issues. We believe such a workgroup will be valuable. 

We are not collecting information on malfunction events. Due to the nature of malfunction 

events (unpredictable variability) our proposal is likely to be based on policies outlined in 

previous RTR proposals and further data collection will not be necessary. 
13

7.0 Request for Webinar

Comment: Commenter 0021 encouraged EPA to host a webinar for facilities in the 

industry to understand the goal of the survey and identify key instructions to complete the 

survey. The commenter recommended that this webinar take place as soon as possible, as sites 

only have 30 days to respond to Part I of the survey under the proposed schedule. The 

commenter noted that EPA has said it will take approximately 2 weeks to issue the surveys after 

OMB approval. If at all possible, the commenter recommended that the Agency post blank 

electronic versions of the survey and instructions on-line and conduct the webinar during this 

time and prior to facilities receiving surveys, to help expedite the process.

Response: EPA intends to host a timely webinar to discuss the pulp and paper survey. 

Plans for this webinar are under development.
14

8.0 Technical Comments

8.1 Survey Instructions

8.1.1 Overall Survey Instructions

Comment: The industry wants to assist the agency by providing the best information 

available. It is noted in many cases, the industry does not collect the data requested and facilities 

will have engineering estimates in lieu of real data or precise numbers that could provide 

valuable information to the agency for their analyses. It is the intent of the industry to provide 

reasonable good faith estimates to the agency. However, the industry does not want the agency to 

use this information for compliance assessments or confirmation of data submitted in regulatory 

reports. Therefore, the industry recommends the following language be inserted following Table 

1 in Section A of the instructions:

“Note that the information submitted by a facility is not intended for a compliance 

assessment. If actual data is not available, the facility should provide the best engineering 

estimates where appropriate.

In addition, it is not the intent of the EPA to use this data to confirm data/information 

submitted in the facility’s Toxic Release Inventory (TRI) or other regulatory required 

reports. It is understood that data submitted in this survey could vary due to the nature of 

the questions.3

”

AF&PA requests that these paragraphs also be added to the certification statement in 

Attachment 4.

Response: The language suggested has been added to the Part I, II, and III survey 

instruction documents and the certification form with the exception of the suggested footnote. 

EPA is interested in emissions reductions achieved by existing technologies regardless if the 

technologies were designed or installed for the purpose of achieving the reduction. 

Comment: In several parts of the survey, the agency requests capacity data. In 

discussions with the agency, it was determined that the best terminology would be to ask for 

“nominal daily throughput capacity.” The industry defines these values as typical operating rates 

for the emission unit and can be used by the agency to compare the relative size of the unit. It is 

recommended that each worksheet of the survey in Excel note in the header this definition: 

“Nominal Daily Throughput Capacity is defined as the typical operating rate for the emission 

unit.”

Response: We have added the requested terminology to the survey. In addition, we 

clarified in the survey instruction documents that mills may:

• Use the pulping line nominal capacity (throughput) for all equipment in the pulping line; 

 3 For example, a scrubber may not be designed for HCl control, but provides some incidental 

control that is noted in the TRI. This information would not be submitted in the Pulp and Paper 

Survey.
15

• Specify the nominal liquor solids or lime kiln throughput for equipment in the chemical 

recovery loop, and 

• Use the nominal paper throughput capacity for papermaking equipment.

We are not interested in maximum capacity values for each piece of equipment outside of the 

constraints of the pulping/papermaking/chemical recovery process within which it is located. 

8.1.2 Survey Instructions for Part I

Comment: The instructions should specifically note that state permit limits are only 

required if a state limit is more stringent that a federal limit. Suggested language is as follows:

State Limits: The facility only needs to include state permit limits that are more stringent 

than those limits in federal rules (e.g., PSD Avoidance or BACT limit). Any reference to 

limits for emissions that are not based on a federally enforceable statute (e.g.., based on 

state only required modeling) should not be included. The facility may also opt to send a 

pdf copy of their permit with the survey.

Response: We have revised the permit limits sections of the Part I and III survey 

instruction documents, but with language different than suggested by the commenter. EPA is 

interested in State permit limits that are more stringent than existing Federal limits, as well as 

certain State limits that may apply for some federally-unregulated emission units. The proposed 

survey instructions already provided that “Mass emission rate limits (lb/hr or tpy) are not being 

requested unless this is the only way in which limits are specified in the permit.” We expanded 

on this proposed language as follows:

State Mass-based Limits: Mass emission rate limits (lb/hr or tpy), or limits based on 

state-only required modeling, are not being requested unless this is the only way in which 

limits are specified in the permit. The EPA is most interested in state permit limits that 

are more stringent than those limits in federal rules (e.g., PSD Avoidance or BACT 

limits).

 * *

Alternative to submit permit copy: The facility may also opt to send a pdf copy of their 

permit with the survey. While we would prefer to receive data in the PIII Permit limits

tab, we will accept a copy of your operating permit (e.g., title V operating permit) instead 

of the completed PIII Permit limits tab. Other complete and up-to-date summaries of 

permit limits, such as a mill-specific summary of permit limits or compliance matrix, 

would be acceptable as well. 

Comment: For Part I of the survey, the facility needs only submit information as it 

relates to Subpart S. Therefore, any Performance Test or CEMS data need only be submitted 

with Part I for units that control sources for Subpart S. All other Performance Test and CEMS 
16

data for either Subpart MM or NSPS need to be submitted with Part III of the survey due in 180 

days.

Response: We have added a footnote to Table 1 in the Survey Overview Document to 

indicate that mills required to complete Part III may postpone submittal of the PM, TRS, NOx, 

SO2, and CO emissions test data and/or CEMS data required under Part I until the deadline for 

submittal of their Part III response. We added a corresponding statement to Section D3 of the 

Part I instruction document. Finally, for tracking purposes, we added a “yes/no” box to the PI 

Emissions test data tab to ask if the respondent is deferring until Part III submittal of any of the 

test data required in Part I.

For logistical reasons, mills that are required to complete Part I (but not Part III) must 

submit all of the emissions test data and CEMS data required under Part I by the Part I deadline. 

These mills typically have fewer emission units to report than mills required to complete all parts 

of the survey.

8.1.2 Survey Instructions for Part II

Comment: AF&PA recommends the following changes in the instruction document: 

• Attachment 1: Delete Pulp dryers from Pulp Washing, Thickening, and Storage 

Equipment as they are list in the Papermaking group.

• Attachment 1: Add Activated Sludge Basins to the Wastewater Treatment System 

Units

• Attachment 1: Thermal Oxidizers should be listed as 1626-2 rather than 1626-3.

• Attachment 2: Add NCASI Technical Bulletin No. 973 as a reference.

Response: All of the above changes were incorporated. Some additional stream-lining 

changes were made to Part II as well:

• In Part II Attachment 1, we moved the salt cake mix tank to the chemical recovery 

combustion unit equipment grouping because the salt cake mix tank accepts 

material from the recovery furnace ESP. Conforming edits were made to the 

Lookups for P&P survey.xls P&P Att 1 with SCC tab and the Attachment 1’s for 

the Part I and III survey instructions. Salt cake mix tanks will now be reported 

under Part III (with only the equipment identification and control information 

required in the PIII Equip detail tab of Part III) instead of under Part I. 

• The requirement to review/revise the “Emission Process Group” column of the 

NEI update was eliminated from all portions of Part II (Inventory and New 

Inventory tabs, and Lookups for P&P survey.xls P&P Att 1 with SCC and All 

11575 SCC tabs). EPA can run a data base query to assign descriptive Emission 

Process Groups based on SCC following receipt of the survey data.

• The instructions were revised to indicate that synthetic area sources are not 

required to complete Part II of the pulp and paper survey.
17

8.2 Excel Survey

8.2.1 Overall Excel Survey

Comment: It is recommended that each line of data have a “Comments” column to 

allow a facility to comment on the data supplied.

Response: A “comments” column was added to the end of each Part I and III 

spreadsheet tab.

Comment: Throughout the survey the EPA should standardize throughput data to be 

“nominal daily production capacity.” This terminology is standard to the industry and will 

provide a better standard to compare facilities.

• Part I of the Survey

o “Mill” worksheet column AS (pulp), AW, AX & AY (paper/paperboard),

o “PI Equipment Detail” worksheet column AQ (digester), AS (washing 

system), AX (knotter, screen, or decker), AZ (evaporator), BC (oxygen 

delignification), BI- BL (stripper parameters), BW (liquor pond 

throughput) BX (causticizing equipment),

o “Pulp prod” worksheet column E (pulp)

o “Bleaching” worksheet column I

• Part III of the Survey

o “PIII Equipment detail” worksheet column AY (black liquor solids), BL 

(spent liquor solids), BQ (smelt or ash production rate), BV (lime)

Response: We have revised the terminology as requested and added related instructions 

to the Part I and III survey instruction documents. We noted in the instruction documents that

“nominal daily throughput capacity” represents typical operating rates for the process or 

emission unit and can be used by the agency to compare the relative size of the unit. 

Respondents may use the pulping line nominal capacity (throughput) for all equipment in the 

pulping line. Respondents may specify the nominal liquor solids or lime kiln throughput for 

equipment in the chemical recovery loop. Likewise, for papermaking equipment respondents

may use the nominal paper throughput capacity. 

The EPA is interested in capacity values that would be used for estimating emissions. 

Mills may wish to use target capacity values used in their permit application. This is acceptable 

assuming the permit application values remain representative (or are adjusted to be 

representative) of operations in 2009.

We are not interested in maximum capacity values for each piece of equipment outside of 

the constraints of the pulping/papermaking/chemical recovery process within which it is located. 

For example, a mill may be able to push 3000 ADTP/day through Unit 1, but this is constrained 

to 500 ADTP/day by other equipment in the process line. We are only interested in the 500 

ADTP/day value. 

We expect respondents to use their judgment to provide the most readily available 

information indicative of the magnitude of production with reasonable specificity (e.g., 1100 

ADTP/day, not 1123.45 ADTP/day). This information will be used for estimating emissions and 
18

understanding the relative magnitude of production and how it varies from mill-to-mill across the 

nation. For example, EPA can determine the relative magnitude of emissions from certain types 

of pulping systems across the nation if the range of nominal production capacity is known across 

mills nationwide. 

Comment: AF&PA members understand the need for the agency to collect Startup,

Shutdown and Malfunction (SSM) data in order to develop work practice requirements where 

numerical limits are not an option. As noted in a previous comment, it is recommended that all 

SSM questions be noted as “Optional” in the survey and a SSM Workgroup be convened to 

address these issues.

• Part I

o “PI Equipment Detail” worksheet columns DN – DT

o “PI Controls” worksheet columns BG – BQ

• Part III

o “PIII Equipment Detail” worksheet columns DO – DU

Response: The information requested would aid in our understanding of startup and 

shutdown conditions and the mill-specific nature of these events. It is worthwhile for EPA to 

know definitively whether the requested startup/shutdown information is available or not. 

Where available, the information would be useful in evaluating work practices that could apply 

during startup and shutdown. Where unavailable, mills have the option of entering “UK” for

unknown in these columns. If we make the columns optional, as requested by the commenter, 

then we will not know whether the startup/shutdown information is unknown or simply not 

provided. Therefore, we are not labeling these columns as optional. Even if only a few mills 

provide this information, it will still be valuable to our understanding of the startup/shutdown 

mechanics associated with pulp and paper processes. 

Comment: For single emission units with multiple release points, the instructions need 

to clarify how to input data for cases such as:

• Uncontrolled brown stock washers, oxygen delignification systems, paper 

machines, and wastewater treatment plants will have multiple release points. Is it 

necessary to list all vents or release points on these systems?

• Other systems may be partially controlled, e.g. bleach plants may not send all 

hood vents, seal tank vents, and vacuum pump exhausts to a scrubber. The 

situation would be the same for a tall oil system (i.e., the reactor may have 

scrubber but the storage and settling tanks are not controlled). The instructions 

need to clarify how to input this information.

• How should liquor storage tanks, pulp storage tanks, and causticizing system 

equipment be handled?

Response: The instructions for single emission units with multiple release points have 

been revised in both the Part I and Part III instruction documents. The commenter’s specific 

questions apply for Part I equipment. If the different release points (vents or stacks) have 

different controls or different NSPS/NESHAP applicability then respondents will need to list 

each vent (or group of vents with the same controls) on separate rows. Otherwise, respondents 
19

may group multiple vents together. Additional examples were included in the Part I instructions 

to cover instances where:

• Different release points (vents or stacks) are uncontrolled, have the same control, and 

have the same NSPS/NESHAP applicability; and

• An emission unit has some groups of release points (vents or stacks) that are controlled 

and some that are uncontrolled (or if NSPS/NESHAP applicability varies for different 

groups of release points).

8.2.2 Part I of the Survey (Excel File)

8.2.2.1 Mill (Part I)

Comment: It is recommended that the question in column AU be deleted: “Is natural gas 

supply currently available to the mill (e.g., truck delivery or pipeline)?” The availability of 

natural gas is dependent upon many factors and the availability of a natural gas supply does not 

necessarily mean the system could support a fuel conversion at the plant. If the facility currently 

burns natural gas, this information will be provided via other questions in the survey.

Response: The column was deleted.

Comment: Columns BA through BO request the capacity of the facility to produce 

several paper grades. However, this approach could lead to the total production by grade to be 

higher than the total capacity of the facility. (For example, a facility could probably produce the 

same amount of uncoated free sheet as coated free sheet.) In addition, this is very sensitive 

information that would be confidential business information (CBI). Therefore, it is recommended 

that the facility simply indicate if the facility can produce certain paper grades rather than the 

actual production values.

Response: The request for capacity by paper grade was replaced with a question asking 

mills to select from menu the paper grades produced.

8.2.2.2 Equipment Detail (Part I)

Comment: In Part I of the survey, the facility should not include either chemical 

recovery combustion sources (covered by Part III of the survey) or power boilers (covered by 

Industrial Boiler MACT). However, if these sources are used for the control of gases covered by 

40 CFR 63 Subpart S, these units should be listed as control devices. This should be clarified in 

both the instructions and excel survey files.

Response: Reference to chemical recovery combustion sources was eliminated. 

However, reference to boilers is being retained in the survey. As explained above, mills are now 

given the option to complete the questions in PI Equip detail relevant to boilers or to supply their 

Boiler MACT ID numbers. Reference to boilers was retained in the instructions for selected 
20

questions for those mills that do not supply Boiler MACT IDs (e.g., mills that did not complete 

the Boiler MACT survey; or mills making changes to boilers such that the Boiler MACT survey 

data are no longer accurate).

Comment: Columns L-N ask for emission exhaust data. The EPA should clarify if this 

information is requested before or after the control device. If exhaust streams are combined for 

more than one source, how should this information be entered into the spreadsheet?

If exhaust from a unit is split into two streams that go to different control devices, what 

flow rate should be reported in Column L?

Response: A column was added for respondents to indicate whether the flow rate 

provided is at the: inlet to collection system, collection system outlet prior to control device,

inlet to control device, control device outlet, or prior to atmospheric release. We did not wish to 

limit the location from where flow rate data are reported because we recognize that flow rate 

measurements are infrequent. Either inlet or outlet data will serve our purposes, and the column 

added will indicate where the data were measured. While we prefer actual measurements (e.g., 

from stack tests), estimated flow rates are acceptable. Respondents not having flow rate data for 

a particular emission unit may enter unknown. It is not necessary to estimate flow rates from 

every emission unit ducted to an LVHC or HVLC system. We recognize that in many cases such 

flow rates have not been measured and are unknown. Nevertheless, we are interested in flow 

rate data from any mills that might have this information. 

Respondents should follow the instructions for “single emission unit with multiple 

release points” for emission units that vent through multiple control devices. The emission unit 

would be reported on two separate rows on the PI Equip detail spreadsheet as indicated in the 

example provided in the instructions.

Comment: The reference to boilers should be removed from column P.

Response: Reference to boilers in this column was retained in this question asking about 

combustion modifications. As explained above, mills are now given the option to complete the 

questions in PI Equip detail relevant to boilers or to supply their Boiler MACT ID numbers. 

Reference to boilers was retained in the instructions for selected questions for those mills that do 

not supply Boiler MACT IDs (e.g., mills that did not complete the Boiler MACT survey; or mills 

making changes to boilers such that the Boiler MACT survey data are no longer accurate).

Comment: For the information requested in Columns R – T, any reported percentages 

will be difficult to interpret unless they are based on long term CEMS data both before and after 

the modifications were made. Short term tests before and after do not provide a meaningful 

assessment of the performance. If these 3 questions are retained, EPA should ask for the basis of 

the reported percent reduction.
21

Response: The instruction row was reworded as follows, “Enter percent reduction (if 

known) and indicate the basis for the value provided (e.g., CEMS data, before-and-after testing, 

design value).”

Comment: For batch digester systems, each equipment source should be listed as in the 

NEI. If several digesters are included in one source, the survey requests production information 

for that source and not each individual digester unit. It is recommended that cell AP6 be 

amended as follows: “Complete for each digester source. This could include multiple emission 

units that are part of one emission source.”

Response: We added the commenter’s suggested language with a reference to the Part I 

survey instructions for "Multiple emission units ducted to a single release point.” We provided 

the following exception in the instructions for "Multiple emission units ducted to a single release 

point:”

Exception: If the multiple emission units ducted to a single release point are numerous and identical in 

design/operation (for example – 20 batch digesters all ducted to LVHC control and processing softwood), 

then you may lump the emission units together on one row and note their total capacity. Note how many 

emission units are lumped together in the “Emission unit description” column (e.g., digester (20 units)) 

Comment: EPA also requests information for process tanks. Some tanks can be used for 

different materials. Therefore, EPA should request in Column BP for the typical tank contents as 

one tank could hold a variety of products.

Response: “Typical” tanks contents are now requested.

Comment: EPA has received detailed information on boilers in the Boiler MACT ICR. 

The questions of importance for this ICR include the type of control device for NCGs, if a backup control device is available, and the number of main vent minutes due to control device 

downtime. All other information is not applicable to this ICR and AF&PA recommends that 

these questions be removed (columns CB, CE – DM). Emissions from these units will be 

submitted in the NEI section (Part II) of the survey.

Response: We are retaining these questions for boilers and other fuel-fired equipment, 

but have made them optional for mills that supply their Boiler MACT ID numbers in PI Equip 

detail. Fuel types and MMBtu/hr heat input capacity are a key component of emissions 

calculations for fuel-fired equipment. Column CB of the proposed survey requests design heat

input capacity (MMBtu//hr) for fuel-fired equipment. Columns CE through DM of the proposed 

survey request details on: 

• Primary fuels for fuel-fired equipment (except black or red liquor), and 

• Supplemental or other fuels for fuel-fired equipment 

For primary fuels, the fuel type and approximate percentage of annual heat input capacity for the 

fuel are requested, along with optional questions for heating value and biomass moisture 

percentage. For supplemental fuels, the fuel type, approximate percentage of annual heat input 
22

capacity, and conditions when the supplemental fuel are used are requested, along with an 

optional question for fuel heating value. 

Emissions from boilers will be submitted with the NEI, but basic process details such as 

MMBtu/hr heat input capacity and primary/supplemental fuel types are not part of the NEI 

inventory data request. If Boiler MACT IDs are provided, EPA can consult the Boiler MACT 

data base for information on fuel types and amounts fired. Otherwise, respondents are asked to 

supply the fuel-firing information for boilers in the PI Equip detail tab. 

Comment: Please note if the following data should be the average from 2009 or target 

values:

• Column AW: Vacuum drum shower water methanol concentration

• Column BE: Oxygen delignification shower water methanol concentration

• Column BN: Methanol removal efficiency

• Column BO: TRS removal efficiency

• Column BW: Liquor pond throughput

Response: “Use the average from 2009 or target value,” was added to the instruction 

row for these columns. Respondents should use their discretion and provide the most readily 

available value.

 

8.2.2.3 Controls (Part I)

Comment: Please note if the following data should be the average from 2009 or target 

values:

• Column W: Sorbent injection rate (lb/hr)

• Column AH: Water flow through the WESP (gpm)

• Columns AJ – AL: Scrubber rates

• Columns AS-AT: Water source data

• Columns AX and BB: Solid waste material generation

Response: “Use the average from 2009 or a target value,” was added to the instruction 

row for these columns. Respondents should use their discretion and provide the most readily 

available value.

8.2.2.4 Byproducts

Comment: For columns C, D, F, K and L, is the turpentine production data requested 

based on 2009 actual data or nominal daily production capacity?

Response: As noted in previous public comments on the survey, turpentine production 

can fluctuate seasonally so an annual average is more meaningful. We inserted the words “based 

on nominal production capacity” into the instruction row for columns C, D, F, K and L. Again, 

we expect respondents to use their judgment and supply to most readily available estimate of 
23

byproduct production. We are interested in understanding the relative magnitude of byproduct 

production from mill to mill (e.g., 5000 gallons vs. 5 million gallons).

 

8.2.2.5 Kraft Condensates

Comment: Additional options need to be added to the survey and/or instructions for the 

following situations:

• It should be noted that some mills implemented an “Equivalency by Permit” project for 

compliance with Subpart S. For this reason, the facility may not collect a specific named 

stream and would have implemented an “equivalent” project. If this is the case, the 

instructions should note that the named stream would be input into Column C and an 

explanation of the treatment option would be described in Column R.

• Another control option listed in 40 CFR §63.446(c)(1), is for the facility to collect all 

named streams. This should be added to the instructions table and as an option in the 

survey spreadsheet in Column F.

• In complying with the collection and treatment requirements, a facility will look at total 

condensate loads, not loads from individual digesters or evaporator lines. Furthermore, 

there are multiple condensate streams from digesters and evaporators, and usually only a 

portion of the total is collected for treatment. Therefore, a simply “Yes” or “No” to the 

question in Column E is not appropriate. (Is condensate stream collected and treated 

according to Subpart S.” It is recommended that the survey and instructions direct 

facilities to indicate “Yes” to this question if all or a portion of the stream is collected 

The facility would then include comments in the “Comments” column EPA will add to 

each worksheet.

Response: We have revamped the Kraft condensates tab to account for the above 

comments. We replaced the blank rows for each named condensate-producing emission unit 

with pull down menus in column C where respondents can select: 

• The source of each "named" kraft condensate stream (digester, turpentine recovery, 

evaporator, HVLC, or LVHC systems),

• “Combined systems" to describe combined condensate streams from multiple "named" 

sources (e.g., combined digester and evaporator condensates), or 

• "Other systems" to describe condensate streams that are un-named (i.e., not listed in 

§63.446(b)) but are controlled to meet subpart S as part of an innovative or equivalencyby-permit project.

In column F, we added equivalency-by-permit as a pull-down menu option. We also revised the 

menu choices in column E to account for the possibility of partial collection and control. 

8.2.2.6 Clean Condensate Alternative (CCA)

Comment: The instructions should note that wastewater treatment is another CCA 

eligible source. In addition, “Equivalency by Permit” facilities may have other credit generating 

sources.
24

Response: The spreadsheet was revised to state, “Sources eligible for inclusion in the 

CCA as credit generators include (but are not limited to): pulping systems, bleaching systems, 

causticizing systems, papermaking systems, and wastewater treatment systems.” Corresponding 

edits were made to the Part I instruction document.

In addition, the column entitled “Emission reductions expected through compliance with 

the kraft pulping system standards (kg total HAP/Mg ODP)” was removed to address comments 

included in the spreadsheet.

 

8.2.2.7 Bleaching

Comment: Is column H asking for 2009 data or nominal production capacity?

Response: The column was revised to request “2009 nominal daily bleached production 

capacity, ADTBP/d.”

8.2.2.8 HAP Additives

Comment: Column E should be clarified to ask for 2009 actual data.

Response: The column was revised to ask for “Amount of additive used in 2009.”

8.2.2.9 Wastewater

Comment: The survey asks for the capacity of the WWTP in MMgal/day. AF&PA 

recommends that this be changed to ask for the average daily throughput in 2009 as these 

systems are large and the “capacity” is dependent upon the load and retention time.

Response: As requested, the column heading was changed to “WWTP throughput, 

MMgal/day.” Respondents are now instructed to enter the 2009 average daily throughput of the 

wastewater treatment plant (million gallons per day).

Comment: Columns J – P request the percent volume of condensate from specific 

processes relative to the overall wastewater flow. In many cases, the facility will not have this 

information. If the facility treats condensates via the hard pipe option, the facility will have data 

on the total volume of condensates relative to the entire wastewater flow. For those facilities that 

do not have a hard pipe or for other systems, the data may not be available. Most facilities will 

not have an estimate for stormwater contribution.

Response: Reference to stormwater was removed. “If known” was added to each 

column heading. Instructions were added to the instruction document to clarify that mills may 

respond “UK” if the volume percentages are unknown.
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In addition to the changes above, three columns were added to the survey spreadsheet to 

address outsourced wastewater treatment. These questions ask if a mill outsources wastewater 

treatment to a publicly owned treatment works (POTW) or other separate entity such as a 

privately held entity that may be owned and operated by the same company or a different 

company. The questions clarify that only mills performing onsite wastewater treatment beyond 

operation of a clarifier for suspended solids removal are required to complete the remainder of 

the WW tab.

8.2.3 Part II of the Survey (Excel File)

Comment: In terms of the release angle, the instructions need to note that this angle is 

relative to the width of the source (Columns BA and BI).

Response: The following comment was added to the columns in P&P NEI update.xls

and P&P NEI blank.xls: “Note that the fugitive angle is relative to the width of the emission unit. 

See instructions for details.”

8.2.4 Part III of the Survey (Excel File)

8.2.4.1 Equipment Details (Part III)

Comment: Columns M-O ask for emission exhaust data. The EPA should clarify if this 

information is requested before or after the control device. If exhaust streams are combined for 

more than one source, how should this information be entered into the spreadsheet?

If exhaust from a unit is split into two streams that go to different control devices, what 

flow rate should be reported in Column M?

Response: A column was added for respondents to indicate whether the flow rate 

provided is at the: inlet to collection system, collection system outlet prior to control device, 

inlet to control device, control device outlet, or prior to atmospheric release. We did not wish to 

limit the location from where flow rate data are reported because we recognize that flow rate 

measurements are infrequent. Either inlet or outlet data will serve our purposes, and the column 

added will indicate where the data were measured. While we prefer actual measurements (e.g., 

from stack tests), estimated flow rates are acceptable. Respondents not having flow rate data for 

a particular emission unit may enter unknown.

Respondents should follow the instructions for “single emission unit with multiple 

release points” for emission units that vent through multiple control devices. The emission unit 

would be reported on two separate rows on the Equip detail spreadsheet as indicated in the 

example provided in the instructions.

Comment: The reference to boilers should be removed from column Q.

Response: The reference to boilers was removed.
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Comment: For the information requested in Columns S – U, any reported percentages 

will be difficult to interpret unless they are based on long term CEMS data both before and after 

the modifications were made. Short term tests before and after do not provide a meaningful 

assessment of the performance. If these 3 questions are retained, EPA should ask for the basis of 

the reported percent reduction.

Response: The instruction row was reworded as follows, “Enter percent reduction (if 

known) and indicate the basis for the value provided (e.g., CEMS data, before-and-after testing, 

design value).”

Comment: For sources covered by Part III, process equipment will not be used for

controls. It is suggested that these references be removed for Columns Y, AA, and AC.

Response: The references were removed.

Comment: The following references are not required for Part III of the survey: 

o Cell AE6 – Parenthetical expression

o Cell AG15 – collects emissions from BB emission units

o Cells AI11 – AI16 – these options are not related to Part III sources

o Column AI – add 0.0168 lb/ton BLS as some sources still have the old 

NSPS limit on their smelt tank (changed in 1986 to 0.033 lb/ton BLS).

o Remove column AJ as a back-up device is not relevant to Part III sources.

Response: All of these corrections were made. 

Comment: Please note if the following data should be the average or target values: 

o Column AS: Liquor flow rate

o Column AT: Liquor solids content

o Columns AZ – BD: Black liquor solids characteristics

o Column BM: Spent liquor solids HHV

o Column BS – BT: Black liquor content

o Columns BW – BY: Lime Mud and Kiln characteristics

Response: “Use the average from 2009 or target value,” was added to the instruction row 

for these columns. Respondents should use their discretion and provide the most readily 

available value.

Comment: Column CG, CL, CQ, CV, DA, DF, DK: Should the breakdown of fuel usage 

as % of total input be based on 2009 actual data or target fuel use?
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Response: These columns request the approximate percent of annual heat input capacity 

(MMBtu/yr) supplied by each primary and supplemental fuel. The spreadsheet instructions for 

these columns already indicated that, “Approximations will suffice.” These instructions were 

expanded to state, “Approximations based on the average from 2009 or a target value will 

suffice.” Corresponding changes were made to these same columns in the Part I spreadsheet. 

Respondents should use their discretion and provide the most readily available value.

Comment: Part III is for Subpart MM sources and therefore fuel-fired equipment should 

be limited to recovery furnaces, semi-chemical combustors, and lime kilns. Any references to 

other equipment should be deleted.

Response: The spreadsheet instructions have been revised to clarify that recovery

furnaces, semi-chemical combustors, and lime kilns are the focus of the questions pertaining to 

fuel-fired equipment, primary fuels, and supplemental fuels under Part III. These types of 

emission units are used as examples of fuel-fired units in the instructions so no uncommon or 

unconventional types of chemical recovery combustion sources will be excluded.

Total heat input capacity (MMBtu/hr) for all fuels including spent pulping liquor is 

requested in the “fuel-fired equipment” column. The primary fuel questions apply for lime kilns, 

but do not apply for spent pulping liquors since there are separate questions in Part III Equip 

detail asking for spent pulping liquor capacity. The supplemental fuel columns are to be 

completed for recovery furnaces, semi-chemical liquor combustors, and lime kilns. 

Thermal oxidizers (e.g., regenerative thermal oxidizers) may be used to control semichemical combustion units. Thermal oxidizers controlling Part III emission sources are not to be 

included as emission units in the Part III Equip detail tab, but will be identified as controls and 

included in the Part III Controls tab. Questions pertaining to fuel use by thermal oxidizers 

treating chemical recovery combustion source emissions were moved to Part III Controls. (Note 

that treatment of thermal oxidizers under Part III is different than under Part I where thermal 

oxidizers are to be listed as both and emission source in PI Equip detail and as a control device 

in PI Controls. This is because Part I thermal oxidizers sometimes have a pollution control 

device for SO2 generated from burning pulp mill vent gas TRS emissions.) 

8.2.4.2 Permit Limits (Part III)

Comment: AF&PA recommends adding sulfuric acid mist and replacing chlorine and 

chlorinated HAP with HCl in Column E (Pollutant list).

Response: These changes were made for the PIII Permit Limits tab.

Comment: For the responses in Column F, EPA should remove Subpart S, Subpart Db, 

and Dc. It should be noted that Subpart BB has two possible TRS emission limits for smelt 

dissolving tanks.
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Response: These changes were made in the PIII Permit Limits tab. We added pull-down 

menu options for the different NSPS subpart BB years (associated with different applicable 

emissions limits).

8.2.4.3 Controls (Part III)

Comment: As Part III sources do not have back-up controls, the instruction in Column 

D should be eliminated. In addition, the following survey requests require clarification: 

o Column W: Sorbent injection rate (lb/hr)

o Column AH: Water flow through the WESP (gpm)

o Columns AJ – AL: Scrubber rates

o Columns AS-AT: Water source data

o Columns AX and BB: Solid waste material generation

Response: Reference to backup controls was removed. “Use the average from 2009 or a 

target value,” was added to the instruction row for these columns. Respondents should use their 

discretion and provide the most readily available value.

Comment: This part of the survey requests data on thermal oxidizers and incinerators 

(column O – T). This information is requested in Part I of the survey and should be eliminated in 

Part III.

Response: These questions were not eliminated because thermal oxidizers may be used 

to control emissions from semi-chemical combustion units. Instead, questions pertaining to fuel 

use by thermal oxidizers treating chemical recovery combustion source emissions were moved 

from PIII Equip detail to Part III Controls so Part III thermal oxidizers are treated as control 

devices only (and need not be listed as a separate emissions source in PIII Equip detail.) 

8.2.4.1 Precipitated Calcium Carbonate (PCC)

Comment: Please clarify if the answers to Columns F and G are based on 2009 data or 

target data.

Response: “Use the average from 2009 or a target value,” was added to the instruction 

row for these columns. Respondents should use their discretion and provide the most readily 

available value.