Date: March 22, 2013

Subject: Review of Pulp and Paper Information Collection Request (ICR) 

Responses Pertaining to Startup and Shutdown of Subpart BB

Equipment

EPA Contract No. EP-D-11-084; Work Assignment No. 1-08

From: Katie Hanks

Corey Gooden

To: Kelley Spence

Bill Schrock

U.S. Environmental Protection Agency (EPA)

Research Triangle Park, NC 27711

I. Introduction

The new source performance standards (NSPS) for kraft pulp mills (40 CFR part 60, 

subpart BB) were promulgated in 1978, last reviewed in 1986, and are due for review under Clean 

Air Act (CAA) section 111(b)(1)(B). As part of the NSPS review, EPA intends to evaluate the 

startup, shutdown, and malfunction (SSM) provisions in the rule in light of the D.C. Circuit Court 

of Appeals decision in Sierra Club v. EPA, 551 F.3d 1019 (D.C. Cir. 2008). In the Sierra Club

case, the D.C. Circuit vacated the SSM exemption provisions in the 40 CFR part 63 General 

Provisions for non-opacity and opacity standards, and held that the SSM exemption in the General 

Provisions in 40 CFR part 63 violated the CAA’s requirement that some standard apply 

continuously. To the extent that SSM provisions similar to the vacated provisions in 40 CFR part 

63 General Provisions appear in the part 60 General Provisions for the subpart BB NSPS, a goal of 

the current NSPS review is to address whether the NSPS can apply at all times, including periods 

of startup and shutdown, or whether there is a need for separate standards during startup and 

shutdown. The purpose of this memorandum is to present and summarize information collection 

request (ICR) data relating to startup and shutdown of subpart BB equipment. This memorandum 

does not address malfunctions, which would be addressed through affirmative defense provisions.

The revised kraft mill NSPS will be codified in a new subpart BBa and would apply for 

new, modified, and reconstructed emission units following the date of proposal (anticipated in 

May 2013). The emission units subject to the current subpart BB and revised subpart BBa NSPS 

include recovery furnaces, smelt dissolving tanks (SDTs), lime kilns, and sources of noncondensable gases (NCGs), including digester, evaporator, brown stock washer, and condensate 

stripper systems. Recovery furnaces, SDTs, and lime kilns are subject to the 40 CFR part 63 

national emissions standards for hazardous air pollutants (NESHAP) for chemical recovery 

combustion sources (40 CFR part 63, subpart MM), and NCG systems are subject to the pulp and

paper manufacturing NESHAP (40 CFR part 63, subpart S). This memorandum focuses primarily

on the chemical recovery combustion sources subject to the NSPS (recovery furnaces, SDTs, and
2

lime kilns) and their air pollution control devices (APCDs)—electrostatic precipitators (ESPs) 

and wet scrubbers. The startup and shutdown of incineration devices used to control NCG 

emission sources are discussed briefly in this memorandum, and were discussed in greater detail 

in a separate memorandum developed for the subpart S residual risk and technology review. 

(RTI 2012)

II. Information Collection Request Startup and Shutdown Questions

The EPA sent out a three-part ICR (survey) in February 2011 that requested information 

needed to perform various regulatory reviews, including the subpart BB NSPS review. Part III of 

the ICR contained questions pertaining to startup and shutdown for the chemical recovery 

combustion sources covered under subpart BB and their control devices. These questions 

appeared in the PIII Equip detail and PIII Controls tabs of the spreadsheet-based survey. The 

startup and shutdown questions were designed to provide EPA with an understanding of the 

duration, emissions potential, work practices, and control mechanisms of startup and shutdown 

events for the variety of equipment used at pulp and paper mills. Appendix A presents the 

specific Part III survey spreadsheet questions.

1 The corresponding Part III survey instructions 

were as follows:

Emission unit startup and shutdown. Complete the startup and shutdown questions for all emission units 

currently subject to Federal or State emission limits or monitoring requirements. Questions pertaining to 

emission unit startup and shutdown are asked in order to provide EPA with an understanding of the 

duration, emissions potential, work practices, and control mechanisms of startup and shutdown events for 

the wide variety of equipment used at pulp and paper mills. The EPA is considering standards that could 

apply during startup and shutdown events (or whether the current standards developed for normal operation 

should apply) in light of the December 2008 vacatur of the NESHAP startup, shutdown, and malfunction 

exemption in 40 CFR Part 63, subpart A. The startup and shutdown questions would also identify pulp and 

paper emission unit types for which startup and shutdown are not already addressed with the current 

emission standards. You are asked to supply information for routine startup and shutdown events associated 

with planned process or mill downtime. (Do not provide information for unplanned startup/shutdown 

events associated with equipment malfunctions.) The startup and shutdown data in the PIII Equip detail tab 

are being sought for regulatory development purposes and will not be used for enforcement purposes. 

Control device startup and shutdown. The EPA is considering standards that could apply during startup and 

shutdown events (or whether the current standards developed for normal operation should apply) in light of 

the December 2008 vacatur of the NESHAP startup, shutdown, and malfunction exemption in 40 CFR Part 

63 subpart A. Questions pertaining to control device startup and shutdown are asked in order to provide 

EPA with an understanding of the duration and definition of startup and shutdown events for the types of 

control devices used at pulp and paper mills. The EPA is seeking information on the integral nature of 

startup and shutdown events for the different combinations of emission units and control devices used in 

the pulp and paper industry. In addition, because Federal NSPS and NESHAP require continuous 

monitoring of emissions or control device operating parameters, information is requested to inform EPA of 

particular pulp and paper NSPS or NESHAP control device parameter limits that cannot feasibly be met 

during startup and shutdown events. Certain parameters may be "instant on" while others are more transient 

in nature (i.e., changing as startup or shutdown progresses). Examples could include control device 

temperature that must heat up to a set point, or pressure drop that cannot be achieved due to low exhaust 

gas flow from the emission unit. The EPA will use this information to evaluate which existing control 

 1 Similar questions were included in Part I of the ICR for NCG sources and their control devices (e.g., incineration 

of NCG in a boiler, lime kiln, or recovery furnace or use of a thermal oxidizer). A separate memorandum developed 

for the subpart S residual risk and technology review promulgated in September 2012 discusses and documents the 

ICR responses related to startup and shutdown for NCG combustion sources and controls. (RTI 2012)
3

device parameter limits may remain in effect during startup and shutdown events, and which parameter 

limits may need to be replaced with another requirement during startup and shutdown. In all of the control 

device startup and shutdown questions, you are asked to supply information for routine startup and 

shutdown events associated with planned equipment or mill downtime. (Do not provide information for 

unplanned startup/shutdown events associated with equipment malfunctions.) The startup and shutdown 

data in the PIII Controls tab are being sought for regulatory development purposes, and will not be used for 

enforcement purposes. 

III. Background Information and ICR Data Relevant for the NSPS

The subpart BB NSPS contain emissions standards for particulate matter (PM) and total 

reduced sulfur (TRS). Subpart BB also contains an opacity limit for recovery furnaces.

Appendix B of this memorandum presents a matrix of the subpart BB standards, control systems, 

initial compliance demonstration methods (e.g., emissions testing methods) and continuous 

compliance demonstration methods (e.g., monitoring requirements). Collectively, these 

requirements dictate how compliance is demonstrated with subpart BB. 

Revisions to the subpart BB standards are under consideration for subpart BBa to reflect 

changes in the technology since the 1986 NSPS review, including:

• Inclusion of an opacity limit for lime kilns controlled with ESPs, 

• Addition of ESP parameter monitoring requirements for recovery furnaces and lime kilns 

equipped with ESPs (in addition to opacity monitoring), and

• Specification of parameter monitoring requirements for recovery furnaces or lime kilns 

equipped with an ESP followed by a wet scrubber.

The effects of startup and shutdown on continuous emissions monitoring systems 

(CEMS) data for TRS and continuous opacity monitoring system (COMS) data submitted with 

the ICR are discussed in a separate memorandum that presents an analysis of the CEMS and 

COMS data. (EPA 2013a) Most of the ICR responses summarized in this memorandum center 

around operating parameter monitoring as opposed to continuous emissions monitoring, though a 

few responses related to opacity are noted. 

The ICR data in the startup and shutdown columns of the PIII Equip detail and PIII 

Controls tabs were reviewed to determine measures used to reduce emissions during startup and 

shutdown, or if mills reported issues with not being able to maintain parameter limits during 

startup or shutdown. Appendices C1 and C2 present the data reviewed from the ICR. Appendix 

C1 contains startup and shutdown details from PIII Equip detail for recovery furnaces, SDTs, 

and lime kilns, organized by emission unit type with the control system type noted. Appendix C2 

contains startup and shutdown details from the PIII Controls table for the PM control devices for 

recovery furnaces, SDTs, and lime kilns. The information in Appendices C1 and C2 was 

reviewed to:

• Assess whether ICR information indicates mills may be in violation of a continuous 

compliance requirement should the standards that apply during normal operation also 

apply during periods of startup and shutdown. If not, then, 

• Identify appropriate alternative standards that could be applied during startup and 

shutdown. Development of separate emissions standards (separate numeric limits or work 
4

practices) for startup and shutdown of pulp and paper processing equipment would 

require consideration of emission unit and control device and the methods for 

demonstrating initial and continuous compliance.

A. Startup and Shutdown Duration for Recovery Furnaces, SDTs, and Lime Kilns

Tables 1 and 2 summarize the startup and shutdown times reported in the ICR responses. 

Table 1 contains emission unit startup and shutdown times from PIII Equip detail. Several 

respondents distinguished between cold startup and hot startup of emission units. The maximum 

time was used when a range of startup or shutdown times was provided (e.g., for cold vs. warm 

startup). Cold startup for recovery furnaces, lime kilns, and SDTs was described by some 

respondents as follows:

• The time elapsed from initial firing of fossil fuel until black liquor is introduced for 

recovery furnaces.

• The time elapsed from initial firing of fossil fuel until lime mud processing for lime kilns. 

Another 1 to 2.5 hours following introduction of lime mud is required for lime product to 

exit the kiln according to two respondents. Some respondents noted that they must follow 

the lime kiln manufacturer’s warm up curve during startup.

• Time elapsed after liquor is introduced and smelt is flowing into SDTs. One respondent 

noted that SDT startup is 1-2 hours following recovery furnace startup.

Similarly, several respondents described a controlled shutdown for a recovery furnace as the time 

elapsed from removing first liquor gun from service until furnace bed is burned out.

Table 2 contains control device startup and shutdown times from PIII Controls. Although 

the PIII Controls tab specifically requested APCD startup and shutdown times, some of the 

maximum times in Table 2 appear to be more closely related to emission unit startup and 

shutdown times than just the APCD startup and shutdown time. Also, some of the minimum 

times (e.g., zero hours for ESP systems) are questionable. Therefore, the averages in Table 2 are 

considered as more representative of APCD startup and shutdown times. Using the averages in 

Table 2, scrubbers appear to take about 1.5 hour to start up and 2 hours to shut down, while ESPs 

appear to require about 6.5 hours to start up and 3.5 hours to shut down.

Table 1. Duration of Emission Unit Startup and Shutdown (Hours)

DCE RF NDCE RF LK SDT

Startup Time

Min 2 2 0.50 0.10

Max 24 60 72 24

Average 9 11 24 7.2

Median 9 10 24 7

Shutdown Time

Min 0.5 0.5 0.03 0.08

Max 84 84 48 38

Average 11 10 12 6.5

Median 6 6 6 6

Source: See Appendix C1 for details.
5

Table 2. Duration of Control Device Startup and Shutdown (Hours)

Row Count Min Max Average

Startup Time

LK ESP 28 0 30 5.7

LK ESP/SCBR 18 0.16 30 4.8

LK SCBR 75 0 26 1.8

RF ESP 114 0.01 39 4.2

RF ESP/SCBR 6 0.08 10 2.1

RF SCBR 2 0.16 0.33 0.25

SDT OTH 3 0 6 2.3

SDT SCBR 101 0 10 1.4

Shutdown Time

LK ESP 27 0 24 3.2

LK ESP/SCBR 18 0.1 24 1.9

LK SCBR 74 0 24 1.3

RF ESP 114 0 39 2.5

RF ESP/SCBR 6 0.08 1 0.32

RF SCBR 2 0.16 0.33 0.25

SDT OTH 3 0 0.5 0.33

SDT SCBR 101 0 18 1.7

Source: See Appendix C2 for details.

LK = lime kiln, RF = recovery furnace, SDT = smelt dissolving tank, 

ESP = electrostatic precipitator, SCBR = wet scrubber, OTH = mist eliminator

B. Distinction Between Startup and Shutdown and Normal Operation for Recovery 

Furnaces, SDTs, and Lime Kilns

Responses to survey questions asking what marks the beginning and end of normal 

operations for emission units and control devices tended to be very site-specific in nature. This 

stands to reason because mills have defined startup and shutdown in consideration of their 

specific equipment and operational practices in their SSM plans formerly required under part 63 

NESHAP (prior to the Sierra Club decision). The most common responses to the ICR questions

of what marks the end of emission unit startup (beginning of normal operations), and the 

beginning of emission unit shutdown (end of normal operations) are generalized in Tables 3 and 

4 for recovery furnaces, SDTs, and lime kilns. 

Tables 5 and 6 summarize the responses to ICR questions pertaining to the end of control 

device startup and the beginning of control device shutdown. Control device startup and 

shutdown were frequently described by respondents in terms of when monitoring parameter 

limits are achieved. This suggests that scrubber and ESP parameter limits (e.g., ESP power, 

scrubber pressure drop) are not likely to be met instantaneously upon control device startup and 

may not be maintained throughout control device shutdown. 
6

Table 3. General Responses Defining the End of Emission Unit Startup

Emission unit 

type The end of startup is marked by...

DCE and NDCE 

recovery furnaces

-beginning of black liquor combustion

-beginning of black liquor combustion, and removal of auxiliary fuel

-when black liquor combustion reaches a site-specific stability target (e.g., 

liquor flow, steam production, steam pressure, stack oxygen, a stable 

furnace bed, and stable smelt flow)

SDTs -beginning of black liquor combustion in the recovery furnace

-smelt flow from the recovery furnace

-when scrubber parameters are met

-when green liquor of specific quality is pumped to recausticizing operation

Lime kilns -introduction of lime mud into the kiln (at the cold end)

-when lime mud flow into the kiln reaches a site-specific flow or tonnage 

target

-following a warm-up curve

-a period of 3-24 hours after lime mud is introduced in the kiln

-lime product flow out of kiln

-hot-end (flame-end) temperature, or cold-end (mud introduction end) 

temperature reaches a certain point

-when combustion of NCGs begins after reaching target temperature 

Source: See Appendix C1 for details.

Table 4. General Responses Defining the Beginning of Emission Unit Shutdown

Emission unit 

type The beginning of shutdown is marked by when the...

DCE and NDCE 

recovery furnaces

-black liquor firing ceases or is reduced

-black liquor firing rate is reduced with the intention of shutting down the 

furnace

-black liquor is removed, and auxiliary fuel is added to burn down the smelt 

bed

SDTs -black liquor firing ceases or is reduced

-black liquor firing rate is reduced with the intention of shutting down the 

furnace

-smelt flow from the recovery furnace into the SDT slows or ceases

Lime kilns -lime mud flow into the kiln ceases

-lime mud flow into the kiln ceases, and the kiln is purged of remaining 

lime 

-kiln fuel firing is reduced

-lime is no longer produced

-mud feed stops; the end of shutdown is when fuel firing is stopped

Source: See Appendix C1 for details.
7

Table 5. General Responses Defining the End of Control Device Startup

Control device 

type The end of startup is marked by when the...

LK ESP -ESP internal temperature reaches target (e.g., 200°F) and power is applied to 

transformer rectifiers

-the precipitator reaches power set points

LK ESP/SCBR

 and

RF ESP/SCBR

-ESP internal temperature reaches target (e.g., 200°F) and power is applied to 

transformer rectifiers

-scrubber pressure drop and liquid flow limits are met

LK SCBR -scrubber pressure drop and liquid flow limits are met

-lime mud is introduced to the lime kiln

RF ESP -ESP internal temperature reaches target (e.g., 200°F) and power is applied to 

transformer rectifiers

-the precipitator reaches power set points

-liquor firing begins

RF SCBR -required parameters (e.g., pressure drop) are met

SDT OTH -scrubbing media flow starts

-required pressure drop is achieved

-smelt flow begins

SDT SCBR -scrubber fan amps and liquid flow limits are achieved

-pressure drop and/or liquid flow rates are achieved

-black liquor is fired into the furnace

-smelt flow into the SDT begins

Source: See Appendix C2 for details.

LK = lime kiln, RF = recovery furnace, SDT = smelt dissolving tank,

ESP = electrostatic precipitator, SCBR = wet scrubber, OTH = mist eliminator

Table 6. General Responses Defining the Beginning of Control Device Shutdown

Control device 

type The beginning of shutdown is marked by when the...

LK ESP -lime mud flow into the kiln ceases

-kiln fuel firing ceases

-ESP fields begin to be de-energized or powered off

LK ESP/SCBR -lime mud flow into the kiln ceases

-kiln fuel firing ceases

-scrubber liquid flow is reduced (to below target) or shut off

-ESP transformer rectifiers are powered off

LK SCBR -lime mud flow into the kiln ceases

-kiln fuel firing ceases and kiln ID fan is shut down

-scrubber liquid flow is reduced (to below target) or shut off

-pressure drop is no longer met

RF ESP -fuel firing ceases and the ESP components are de-energized/shut down

-black liquor firing ceases

-black liquor firing ceases and smelt bed is burned out

-ESP fields begin to be de-energized or powered off
8

Control device 

type The beginning of shutdown is marked by when the...

RF ESP/SCBR -fuel firing ceases and the ESP components are de-energized/shutdown

-scrubber liquid flow is shut off

RF SCBR -black liquor firing ceases

-auxiliary fuel firing ceases

SDT OTH -shower flow stops

SDT SCBR -black liquor firing in the recovery furnace ceases

-smelt flow has ceased, the scrubber fan is shutdown, weak wash recycle 

pump and weak wash makeup pump are shut down

-scrubber liquid flow is shut off

-pressure drop or scrubbing liquid flow drops below normal operating range

Source: See Appendix C2 for details.

LK = lime kiln, RF = recovery furnace, SDT = smelt dissolving tank, 

ESP = electrostatic precipitator, SCBR = wet scrubber, OTH = mist eliminator

C. Emission Unit and Control Device Integration, Control Device Parameter Deviations, and 

Emission Reduction Measures During Startup and Shutdown

The ICR asked respondents to identify measures employed to reduce air emissions during 

emission unit startup and shutdown.2

 Many respondents selected a default response indicating 

that the emission unit and control device operate in compliance with NSPS and NESHAP 

parameter limits during emission unit startup and shutdown, or that the applicable emission and 

parameter limits are not expected to be exceeded during startup or shutdown. About half of the 

respondents indicated that the control device is started up prior to emission unit startup, and is 

shut down following emission unit shutdown in response to questions related to emission unitAPCD integration and control device emission reduction measures. Other responses to the 

questions about emission reduction measures, emission unit-APCD integration, and control 

device parameter deviations revealed potential startup and shutdown concerns that are 

generalized as follows:3

• Many responses noted that ESPs need to warm to a specified temperature (typically 200-

240°F) before full power can be applied to the transformer rectifier set in order to prevent 

condensation of sticky particulates on the ESP plates that would not be removed easily 

with rapping and result in damage to the ESP by masking the plates (or wires) with 

material that impedes the electrical charge imparted to attract additional particulate. ESPs 

are typically partially energized during the warm-up period. The need for ESPs to warm 

to above 200°F is also described in ESP operation and maintenance literature. (APTI 

1998)

• A few responses indicated that opacity (e.g., a 20 percent limit) or total secondary power 

may not be met for recovery furnaces or lime kilns with an ESP until the emission unit is 

fully online.

 2 See columns labeled SU_EmissRednMeas and SD_EmissRednMeas in Appendix C1.

3 See columns labeled APCD_SD_EmissRednMeas, APCD_SD_EmissRednMeas, 

APCD_SU_Integration, and APCD_SU_ParamDeviation in Appendix C2.
9

• Many responses indicated that scrubber pressure drop cannot be achieved until a certain 

air flow through the scrubber is reached.

• A few responses also noted that lime kiln and SDT scrubber flow rate may not be met 

during startup and shutdown, but a subset of these responses also clarified that flow rate 

limits were met by the time the lime kiln burner is lit or when lime mud is fired (or black 

liquor is fired for an SDT scrubber).

• As noted in the tables above, many mills indicated that ESPs are fully powered when 

black liquor firing begins and remain in operation until black liquor firing ceases. 

• Similarly, the flow of lime mud into the lime kiln appears to be the point when lime kiln 

scrubbers and ESPs are in compliance with parameter limits. 

D. Respondent Recommendations for Standards During Startup and Shutdown for Recovery 

Furnaces, SDTs, and Lime Kilns

As shown in Appendix A, the ICR contained optional questions where respondents were 

asked to suggest a separate standard that could apply during emission unit and control device 

startup or shutdown. Very few suggestions were received. Two respondents suggested that EPA 

require compliance with a scrubber liquid flow parameter monitoring limit, but not a pressure 

drop parameter monitoring limit. Another respondent suggested that the opacity and PM

emissions limits for recovery furnaces should apply only while firing black liquor solids and that 

these limits should not apply during startup and shutdown periods while firing only fuel oil or 

natural gas but not firing black liquor. Finally, another respondent noted that SDT scrubbers 

typically have a bypass line that vents to the atmosphere to protect the integrity of the SDT and 

scrubber in the event of over-pressurization. The respondent noted that the current rule does not 

address how to monitor or report bypasses of the SDT scrubber, and requested that the rule 

include language that allows for scrubber bypasses for safety reasons to protect the integrity of

equipment.

E. Incinerator Temperature Monitoring 

Temperature monitoring is required under the NSPS for incineration control devices (e.g., 

thermal oxidizers) that destroy TRS emissions from NCG emission sources. The startup and 

shutdown of incineration controls used to control NCG sources was discussed in detail in a 

separate memorandum developed for the subpart S residual risk and technology review. (RTI 

2012) As indicated in Appendix C4 of the 2012 memorandum, thermal oxidizers on average take 

8.5 hours to startup and 2.4 hours to shut down. The median startup and shutdown times for 

thermal oxidizers were 6 hours and 0.3 hours, respectively. Subpart S does not specify a block 

averaging time for incinerator temperature, but information from review of permits and a 

meeting with industry representatives suggests that a 3-hour block average is commonly used.

(EPA 2013b, EPA 2013c) Mills typically ensure that the incinerator is at the required 

temperature (1200°F for TRS) prior to routing NCGs to the incinerator. This is accomplished 

through use of alternative or backup NCG control devices (e.g., a lime kiln or boiler), or through 

sequencing of emission unit startup and shutdown with thermal oxidizer startup and shutdown,

so that the thermal oxidizer will be hot enough to accept NCGs. Thus, the warm-up and cooldown time required by incineration devices when no TRS is burned could be excluded from the 

temperature monitoring requirement in the revised subpart BBa. 
10

IV. Summary and Recommendations 

Responses to startup and shutdown questions in Part III of the pulp and paper ICR were 

reviewed to determine the nature and extent of issues that mills would have upon removal of the 

startup and shutdown exemption from subpart BB, to assess whether there is a need for separate 

standards (other than the normal operational standards) to apply during startup and shutdown 

periods, and to determine what separate standards could apply. The effects of startup and 

shutdown on continuously-monitored opacity and TRS are discussed in a separate memorandum. 

(EPA 2013a)

Nearly half of the ICR responses indicated no problems with meeting control device 

parameter limits for ESPs and wet scrubbers during startup and shutdown. However, many 

respondents noted issues with meeting scrubber pressure drop (and in some cases liquid flow) 

limits during startup and shutdown. The need for ESPs to warm to above 200°F before being 

fully energized was also apparent from the ICR responses. The beginning of startup and end of 

shutdown were most commonly marked by the beginning and end of: (1) black liquor firing in 

recovery furnaces; (2) black liquor firing or smelt flow for SDTs; and (3) lime mud firing in lime 

kilns.

Very few ICR respondents provided suggestions for alternative standards during startup 

and shutdown, and there are no emissions data available for use in establishing alternative PM 

emission limits during startup and shutdown. Having parameter limits apply only when black 

liquor or lime mud is processed was suggested by respondents, and this option is supported by 

the responses to ICR questions pertaining to emission unit-APCD integration and emission 

reduction measures.

Based on the information provided in the startup and shutdown ICR questions, rather than 

establishing separate numeric emission limits during startup and shutdown, EPA could continue 

to require continuous parameter monitoring and use the descriptions of what constitutes excess 

emissions in the revised §60.284a(d) of the NSPS to define excess emissions as parameters 

below their minimum limits when black liquor or lime mud is fired. It is also suggested that 

scrubber liquid flow (alone), in lieu of scrubber pressure drop, be used to demonstrate 

compliance during startup and shutdown. Use of a longer averaging time for selected parameters 

(e.g., the ESP parameters added to subpart BBa in conjunction with opacity monitoring or wet 

scrubber parameter monitoring) may also be beneficial to ensure that startup and shutdown 

periods are accounted for in the parameter limits.
11

V. References

APTI 1998 EPA Air Pollution Training Institute, APTI SI:412B Electrostatic Precipitator 

Plan Review, Lesson 6: ESP Operation and Maintenance. Available at

http://yosemite.epa.gov/oaqps/eogtrain.nsf/fabbfcfe2fc93dac85256afe00483cc4/b

6c72f7e09cff3b185256b66004f3530/$FILE/12bles6.pdf (accessed March 1, 

2013)

EPA 2013a Kelley Spence, EPA. Continuous Emissions Monitoring (CEM) and Continuous 

Opacity Monitoring (COM) Data Summary Memo. April 5, 2013

EPA 2013b Kelley Spence, EPA. Minutes of the March 14, 2013 Meeting with AF&PA. 

March 26, 2013

EPA 2013c John Bradfield and Kelley Spence, EPA. Review of the Air Permits for Kraft Pulp 

Mills. April 26, 2013. 

RTI 2012 Katie Hanks, RTI International. Review of Pulp and Paper Information Collection 

Request (ICR) Responses Pertaining to Startup and Shutdown of Subpart S 

Equipment. July 23, 2012. 
Appendix A

Part III Survey Startup and Shutdown Questions
Emission Unit Startup and Shutdown Questions from Part III of the ICR

Data base field Survey Question Survey Spreadsheet Notes Spreadshe

SU_Duration_hrs Approximate duration of emission unit startup

(hours)

Supply startup/shutdown information for equipment (including collection systems or APCDs) that appear in the Emission

Unit ID column.Enter approximately how long it takes for the emission unit to startup. Use decimals if less than one hour (e.g., 18

minutes = 0.3 hr).Supply information for routine startup and shutdown events such as events associated with planned mill downtime. (Do

not provide information for startup/shutdown events associated with control device or emission unit malfunctions).

"Startup" means the setting in operation of an affected source or portion of an affected source for any purpose.

SU_EmissRednMeas Measures employed to reduce air emissions

during emission unit startup (if any)

Select from menu or write in emission u

NSPS and 

startupemission u

unit startu

NSPS/NES

backup coNA ‐ appli

to be exce

SU_MarkEnd What marks the end of emission unit startup

and beginning of normal operating conditions?

Write in response specifying when startup ends and normal operation begins (e.g., Startup ends when the auxiliary

burners switch off and material throughput begins to flow.)

SD_Duration_hrs Approximate duration of emission unit

shutdown (hours)

Enter approximately how long it takes for the emission unit to shutdown. Use decimals if less than one hour (e.g., 18

minutes = 0.3 hr).

"Shutdown" means the cessation of operation of an affected source or portion of an affected source for any purpose.

SD_EmissRednMeas Measures employed to reduce air emissions

during shutdown (if any)

Select from menu or write in Continue o

to 200F

Temperat

SD_MarkBegin What marks the end of normal operating

conditions and beginning of emission unit

shutdown?

Write in response specifying when shutdown begins and normal operation ends (e.g., Shutdown begins when material

throughput ceases to flow.)

SU_SD_Recommend Optional: Do you wish to recommend a

standard that would apply during startup or

shutdown of this emission unit? If so, please

describe the event to which the standard would

apply; the recommended standard (this could

be an emission limitation, work practice, or

operational standard) that would apply during

the period; the basis for the recommended

standard; why and how the standard would

minimize emissions during the event; and how

would compliance be determined and/or

monitored. Supply as a separate attachment to

your survey response if necessary.

OPTIONAL QUESTION. Input on appropriate standards that would be reasonable for your pulp and paper source

category emission units is requested. Supply recommendations for the specific equipment (including collection systems

or APCDs) appearing in the Emission Unit ID column.

Appendix A ‐ PIII Equip detail questions 
Control Device Startup and Shutdown Questions from Part III of the ICR

Data base field Survey Question Survey Spreadsheet Notes Spreadsheet menu choi

APCD_SU_Duration_hrs Approximate duration of control device startup (hours) Supply startup/shutdown information for the equipment that appears in

the APCD_ID column.

Enter approximately how long it takes for the control device to startup.

Use decimals if less than one hour (e.g., 18 minutes = 0.3 hr).

Supply information for routine startup and shutdown events such as

events associated with planned mill downtime. (Do not provide

information for startup/shutdown events associated with control device

or emission unit malfunctions)."Startup" means the setting in operation of an affected source or portion

of an affected source for any purpose.

APCD_SU_Integration Explain how control device startup is integrated with

(dependent upon) emission unit startup/operation

Select from menu, expand on menu response, and/or write in.

For example, is a certain gas flow rate from the emission unit required

before the control device operating parameter limits can be met? Is a

certain heating value from the emission unit exhaust gas required to

achieve control device temperature?

Control device is started 

parameter limits before 

Control device cannot b

up due to safety issue o

Control device cannot fu

rate of {specify} acfm fro

APCD_SU_ParamDeviation List any control device continuous emissions monitoring or

operating parameter limits that cannot be met during control

device startup

List any control device parameter limits that cannot be met during control

device startup. Certain parameters may be "instant on" while others are

more transient in nature. Examples could include control device

temperature that must heat up to a set point, or pressure drop that

cannot be achieved due to low exhaust gas flow from the emission unit.

The EPA is particularly interested in emission limits or parameter limits

originating from the pulp and paper NSPS or NESHAP that cannot be met

during control device startup or shutdown.

Select from menu if the applicable emission and parameter limits are

expected to be met during startup.

The applicable emission 

met during startup

APCD_SU_EmissRednMeas Measures employed to reduce air emissions during control

device startup (if any)

Write in response (if any).

APCD_SU_MarkEnd What marks the end of control device startup and beginning of

normal operating conditions?

Write in response specifying when control device startup ends and normal

operation begins (e.g., Startup ends when oxidizer temperature set point

of 1200F is reached.)

APCD_SD_Duration_hrs Approximate duration of control device shutdown (hours) Enter approximately how long it takes for the control device to shutdown.

Use decimals if less than one hour (e.g., 18 minutes = 0.3 hr).

"Shutdown" means the cessation of operation of an affected source or

portion of an affected source for any purpose.

Appendix A ‐ PIII Controls questions 
Data base field Survey Question Survey Spreadsheet Notes Spreadsheet menu choi

APCD_SD_Integration Explain how control device shutdown is integrated with

(dependent upon) emission unit shutdown

Select from menu, expand on menu response, and/or write in.

For example, is a certain gas flow rate from the emission unit required for

the control device operating parameter limits to be met? Is a certain

heating value from the emission unit exhaust gas required to achieve

control device temperature?

Control device continue

operating limits while e

Control device cannot o

due to safety issue or ris

Control device cannot fu

rate of {specify} acfm fro

APCD_SD_ParamDeviation List any control device continuous emissions monitoring or

operating parameter limits that cannot be met during control

device startup

List any control device parameter limits that cannot be met during control

device shutdown. Certain parameters may be "instant off" while others

are more transient in nature. Examples could include control device

temperature that decreases from the set point as shutdown progresses, or

pressure drop that cannot be achieved due to low exhaust gas flow from

the emission unit.The EPA is particularly interested in emission limits or parameter limits

originating from the pulp and paper NSPS or NESHAP that cannot be met

during control device startup or shutdown.

Select from menu if the applicable emission and parameter limits are

expected to be met during shutdown.

The applicable emission 

met during startup

APCD_SD_EmissRednMeas Measures employed to reduce air emissions during control

device shutdown (if any)

Select from menu or write in

APCD_SD_MarkBegin What marks the end of normal operating conditions and

beginning of control device shutdown?

Write in response specifying when shutdown begins and normal operation

ends (e.g., Shutdown begins when the burners are shut off.)

APCD_SU_SD_Recommend Optional: Do you wish to recommend a standard that would

apply during startup or shutdown of this control device? If so,

please describe the event to which the standard would apply;

the recommended standard (this could be an emission

limitation, work practice, or operational standard) that would

apply during the period; the basis for the recommended

standard; why and how the standard would minimize emissions

during the event; and how would compliance be determined

and/or monitored. Supply as a separate attachment to your

survey response if necessary.

OPTIONAL QUESTION. Input on appropriate standards that would be

reasonable for your pulp and paper source category control system is

requested. Supply recommendations for the specific APCD appearing in

the APCD_ID column.

Appendix A ‐ PIII Controls questions 
Appendix B

Matrix of Subpart BB Standards, Control Systems, and Initial and Continuous Compliance 

Demonstration Requirements
Subpart BB Standards Typical source control systems Pollutant standard Emission Testing Method 1 (Initial Compliance) 

ESP ConScrubber UnESP and scrubber Un

Cross Recovery Furnace 2 ESP or scrubber (1) 0.10 g/dscm (0.044 gr/dscf) corrected to 8 percent O2; and (2) 35 percent opacity. Method 5 (PM) and Method 9 or COMS (opacity). Con

Smelt Dissolving Tank Scrubber 0.1 g/kg black liquor solids (dry weight)[0.2 lb/ton black liquor solids(dry weight)]. Method 5 (PM concentration and volumetric flow rate), process data for BLS. Scr

ESP Un

Scrubber ScrESP and scrubber Scr

ESP 

Straight Kraft Recovery Furnace 2 ESP, Scrubber, or ESP and scrubber 5 ppm by volume on a dry basis, corrected to 10 percent O2 Method 16 (TRS) Con

con

Cross Recovery Furnace 2 ESP or scrubber 25 ppm by volume on a dry basis, corrected to 10 percent O2 Method 16 (TRS) Con

con

Smelt Dissolving Tank Scrubber 0.016 g/kg (0.033 lb/ton) black liquor solids as H2S Method 16 (TRS) and black liquor feed rate Scr

Lime Kiln ESP 8 ppm by volume on a dry basis, corrected to 10 percent O2 Method 16 (TRS) Con

con

Scrubber 8 ppm by volume on a dry basis, corrected to 10 percent O2 Method 16 (TRS) Con

con

Straight Kraft Recovery Furnace 5 ppm by volume on a dry basis, corrected to 10 percent O2 Method 16 (TRS) on furnace Con

con

Cross Recovery Furnace 25 ppm by volume on a dry basis, corrected to 10 percent O2 Method 16 (TRS) on furnace Con

con

Lime Kiln 8 ppm by volume on a dry basis, corrected to 10 percent O2 Method 16 (TRS) on lime kiln Con

con

Incinerator or other combustion control device, or lime kiln or recovery furnace not subject to NSPS

Minimum temperature of 650oC (1200oF) for at least 0.5 seconds Method 16 (TRS) on combustion source Tem

Non-combustion control 5 ppm by volume on a dry basis, uncorrected for O2 Method 16 (TRS) No

New, modified, or reconstructed digester system Uncontrolled Less than 0.005 g/kg (0.01 lb/ton) air dried pulp Method 16 (TRS) and pulp production rate NoESP - electrostatic precipitator, TRS - total reduced sulfur, COMS - continuous opacity monitoring system, PM- particulate matter, O2 - oxygen

Some facilities may use the parameters included in subpart BB though they are not meaningful (e.g., monitoring opacity between an ESP and scrubber). Subpart BBa will specify monitoring requir2 - TAPPI Method T.624 is used when determining whether a furnace is a "straight" or "cross" recovery furnace based on green liquor sulfidity.3 - Scrubbers for recovery furnaces, ESPs for lime kilns, and ESP-scrubber combinations are not addressed under the current NSPS subpart BB. Facilities presumably would petition the AdministraDigester system, brown stock washer system, multiple effect evaporator system, or condensate stripper system

Appendix B. Summary of NSPS Subpart BB Standards, Test Methods, and Monitoring Requirements

PM TRSStraight Kraft Recovery Furnace 2

1 - For Method 5, Method 17 may be used if a constant value of 0.009 g/dscm (0.004 gr/dscf) is added to the results of Method 17 and the stack temperature is no greater than 204°C (400°F). In plaused. Subpart BB requires an initial compliance test only (e.g., no repeat tests are specified in subpart BB).

(1) 0.10 g/dscm (0.044 gr/dscf) corrected to 8 percent O2; and

(2) 35 percent opacity.(1) 0.15 g/dscm (0.066 gr/dscf) corrected to 10 percent O2, for gaseous fossil fuel; or(2) 0.30 g/dscm (0.13 gr/dscf) correct to 10 percent O2, for liquid 

fossil fuel.

Method 5 (PM) and Method 9 or COMS (opacity).

Lime Kiln Initial Compliance - Method 5 (PM)

Appendix B 
Appendix C

ICR Data Relevant for the Kraft NSPS PM and TRS Standards

Appendix C1 – Query of Part III Survey Data Base (PIII Equip detail tab) for PM and TRS 

Generating Processes and Collection Systems

Appendix C2 – Startup and Shutdown Responses for PM and TRS Controls in the PIII Controls

tab of the ICR
Appendix C1

Query of Part III Survey Data Base (PIII Equip detail tab) for PM and TRS Generating 

Processes and Collection Systems
Appendix C1: Query of Part III Survey Data Base (PIII Equip detail tab ) for PM and TRS Generating Processes and Collection Systems

Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

DCEDCE DBESP 119 1 RF ESP 8 8

ESP is powered up prior toinitial fire in recovery furnace

establishment of a stable

furnace bed at the targetedarea and height 16 16

ESP is the last device shut

down

DCE DBESP 121 2 RF ESP 8 8

Ensure ESP in operation priorto firing black liquor

When target black liquor flow

is achieved 6 6

Ensure ESP in operation until

black liquorflow is ceased

DCE DBESP 124 1 RF ESP 4 4

emission unit and control

device operates in compliancewith NSPS and NESHAP

parameter limits duringemission unit startup Begin burning black liquor 2 2 contine operating esp

DCE DBESP 131 1 RF ESP 6 6

emission unit and control

device operates in compliancewith State and NESHAP

parameter limits duringemission unit startup

Furnace combustion O2 < 15%and steam flow > 190 klb/hr. 1 1

Continue to operate controldevice until unit is down

DCE DBESP 142 1 RF ESP

~9 hrs (Hot),

~12 Hrs (Cold) 12

Control device is turned on

prior to emission unit startup.

The startup period ends whengreen liquor is produced in the

associated dissolving tank andpumped for five (5)

consecutive hours understeady state conditions.

~10 hrs (Hot),

~84 hrs (Cold) 84

Control device is operated

during emission unit shutdown

DCE DBESP 151 1 RF ESP 9 9

Ensure ESP operation is stable

and all apparent problemshave been addressed

Once boiler is up to operating

steam pressure andsuperheater loops are clear theRecovery Boiler may be placed

on‐line 3 3

Stop all black liquor flow into

the recovery boiler andmonitor opacity during theshutdown process

DCE DBESP 613 2 RF ESP 2 2

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits during

emission unit startup When black liquor is fired. 2 2

Precipitators are operational

during boiler shutdown.

DCE DBESP/SCBR 197 1 RF ESP/SCBR 3 3

NA ‐ applicable emission andparameter limits not expected

to be exceeded during startup

gas is out of the boiler and

black liquor is being burned 1 1

DCE DBESP‐WPR 171 3 RF ESP 8 8

Ensure control equipment isoperational as early as possiblein startup procedure.

Document steps for accurateSU through SSM plan and

standard operating procedures.

Startup ends when steambeing generated by Recovery

Boilers less the amount of

natural gas generated steam isgreater than 50,000 lb/hr 8 8

Ensure control equipment isoperational as long as possiblein shutdown procedure.Document steps for specific SDthrough SSM plan and standardoperating procedures.

DCE WBESP 105 1 RF ESPDCE WBESP 124 1 RF ESP 4 4

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup Begin burning black liquor 2 2 contine operating esp

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

DCE WBESP 130 2 RF ESP

Cold Startup: 8

to 12 Hrs (Time

elapsed from

initial auxiliary

fuel firing until

black liquor is

introduced);

Hot Startup: 0.5

to 2 Hrs 12

Emission unit and control

device operate in compliance

with NESHAP parameter limits

during emission unit startup.

SOP: ESP is operational (Power

is applied to tranformerrectifiers after ESP penthouse

heaters have been on 4 to 6hours) before black liquor isintroduced to the recoveryfurnace.

Black liquor is introduced to

the boiler, a stable funace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from reducing

liquor firing

until furnace

bed is burned

out/smelted

out): 5 to 7 Hrs 7

SOP: ESP remains operational

until all black liquor is pulled

from the recovery furnace andthe bed is burned out/smeltedout (recovery furnace isshutdown).

DCE WBESP 142 1 RF ESP

~10 hrs (Hot),

~12 hrs (Cold) 12

Control device is turned on

prior to emission unit startup.

The startup period ends whengreen liquor is produced in the

associated dissolving tank andpumped for five (5)consecutive hours under

steady state conditions.

~6 hrs (Hot),

~84 hrs (Cold) 84

Control device is operated

during emission unit shutdown

DCE WBESP 143 3 RF ESP

Hot 2‐8, Cold 8‐

24 24

Adjust air flow, adjust oil guns,ESP is operational as soon asblack liquor firing begins

1 hour after black liquor is in

the furnace

Hot or cold: 4‐8

hours 8

Adjust air flow and adjust oil

guns, ESP remains operational

until black liquor firing ceases.

DCE WBESP 145 2 RF ESP 7 7

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

Recovery unit has stabilized

black liquor burning 7 7

DCE WBESP 146 1 RF ESP 10 10

ESP is to be in operation prior

to introduction of black liquor

in the recovery furnace/BLOx

tower is to be in operationwith acceptable sulfidity levels

Introdution of black liquor to

the recovery furnace 1 1

Control device remains inoperation until after black

liquor addition has stopped

DCE WBESP 154 2 RF ESP 12 12

NA ‐ applicable emission andparameter limits not expected

to be exceeded during startup

when the liquor ring headerrecirculation valves are closed 8 8

NA ‐ applicable emission andparameter limits not expected

to be exceeded during

shutdown 

DCE WBESP 154 1 RF ESP 12 12

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

when the liquor ring headerrecirculation valves are closed 8 8

NA ‐ applicable emission andparameter limits not expected

to be exceeded during

shutdown 

DCE WBESP 156 1 RF ESP 5 5 follow SSM manual procedures

Startup is marked by

completely cold furnacetemperature till liquor is fired 5 5 follow SSM manual procedures

DCE WBESP 156 1 RF ESP 5 5 follow SSM manual procedures

Startup is marked by

completely cold furnacetemperature till liquor is fired 5 5 follow SSM manual procedures

DCE WBESP 163 1 RF ESP

12 (Cold

Startup) 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolving

tank is achieved.

6 (Cold

Shutdown) 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner is

removed.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

DCE WBESP 166 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Black liquor isintroduced to the recovery

furnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner isremoved.

DCE WBESP 167 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial auxiliary

fuel firing until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

tranformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable funace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and the

last oil or gas burner isremoved.

DCE WBESP 174 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after the

ESP internal temperature

reaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner isremoved.

DCE WBESP 188 2 RF ESP 6 6

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

The startup period ends when

black liquor is being fired and

the liquor rail purge valveshave been closed. 0.5 0.5 ESP left on until fire is out

DCE WBESP 205 1 RF ESP 10 10

ESP is operating once black

liquor is introduced intorecovery furnace

Black liquor flow to recovery

furnace exceeds 70,000 lbs/hr

for at least 15 minutes 4 4

Continue operatingelectrostatic precipitator until

after liquor firing ceases

DCE WBESP 206 1 RF ESP 6 6 None

When liquor solids are greater

than 62% and nozzle pressureis greater than 34 psi on size 34nozzles and oil guns are out of

service. 6 6

emission unit and control

device operates duringemission unit shutdown (but

not necessarily in compliance

with all NSPS/NESHAP

parameter limits)

DCE WBESP 206 1 RF ESP 6 6 None

When liquor solids are greater

than 62% and nozzle pressure

is greater than 34 psi on size 34nozzles and oil guns are out of

service. 6 6

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

DCE WBESP 600 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor isintroduced to the recovery

furnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolving

tank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner is

removed.

DCE WBESP/SCBR 152 1 RF ESP/SCBR 8 8

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup begin combusting black liquior 24 24

continue operatiingprecipitator and scrubberduring cool down 

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

DCE WBESP/SCBR 166 1 RF ESP/SCBR

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Black liquor isintroduced to the recovery

furnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner isremoved.

DCE DBESP 613 2 RF ESP 2 2

emission unit and control

device operates in compliancewith NSPS and NESHAP

parameter limits duringemission unit startup When black liquor is fired. 2 2

Precipitators are operational

during boiler shutdown.

DCE DBESP 606 1 RF ESP 12 12

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Stable operation of furnace onBLS at >70% nominal rate 8 8 

DCE WBESP 175 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner isremoved.

Lime KilnLime Kiln CYC/ESP 147 1 LK ESP 20 20

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup Full load introduced 24 24

emission unit and control

device operates duringemission unit shutdown 

Lime Kiln CYC/SCBR 131 1 LK SCBR 8 8

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Flame is present and mud flow> 100 gpm. 3 3

Continue to operate controldevice until unit is down

Lime Kiln CYC/SCBR 135 1 LK SCBR 53 53

The scrubber is operating priorto the start of fuel firing in the

lime kiln.

The oil firing in the kiln and

mud flow to the kiln is stableand continuous. 5 5

The scrubber is operated

during the shutdown of thelime kiln.

Lime Kiln CYC/SCBR 149 1 LK SCBR

2 hours after 24

to 30 hour

warm up curve 30

Operate all APCDs during

startup

Total Mud Flow to Kiln > 400

lb/min for 2 hrs and Gas Flowto Kiln > 51 MMscfh 2 2

Operate all APCDs duringshutdown

Lime Kiln CYC/SCBR 174 1 LK SCBR

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Scrubber is operational and

scrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is shutdown.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln CYC/SCBR 202 1 LK SCBR

6 hours.

Startup is

considered to

begin after lime

mud is first

added to the

lime kiln,

Startup for

NESHAP is not

considered the

time required

when warming

up on natural

gas although

CEMS are in

operation then.

Lime kiln warm‐

up from a cold

start can 6

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Mud Flow to Precoat Filter >

100 gpm for 6 hours; aftermore than 30.3 SCFM Naturalgas flow AND feed conveyor

forward

2009 average

shutdown time

is 2.15 hours ‐ 

Lime kiln shut

down is

considered

complete when

natural gas fuel

flow is less than

30.3 scfm for 1

minute and

lime mud is not

entering the

kiln. 2.15

Continue operating scrubberunless need to work onscrubber even when emission

unit down. Continue operatingscrubber until gas is off kilnand mud flow is out of kiln as

well as verify 3‐hour blockaverage for flow and supplypressure is met.

Lime Kiln ESP 100 1 LK ESP

19 hours (cold

outage to

introducing

lime mud) 19 Startup on natural gas

Consistent target fire end

temperature is attained and

consistent mud flow isachieved.

Take lime mud

and natural gas

out in ~0.25

hour &

continue to

rotate kiln.

Total outage

has a ~44 hour

curve to

completely cool

kiln and get

product out. 44

Keep preciptators operating

until temperature reduces to a

point that the lime kiln can be

shutdown.

Lime Kiln ESP 102 1 LK ESP 24 24

While purging Kiln prior to

lighting burner, Precipitator ID

fans are sped up to purge

requirements in incrementalsteps rather than all at once in

order to minimize lime dustentrainment and stack opacity.

Hot end temperature stable at1800F 48 48

Operate LK‐ESP at normalpower until lime mud & rock

feed stops and fire is out of

burner; continue operating LK‐

ESP at partial power during LK

cooldown.

Lime Kiln ESP 104 1 LK ESP

Cold Startup:

36 Hrs; Hot

Startup: 6

Hours 36

BEFORE startup of the Lime

Kiln: 1) Confirm the LVHC

System control device is readyto accept gases and 2) Ensure

equipment is properly valved

to the LVHC Collection System

Lime Kiln is operating at a

stable rate when hot end

temperature is greater than

1600 degF and incineration

interlocks are met.

Controlled

Shutdown: 6

Hrs 6

Continue operating scrubber

until mud is fed out of the kiln,

potential for dusting iseliminated, and fan is shutdown.

Lime Kiln ESP 107 1 LK ESP 24 24

Start the ESP when the outlet

temperature exceeds 240F but

before mud is fed to the kiln

4 hours after mud introduced

into the kiln

Shut down ESP when the ESPoutlet temperature dropsbelow 240F 

Lime Kiln ESP 109 1 LK ESP 24 24

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Introduce mud flow to Kiln'sprecoat filter 24 24

emission unit and contol device

operates in compliance with

NSPS and NESHAP parameter

limits during emission unit

shutdown.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln ESP 111 1 LK ESP 12 12

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Lime mud addition to the hot

end of the kiln has reached a

stable rate. 14 14

Emissions controls remain inoperation until shut‐down has

been completed.

Lime Kiln ESP 112 1 LK ESP

Lime Kiln ESP 114 1 LK ESP 24 24

Startup ESP prior to beginning

startup of the Lime Kiln Mud flow rate >240 tons/day 24 24

Continue operating ESP untilLime Kiln is shutdown

Lime Kiln ESP 115 1 LK ESP 24 24

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup Lime flow out of the Kiln 4 4

NA ‐ applicable emission andparameter limits not expected

to be exceeded during

shutdown 

Lime Kiln ESP 127 2 LK ESP 2 2 ESP operates during startup

1800 oF on front side and 400

oF on back side on kiln with

lime mud feed rate of 130‐150

GPM 0.0333 0.0333

ESP continues to operate

during shutdown

Lime Kiln ESP 132 1 LK ESP 36 36

ESP energized and NCGs routedto backup incinerator Lime is produced. 36 36

Control device remains

operational until the EU is

shutdown

Lime Kiln ESP 136 1 LK ESP 3 3

Operate control equipment at

all times emission unit is not

down

natural gas flow > 10 kscf/hand continuous lime mud feedfor 3 hours 1 1

Continue operating APCE untilunit is down

Lime Kiln ESP 137 1 LK ESP 36 36 FOLLOW SSM PLAN

Natural gas flow > 150 scfm on

a sustained basis andprecipitator temperature > 350

deg.F and Stack O2 is < or =

16% on a sustained basis andprecoat belt mud flow into kiln

operating in a forward positionand mud flow to lime kiln > or

= 50 gpm on a sustained basis. 24 24 FOLLOW SSM PLAN

Lime Kiln ESP 143 1 LK ESP

Hot: 0.5 ‐ 1.5

hours Cold:

23.0 ‐ 25.0

hours Must

follow

manufacturer

warm up curve 25

Lime Kiln is started firingauxiliary fuel; ESP on before

lime mud enters kiln.

Consistent target fire end

temperature is attained and

consistent mud flow isachieved.

Hot or Cold: 10 ‐

15 hours 15

Continue operating ESP until

mud is fed out of the kiln andID fan is shut down.

Lime Kiln ESP 148 1 LK ESP 14 14

emission unit and control

device operates in complianceparameter limits duringemission unit startup

When proper operatingtemperature has been

achieved 0.5 0.5

emission unit and control

device operates in complianceparameter limits duringemission unit shutdown 

Lime Kiln ESP 156 1 LK ESP 42 42 follow SSM manual procedures Rolling mud through kiln 24 24 follow SSM manual procedures 

Lime Kiln ESP 162 1 LK ESP

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Power is applied to the

transformer rectifiers after theESP internal temperature

reaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Lime Mud isintroduced to the lime kiln onlyafter the ESP is brought on‐

line.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

ESP remains operational untilall lime mud is pulled from the

lime kiln and the last oil or gas

burner is removed.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln ESP 179 1 LK ESP 24 24

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Lime mud begins being fed to

the kiln 8‐24 24

Emission unit control device

continues to operate duringshutdown.

Lime Kiln ESP 196 1 LK ESP 18 18

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Hot end temperature reaches1300F; Cold end reaches 450F 18 18

Continue operating ESP untillime production has ceased 

Lime Kiln ESP 200 1 LK ESP 24 24

Follow appropriate pre‐start/startup checklist. ESP

charged and operational.

ID fan is in operation, mud feed

system is on, and the burner isin operation. 24‐48 48

Follow the appropriate

shutdown checklist. Control

device may continue tooperate throughout shutdown.

Lime Kiln ESP 240 1 LK ESP

>20 hours if

cold startup

from planned

outage 20

To avoid severe corrosiondamage to control device, the

ESP cannot be started up

before fuel‐only firing in Lime

Kiln can bring the temperatureat back end of kiln above acid

dewpoint temperatures.However, during this fuel‐onlyfiring/kiln heatup process , thelime kiln is not feeding or

processing any lime mud. so

the only particulate generation

is from the fuel combustion.

Lime Kiln meets minimum backend temperature and rawmaterial lime mud feed begins.

> 20 hours if

shutting down

to cold

conditions for

planned outage 20

Control device continues to

operate and meet required

operating limits until lime mud

feed to the emission unit has

ceased, remaining lime product

has discharged from theemission unit, and fuel firing to

the unit ceases. 

Lime Kiln ESP 531 1 LK ESP

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Lime Mud is

introduced to the lime kiln onlyafter the ESP is brought on‐

line.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

Continue operating ESP until

mud is fed out of the kiln,potential for dusting iseliminated, and ID fan is shut

down.

Lime Kiln ESP 606 1 LK ESP 24 24

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits during

emission unit startup

Lime mud feed stable andemissions in limits 4 4

ESP operates until fire is out

and kiln is cooled down 

Lime Kiln ESP 617 1 LK ESP 4 4

control device is fullyoperational prior to processstartup

lime mud feed rate reaches 70

gpm 19 19

control device is fullyoperational until shutdown is

complete 

Lime Kiln ESP

2082285

35 1 LK ESP 24 24

Ensure scrubber liquid isflowing prior to igniting fire inthe kiln

Lime mud flow to precoat filteris greater than 230 gpm for at

least 3 hours 1 1

Continue operating scrubberuntil temperature in kiln dropsto 200F

Lime Kiln ESP/PBSCBR 137 1 LK ESP/SCBR 36 36 FOLLOW SSM PLAN

Natural gas flow > 150 scfm on

a sustained basis andprecipitator temperature > 350

deg.F and Stack O2 is < or =16% on a sustained basis andprecoat belt mud flow into kiln

operating in a forward position

and mud flow to lime kiln > or

= 50 gpm on a sustained basis. 24 24 FOLLOW SSM PLAN

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln ESP/SCBR 126 1 LK ESP/SCBR

Cold startup:

12 hours (time

elapsed from

initial firing of

fossil fuel lime

processing);

Hot startup: 4

hours 12

During cold start up prior to

processing lime mud the

precipitator is bypassed andemissions treated by scrubber

until flue gas temperature over

400 F when precipitator is tied

in. After heating precipitator

TRs are energized and lime

mud processing begins

3 hours after lime mud

processing begins and whenfiring sufficiently stable tothermally oxidize NCG from

LVHC.

Controlled

shutdown: 6

hours 6

ESP and Scrubber remainoperational and LVHC thermal

oxidation continues until all

lime processing ceases.

Lime Kiln ESP/SCBR 146 1 LK ESP/SCBR 16 16

ESP is to be in operation prior

to introduction of lime mud

Introduction of lime mud tothe lime kiln 0.1 0.1

Control device remains inoperation until lime mud

addition has stopped 

Lime Kiln ESP/SCBR 154 1 LK ESP/SCBR 24 24

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup when feeding mud 0.5 0.5

NA ‐ applicable emission andparameter limits not expected

to be exceeded during

shutdown 

Lime Kiln ESP/SCBR 174 1 LK ESP/SCBR

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Scrubber is operational andscrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target fire end temperature is

attained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

Lime Kiln ESP/SCBR 178 1 LK ESP/SCBR

Cold Startup:

~36 Hrs; Hot

Startup: ~6 Hrs 36

Scrubber is operational and

scrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: ~6

Hrs 6

Continue operating scrubber

until mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

Lime Kiln ESP/SCBR 184 1 LK ESP/SCBR 24 24

Ensure scrubber liquid flow and

differential pressure isachieved and ESP is energized

prior to lighting main burner.

Appropriate hot end

temperature is reached. 24 24

Continue operating ESP and

scrubber until main burner

flame is extinquished.

Lime Kiln ESP/SCBR 186 1 LK ESP/SCBR 24 24

ESP and scrubber must be incompliance

When mud and fire are fed to

the kiln 12 12

ESP and scrubber must be incompliance

Lime Kiln ESP/SCBR 242 1 LK ESP/SCBR 24 24

emission unit and control

device operates in compliancewith NSPS and NESHAP

parameter limits duringemission unit startup

When lime iflowing to theproduct silo 20 20

Precipitator and scrubber areoperational during boilershutdown.

Lime Kiln ESP/SCBR 243 1 LK ESP/SCBR 24 24

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

24 hours after introducing lime

mud into the lime kiln 6 6

Continue to operate scrubberand precipitator untilshutdown complete

Lime Kiln MC/SCBR 124 1 LK SCBR 4 4

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup Begin calcining lime 4 4 continue operating scrubber 

Lime Kiln SCBR 103 1 LK SCBR 15 15

The kiln body should be under

a slight negative pressure.

For a cold startup, the kiln is

operating at a stable rate not <

300 gpm of lime mud. 24 24

Reduce mud flow to filters

before taking the cake off. DCS

display provides information of

shutdown.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln SCBR 108 1 LK SCBR

Cold Startup:

24 Hrs; Hot

Startup: 6 Hrs 24

Scrubber is operational and

scrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target fire end temperature is

attained and consistent mud

flow is achieved.

Controlled

Shutdown: 8

Hrs 8

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

Lime Kiln SCBR 116 1 LK SCBR

Cold Startup:

~36 Hrs

Hot Startup: ~6

Hrs 36

Scrubber is operational and

scrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: ~6

Hrs 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is shut

down.

Lime Kiln SCBR 117 1 LK SCBR 36 36

Operate Scrubber during Start‐

UP

Full and Steady Combustiontemperature reached and limemud feed on, Liquid Flow to

scrubber, Scrubber Fan On 18 18

the control device is operatedduring emission unit shutdown 

Lime Kiln SCBR 119 1 LK SCBR 0.5‐24 24

Scrubber operates prior to

start‐up of ID fan

hot end temperature exceeds1900F and kiln is procucinglime 4 4

Scrubber is last device shutdown

Lime Kiln SCBR 120 1 LK SCBR 38 38

The scrubbing system isutilized when the main burner

fuel is turned on.

LK1 hot end and cold endtemperatures must be ontarget and at steady state.Only after the kiln’s residual

carbonate test meet target is

the kiln deemed in normalmode. 38 38

The scrubber is in operationuntil the kiln has stopped

rotation

Lime Kiln SCBR 120 1 LK SCBR 38 38

The scrubbing system isutilized when the main burner

fuel is turned on.

LK2 hot end and cold end

temperatures must be ontarget and at steady state.Only after the kiln’s residualcarbonate test meet target is

the kiln deemed in normal

mode. 38 38

The scrubber is in operationuntil the kiln has stopped

rotation

Lime Kiln SCBR 121 1 LK SCBR 72 72

Ensure scrubber liquid isflowing at or above minimum

scrubber flow established in

the NESHAP MM initial

performance test Reach target temperature 24 24

Ensure scrubber liquid isflowing at or above minimum

scrubber flow established in

the NESHAP MM initialperformance test

Lime Kiln SCBR 130 1 LK SCBR

Cold Startup:

24 to 42 Hrs;

Hot Startup: 1

to 8 Hrs 42

Emission unit and control

device operate in compliance

with NESHAP parameter limits

during emission unit startup.

SOP: Scrubber is operationaland minimum operating

parameter requirements(Scrubber Δ Pressure and

Recycle Flow) are achievedbefore startup of kiln.

Target feed end and fire endtemperatures are attained and

consistent mud flow isachieved.

Controlled

Shutdown: 6 to

12 Hrs 12

SOP: Continue operating

scrubber until mud is fed out of

the kiln, potential for dusting is

eliminated, and ID fan is shutdown.

Lime Kiln SCBR 130 1 LK SCBR

Cold Startup:

24 to 42 Hrs;

Hot Startup: 1

to 8 Hrs 42

Emission unit and control

device operate in compliance

with NESHAP parameter limits

during emission unit startup.

Standard Operating Procedure(SOP): Scrubber is operational

and minimum operating

parameter requirements

(Scrubber Δ Pressure and

Recycle Flow) are achievedbefore startup of kiln.

Target feed end and fire end

temperatures are attained and

consistent mud flow isachieved.

Controlled

Shutdown: 6 to

12 Hrs 12

Standard Operating Procedure(SOP): Continue operatingscrubber until mud is fed out of

the kiln, potential for dusting is

eliminated, and ID fan is shutdown.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln SCBR 131 1 LK SCBR 5 5

emission unit and control

device operates in compliance

with State and NESHAP

parameter limits duringemission unit startup

Flame is present and mud flow

> 100 gpm. 2 2

Continue to operate control

device until unit is down

Lime Kiln SCBR 133 2 LK SCBR 6 6

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

The mud feed and burner is

operating in the normal range

and the product lime meetsquality criteria 3 3

Lime Kiln SCBR 138 1 LK SCBR 36 36

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

feed end temperature reaches

680F 4 4 continue operating scrubber 

Lime Kiln SCBR 139 1 LK SCBR

4 for routine

startup,16 from

annual down. 16

LK Scrubber is operating priorto initiating odor gases or mud

feed is fired. Firing

temperature is > 1000 F prior

to introducing LVHC gases

Target mudflow rate has been

reached. 4 4

Scrubber is operating until oil is

off and no odor gases are beingsent to the lime kiln.

Lime Kiln SCBR 140 1 LK SCBR

Venturi Scrubber flow isgreater than 500 gpm and the

delta P across the scrubber isgreater than 20 inches of

water.

Lime Mud filter pump is on,

Venturi Scrubber flow isgreater than 500 gpm and the

delta P across the scrubber is

greater than 20 inches of

water.

The flow to the Venturiscrubber must be greater than

500 gpm and the delta P across

the scrubber must be greater

than 20 inches of water.

Lime Kiln SCBR 142 2 LK SCBR

~6 hrs (Hot),

~24 Hrs (Cold) 24

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

Adequate vacuum is

maintained at essential inlets

and outlets of the LVHC systemfor 60 minutes.

~1 hr (Hot), ~20

hrs (Cold) 20

Control device is operated

during emission unit shutdown

Lime Kiln SCBR 145 1 LK SCBR 24 24

The venturi scrubber is placed

in operation prior to the kiln.

Pressure drop regulated to the

normal operating level 24 24

continue to operate thescrubber for 24 hours after

flame and lime mud stop

Lime Kiln SCBR 146 1 LK SCBR 16 16

Scrubber is to be in operation

prior to introduction of lime

mud

Introduction of lime mud tothe lime kiln 0.1 0.1

Control device remains inoperation until lime mud

addition has stopped 

Lime Kiln SCBR 147 1 LK SCBR 20 20

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup Full load introduced 24 24

emission unit and control

device operates during

emission unit shutdown 

Lime Kiln SCBR 148 1 LK SCBR 14 14

emission unit and control

device operates in compliance

parameter limits duringemission unit startup

When proper operatingtemperature has been

achieved 0.5 0.5

emission unit and control

device operates in complianceparameter limits duringemission unit shutdown 

Lime Kiln SCBR 150 1 LK SCBR 36 36

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Mud is being fed at a rate of

greater than 300 Tons per day 24 24

Continue operating scrubber

until kiln completes shutdown 

Lime Kiln SCBR 152 1 LK SCBR 12 12

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

begin feeding mud to cold endof kiln 24 24

continue operatiing scrubberduring cool down 

Lime Kiln SCBR 153 1 LK SCBR

Lime Kiln SCBR 155 1 LK SCBR 24 24

Ensure scrubber flowrate isgreater than 504 gpm and dP isgreater than 13" water prior to

start‐up.

Mud flow greater than 180gpm for 2 hrs and gas flow to

kiln greater than 600 scfm orfuel oil to kiln is greater than 1

gpm and oil pressure to kiln is

greater than 75 psig 6 6

Ensure scrubber flowrate is

greater than 504 gpm and dP is

greater than 13" water until

shutdown is complete.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln SCBR 156 1 LK SCBR 42 42 follow SSM manual procedures

Open Weak NCG supply valve

to No. 3 Lime Kiln Primary Air

Fan inlet Stack 24 24 follow SSM manual procedures

Lime Kiln SCBR 156 1 LK SCBR 42 42 follow SSM manual procedures

Open Weak NCG supply valve

to No. 4 Lime Kiln Primary Air

Fan inlet Stack 24 24 follow SSM manual procedures

Lime Kiln SCBR 157 1 LK SCBR 27 27

emission unit and control

device operates in compliancewith NSPS and NESHAP

parameter limits duringemission unit startup When product lime is made 3 3

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during

shutdown 

Lime Kiln SCBR 159 1 LK SCBR

12 to 24 hours

for a cold start 24

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits) feeding lime mud to the kiln 4‐6 6

continued operation of thescrubber

Lime Kiln SCBR 162 1 LK SCBR

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Scrubber is operational andscrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target fire end temperature is

attained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

Lime Kiln SCBR 163 2 LK SCBR

36 (Cold

Startup) 36

Scrubber is operational and

scrubber parameter limits (flow

and differential pressure) areachieved before processing

lime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

6 (Cold

Shutdown) 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shut

down.

Lime Kiln SCBR 164 1 LK SCBR 26 26

scrubber is employed duringentire warmup curve. NCG is

not introduced until the hot

end temperature is > 1200 F

after 26 hour warm up curve

lime kiln hot end temperatureis > 1200 F 24 24

keep lime kiln scrubber

operating for 24 hours after

lime mud feed stops 

Lime Kiln SCBR 165 1 LK SCBR

Cold Startup:

37 Hrs (36 hrs

to warm on

gas, 1 hr to add

mud flow); Hot

Startup: 6 Hrs 37

Scrubber is operational andscrubber parameter limits

(liquid flow) are achievedbefore firing fuel or processing

lime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: 18

Hrs 18

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

Lime Kiln SCBR 165 1 LK SCBR

Cold Startup:

37 Hrs (36 hrs

to warm on

gas, 1 hr to add

mud flow); Hot

Startup: 6 Hrs 37

Scrubber is operational and

scrubber parameter limits

(liquid flow) are achieved

before firing fuel or processing

lime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: 20

Hrs 20

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

Lime Kiln SCBR 166 2 LK SCBR

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Scrubber is operational andscrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

Lime Kiln SCBR 167 1 LK SCBR

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Scrubber is operational and

minimum operating parameterrequirements (flow and dP) areachieved before processinglime mud.

Target fire end temperature is

attained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln SCBR 169 1 LK SCBR

Cold Startup:

24 Hrs; Hot

Startup: 3 Hrs 24

Scrubber is operational and

scrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target fire end temperature is

attained and consistent mud

flow is achieved

Controlled

Shutdown: 3

Hrs 3

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown

Lime Kiln SCBR 171 2 LK SCBR 20 20

Ensure control equipment is

operational as early as possible

in startup procedure.

Document steps for accurateSU through SSM plan andstandard operating procedures.

Startup ends when front endtemperature of kiln exceeds1600 deg F OR when mud flow

is greater than 25 gpm andeither: fuel oil flow s greater

than 1 gpm OR natural gas flow

is greater than 5 kscf/hr. 4 4

Ensure control equipment isoperational as long as possible

in shutdown procedure.Document steps for specific SDthrough SSM plan and standardoperating procedures.

Lime Kiln SCBR 172 1 LK SCBR

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Scrubber is operational andscrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is shutdown.

Lime Kiln SCBR 173 1 LK SCBR

Cold startup:

36 hours; Hot

startup: 14

hours 36

Scrubber is operational and

scrubber parameter limits (flow

and differential pressure) areachieved before processinglime mud.

Target feed end temperature is

attained and consistent mud

flow is achieved.

Controlled

shutdown: 6

hours 6

Continue operating scrubberuntil mud is out of the kiln,potential for dusting is

eliminated and ID fan is shut

down.

Lime Kiln SCBR 175 2 LK SCBR

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Scrubber is operational and

scrubber parameter limits (flow

and differential pressure) are

achieved before processinglime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

Lime Kiln SCBR 176 1 LK SCBR 26 26

Lime Kiln Scrubber started andcontrol parameters up to limitsbefore fire is put in kiln

Mud pump and feed‐end screw

running 1 1

Lime kiln scrubber including

control device parametersmaintained until three hours

after fire is pulled from the kiln

Lime Kiln SCBR 177 1 LK SCBR 10 ‐ 20 hours 20

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Normal operation begins whenthe limekiln is operating at

normal mud feed rate and lime

kiln operation is stable. 10 ‐ 20 hours 20

Control device (EU0905)continues to operate normally

durng the kiln shutdownprocess.

Lime Kiln SCBR 180 2 LK SCBR 8 8 Wet scrubber

Infeed temperature 1300degrees and mud on kiln 2 2 Wet scrubber 

Lime Kiln SCBR 181 2 LK SCBR 24 24

scrubber is operational prior to

startup; applicable emission

and parameter limits not

expected to be exceeded

during startup mud in kiln 24 24

scrubber is operational until

shutdown complete; applicable

emission and parameter limits

not expected to be exceeded

during shutdown 

Lime Kiln SCBR 183 1 LK SCBR

Lime Kiln SCBR 184 1 LK SCBR 24 24

Ensure scrubber liquid flow and

differential pressure isachieved prior to lighting main

burner.

Appropriate hot end

temperature is reached. 24 24

Continue operating scrubberuntil main burner flame isextinquished.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln SCBR 185 1 LK SCBR

1.0 hour

following mud

flow to kiln is

initiated until

operating

parameters are

stabilized.

2.5 hours

following mud

flow to kiln is

initiated until

product lime

leaves the kiln 3

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

Excess oxygen, TRS, and kiln

drafts have stabilized

0.25 hours to

stop mud flow

and run out

mud feed

system; 2.5

hours following

stop of mud

flow to kiln

remaining

product lime

exits the kiln 2.75

Kiln scrubber continues tooperate until mud flow to kilnstops, kiln is on slow roll, and

ID Fan is shutdown and

stopped

Lime Kiln SCBR 188 2 LK SCBR 24 24

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Lime mud is introduced to wet

end of kiln 24 24

Operate Peabody Scrubber

during Shutdown 

Lime Kiln SCBR 188 1 LK SCBR 48 48

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Lime mud is introduced to wet

end of kiln 24 24

Operate Peabody Scrubber

during Shutdown 

Lime Kiln SCBR 189 1 LK SCBR 6 6

Startup and ensure the

minimum scrubber flow rateand differential pressure havebeen established in the Venturi

Scrubber before introducing

mud into the Lime Kiln. Follow

the standard operating

procedures for the startup ofthe lime kiln. After proper

startup, ensure that thescrubber flow rate and

differential pressure aremeeting the minimumrequirements.

The transition from startup tonormal operations will be

considered complete when

these conditions have been

achieved and product is

flowing out and the operating

temperature is >300F. 3 3

Ensure that the minimum

scrubber flow rate and

differential pressure aremaintained during operation ofscrubber. Full operation of theVenturi Scrubber should

continue after fuel firing hasceased, until the flow of limemud has stopped and the

generation of lime has also

ceased (approximately 3 hourslater)

Lime Kiln SCBR 190 1 LK SCBR 30 30

Control device is started up

and required scrubber flow and

differential pressure operatingparameter limits are met

before load is put on Lime Kiln.Ensure minimum Kiln front end

temperature is met before

routing NCG to the Kiln.

Startup is complete once lime

mud begins going to the lime

kiln. 8 8

Control device continues tooperate and meets requiredoperating limits while emissionunit is shut down.

Lime Kiln SCBR 190 1 LK SCBR 30 30

Control device is started up

and required scrubber flow and

differential pressure operatingparameter limits are met

before load is put on Lime Kiln.Ensure minimum Kiln front end

temperature is met before

routing NCG to the Kiln.

Startup is complete once lime

mud begins going to the lime

kiln. 8 8

Control device continues tooperate and meets requiredoperating limits while emissionunit is shut down.

Lime Kiln SCBR 195 1 LK SCBR 1 1

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits) Introduction of mud 1 1

All Control Equipment remainon‐line until source is shut

down. 

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln SCBR 196 1 LK SCBR 18 18

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Hot end temperature reaches1300F; Cold end reaches 450F 18 18

Continue operating scrubberuntil lime production has

ceased 

Lime Kiln SCBR 197 1 LK SCBR 24 24

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

When mud is being sentthrough the kiln 4 4

Lime Kiln SCBR 198 1 LK SCBR 8 8

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

kiln temperature profile is

reached and lime product is

diverted to bucket elevator 3 3

scrubber operates until lime

product is removed from kiln 

Lime Kiln SCBR 199 1 LK SCBR 24 24

Ensure scrubber liquid isflowing prior to igniting fire inthe kiln

Lime mud flow to precoat filter

is greater than 160 gpm for at

least 2 hours 1 1

Continue operating scrubberuntil temperature in LK1 dropsto 200F

Lime Kiln SCBR 201 1 LK SCBR 24 24

Ensure scrubber liquid isflowing prior to igniting fire inthe kiln

Lime mud flow to precoat filteris greater than 60 gpm for at

least 4 hours 1 1

Continue operating scrubberuntil temperature in kiln drops

to 200F

Lime Kiln SCBR 203 1 LK SCBR 24 24

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

mud flow> 75 gpm for 4 hrs

AND kiln hot end temp>1500

deg F for 15 minutes 36 36

Continue operating scrubberuntil kiln completely down

Lime Kiln SCBR 205 1 LK SCBR 24 24

Ensure scrubber liquid is

flowing prior to igniting fire inthe kiln

Lime mud flow to precoat filter

is greater than 150 gpm for at

least 3 hours 1 1

Continue operating scrubberuntil temperature in LK1 dropsto 200F

Lime Kiln SCBR 206 2 LK SCBR 1 1

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

12 hours after normal mud

flow begins introduction intothe kiln 1 1

operate scrubber until

shutdown is complete

Lime Kiln SCBR 207 1 LK SCBR 0.5 0.5

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Scrubber dP leveled out and

lime generated from kiln 4.5 4.5

scrubber recirculation flowmaintained 

Lime Kiln SCBR 226 2 LK SCBR 24 24

Ensure scrubber liquid isflowing prior to igniting fire inthe kiln

Lime mud flow to precoat filterexceeds 50 gpm and bucket

elevator operation commences 1 1

Continue operating scrubberuntil temperature in kiln drops

to 200F

Lime Kiln SCBR 340 1 LK SCBR 20 20

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup Hot end reaches 2000F 4 4

Continue operating scrubberuntil temperature in LK1 dropsto 200F 

Lime Kiln SCBR 525 1 LK SCBR 24 24

scrubber flow is establishedduring startup.

LK feed end temp >400F; lime

flowing from hot end. 3 3

maintain scrubber flow untillime is no longer produced 

Lime Kiln SCBR 600 3 LK SCBR

Cold Startup:

36 Hrs; Hot

Startup: 6 Hrs 36

Scrubber is operational andscrubber parameter limits (flow

and differential pressure) are

achieved processing lime mud.

Target fire end temperature isattained and consistent mud

flow is achieved.

Controlled

Shutdown: 6

Hrs 6

Continue operating scrubberuntil mud is fed out of the kiln,

potential for dusting iseliminated, and ID fan is shutdown.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

Lime Kiln SCBR 610 1 LK SCBR 1 1

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NESHAP parameter limits

(dp)) mud flow and oil on 0.08 0.08

emission unit and control

device operates during

emission unit shutdown (but

not necessarily in compliance

with all NESHAP parameter

limits (dp))

Lime Kiln SCBR 610 1 LK SCBR 1 1

emission unit and control

device operates in compliancewith NESHAP parameter limits

during emission unit startup mud flow and oil on 0.08 0.08

emission unit and control

device operates in compliancewith NESHAP parameter limits

during emission unit shutdown

Lime Kiln SCBR 613 1 LK SCBR 2 2

Per the SSM Plan, Startup andensure the minimum scrubberflow rate and differential

pressure have been establishedin the Venturi Scrubber before

introducing mud into the Lime

kiln. Follow established

operating procedures.

Per the SSM Plan, Veifty thatlime kiln fuel burner is in

operation and is stable. Verifythat the lime kiln's flame safety

system is engaged. Verify the

SO2 system is operating within

normal ranges, as is thetemperature. 3 3

Per the SSM Plan: Full

Operation of the Venturi

Scrubber should continue after

fuel firing ceased, until the flow

of lime mud has stopped andthe generation of lime has also

ceased (approximately 3hours); Verify that gases areno longer being accepted

Lime Kiln SCBR 615 1 LK SCBR 36 36

scrubber flowrate established

during natural gas firing;

pressure drop established just

before lime mud feed is on lime mud feed to lime kiln 12 12

scrubber flowrate is

maintained 

Lime Kiln SCBR

2082285

35 1 LK SCBR 24 24

Ensure scrubber liquid isflowing prior to igniting fire in

the kiln

Lime mud flow to precoat filteris greater than 230 gpm for at

least 3 hours 1 1

Continue operating scrubber

until temperature in kiln drops

to 200F

Lime Kiln

SCBR (NCG

scrubbers pre‐kiln + LK ESP] 151 1 LK ESP 13.5 13.5

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

Lime Kiln and ESP are stable

and meeting normal operationprocess conditions; All LVHCGas Sources have beencollected; regulated HVLC have

been collected, and SOGscollected if steam stripper is in

service 12.5 12.5

Bypass gases to LK4 or shut

down sources of LVHC, HVLC

and SOGs; continue operationof ESP until kiln has stopped

continuous rotation 

Lime Kiln

SCBR (NCG

scrubbers pre‐kiln + LK SCBR] 151 1 LK SCBR 1 1 backup control

Lime Kiln and Scrubber arestable and meeting normaloperation process conditions;

All LVHC Gas Sources have

been collected; regulated HVLC

have been collected, and SOGs

collected if steam stripper is in

service 24 24

Send gases to LK5 or shut

down sources of LVHC, HVLC

and SOGs; continue operation

of scrubber until kiln hasstopped continuous rotation 

Lime Kiln ESP 105 1 LK ESP

12 (coldstartup) 12

Prior to introduction of

collection system gases intothe kiln, the proper kilntemperature must be attained

and exhaust gases must

contain greater than 1%oxygen. The ESP must also beon line and powered up beforekiln startup.

Kiln is operating at a stablerate, incineration interlocks are

met and front end temperature

is at least 1250 degrees F. 6 6

Transfer collection systemgases to the backup kiln before

beginning shutdown of current

kiln.

NDCENDCE DBESP 100 1 RF ESP

7 hours (cold

outage to

burning liquor) 7 Startup on natural gas

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolving

tank is achieved.

~4 hours (take

liquor out but

~3‐4 hours to

burn the "bed"

out using

natural gas) 4

Keep preciptators operatinguntil temperature reduces to a

point that the boiler can be

shutdown.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE DBESP 103 1 RF ESP 8 8

Follow the proper startup

sequence and procedures

outlined in the appropriate

sections for the precipitators.

The No. 5 Recovery Boiler

startup is considered complete

when conditions under the

following SOP have beenestablished: Recovery BoilerNormal Operating Parameters 8 8

During normal shutdowns,

opacity compliance ismaintained until the boiler is

off of oil fire.

NDCE DBESP 104 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Recovery Furnace is operating

at a stable rate and ready for

NCGs when 1) > 30% Liquor

Flow and 2) > 30% Steam

Generation.

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner isremoved.

NDCE DBESP 107 1 RF ESP 8 8

Route emissions to operatingESP after reaching safe

operating temperature

Liquor flow is greater than 180gallons/minute and liquor

recirculation valves are closed 5 5

Route emissions to operatingESP after reaching safe

operating temperature 

NDCE DBESP 108 1 RF ESP

Cold Startup:

11 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 11

Black liquor is introduced to

the recovery furnace only afterthe ESP is brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 10 Hrs) 10

ESP remains operational until

all black liquor is pulled fromthe recovery furnace and thelast oil or gas burner isremoved.

NDCE DBESP 109 2 RF ESP 10 10

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Begin flow of liquor through

injection nozzles 12 12

emission unit and contol deviceoperates in compliance with

NSPS and NESHAP parameter

limits during emission unit

shutdown.

NDCE DBESP 112 1 RF ESPNDCE DBESP 114 1 RF ESP 6 6

Startup ESP prior to beginning

startup of the RecoveryFurnace

Steam flow rate >100,000lbs/hr 16 16

Continue operating ESP untilRecovery Furnace is shutdown

NDCE DBESP 115 1 RF ESP 12 12

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Boiler in the Steam Header and

Smelt Flow 0.5 0.5

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during

shutdown 

NDCE DBESP 117 1 RF ESP 12 12 Operate ESP during Start‐UP

Liquor flow to the boiler is

established 12 12

the control device is operatedduring emission unit shutdown

NDCE DBESP 119 1 RF ESP 8 8

ESP is powered up prior toinitial fire in recovery furnace

establishment of a stablefurnace bed at the targetedarea and height 16 16

ESP is the last device shut

down

NDCE DBESP 120 1 RF ESP 18 18

Operate a minimum of two

precipitator cells prior to firingany oil. As load dictates add

additional cell.

Stable firing of a minimum 160

kpph of liquor solids (typically

12hrs) 24 24

Operate precip until all fuelsare out of the boiler

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE DBESP 130 1 RF ESP

Cold Startup: 8

to 12 Hrs (Time

elapsed from

initial auxiliary

fuel firing until

black liquor is

introduced);

Hot Startup: 0.5

to 2 Hrs 12

Emission unit and control

device operate in compliance

with NESHAP parameter limits

during emission unit startup.

SOP: ESP is operational (Power

is applied to tranformerrectifiers after ESP penthouse

heaters have been on 4 to 6hours) before black liquor isintroduced to the recoveryfurnace.

Black liquor is introduced to

the boiler, a stable funace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from reducing

liquor firing

until furnace

bed is burned

out/smelted

out): 5 to 7 Hrs 7

SOP: ESP remains operational

until all black liquor is pulled

from the recovery furnace andthe bed is burned out/smeltedout (recovery furnace isshutdown).

NDCE DBESP 131 1 RF ESP 13 13

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Steam Flow > 300 klb/hr andO2< 10%. 7 7

Continue to operate controldevice until unit is down

NDCE DBESP 133 1 RF ESP 16 16

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

The recovery boiler

combustion is selfsustaining on

black liquir, the unit is

generating steam, smelting and

producing acceptable green

liquor quality 8 8

NDCE DBESP 135 1 RF ESP 25 25

One precipitator or more (if

needed) is operating prior tothe start of fuel firing in the

Recovery Boiler.

The boiler is firing black liquorat a stable and continuous rateand oil firing has stopped. 7 7

One precipitator or more (if

needed) are operated duringthe shutdown of the RecoveryBoiler.

NDCE DBESP 136 1 RF ESP 3 3

Operate control equipment at

all times emission unit is not

down

Black liquor flow greater than200 gpm for 3 hours 1 1

Continue operating APCE untilunit is down

NDCE DBESP 140 1 RF ESP

NA ‐ applicable emission andparameter limits not expected

to be exceeded during startup

Black Liquor purge credit is

established and Precipitator

Fields 1‐4 on the east or westside of the precipitator must beenergized.

Ensure that the electrostatic

precipitator fields 1‐4 on the

east or the west side of the

precipitator is energized untilthe boiler is off liquor.

NDCE DBESP 142 1 RF ESP

~9 hrs (Hot),

~12 Hrs (Cold) 12

Control device is turned on

prior to emission unit startup.

The startup period ends when

green liquor is produced in the

associated dissolving tank andpumped for five (5)consecutive hours understeady state conditions.

~16 hrs (Hot),

~84 hrs (Cold) 84

Control device is operated

during emission unit shutdown

NDCE DBESP 147 2 RF ESP 6 6

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Steam Temp and Pressure LimitMet 9 9

emission unit and control

device operates duringemission unit shutdown 

NDCE DBESP 148 1 RF ESP 6 6

emission unit and control

device operates in complianceparameter limits duringemission unit startup

When emission unit is firing

black liquor 4 4

emission unit and control

device operates in complianceparameter limits during

emission unit shutdown 

NDCE DBESP 148 1 RF ESP 6 6

emission unit and control

device operates in complianceparameter limits duringemission unit startup

When emission unit is firing

black liquor 4 4

emission unit and control

device operates in complianceparameter limits duringemission unit shutdown 

NDCE DBESP 149 1 RF ESP 12 12

Operate all APCDs during

startup

Normal steam rate and nolonger burning auxiallary fuel 8 8

Operate all APCDs duringshutdown

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE DBESP 150 1 RF ESP 36 36

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits) Black liquor flow at setpoint 24 24

Continue operating

electrostatic precipitator until

CREC‐1 completes shutdown

NDCE DBESP 151 1 RF ESP 16 16

Ensure ESP operation is stable

and all apparent problems

have been addressed

Once boiler is up to operating

steam pressure andsuperheater loops are clear theRecovery Boiler may be placed

on‐line 6 6

Stop all black liquor flow into

the recovery boiler andmonitor opacity during theshutdown process

NDCE DBESP 155 1 RF ESP 24 24

Ensure ESP is operating prior to

start‐up

Liquor flow greater than 40gpm for 15 minutes and

supplemental fuel oil flow

ceases 5 5

ESP is operated until shutdown

is complete

NDCE DBESP 156 1 RF ESP 5 5 follow SSM manual procedures

Startup is marked bycompletely cold furnace

temperature till liquor is fired 5 5 follow SSM manual procedures

NDCE DBESP 162 2 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor is

introduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and the

last oil or gas burner isremoved.

NDCE DBESP 164 1 RF ESP 5.7 5.7

black liquor burning does not

start until ESP TR sets have

been energized for 1 hour after 5 hour warm up curve 2 2

keep ESP energized during 2hour bed burn down 

NDCE DBESP 164 1 RF ESP 7.7 7.7

black liquor burning does not

start until ESP TR sets have

been energized for 1 hour after 7 hour warm up curve 2 2

keep ESP energized during 2hour bed burn down 

NDCE DBESP 165 2 RF ESP

Cold Startup:

12 Hrs (time

elapsed from

initial firing of

fosil fuel untilblack liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved.

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 8 Hrs 8

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner is

removed.

NDCE DBESP 173 1 RF ESP

Cold startup:

12 hours (time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot startup: 2

hours 12

A portion of or all three

precipitator cells areoperational prior tointroducing # 6 fuel oil or black

liquor to the recovery furnace.

Black liquor is introduced to

the recovery furnace, a stablefurnace bed is obtained, and aconsistent smelt flow to the

dissolving tank is achieved.

Controlled

shutdown: 8

hours 8

The ESP remains operational

until all black liquor is pulled

from the recovery furnace and

the last oil burner is removed.

NDCE DBESP 174 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after the

ESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolving

tank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner isremoved.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE DBESP 175 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Black liquor isintroduced to the recovery

furnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner isremoved.

NDCE DBESP 176 1 RF ESP 8 8 Flame proven in furnace oil 12 12

NDCE DBESP 177 1 RF ESP 8‐12 hours 12

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Normal operation begins whennormal black liquour firing

rates are reached and thefurnace operation is stable. 8 ‐ 12 hours 12

Control device (EU0804ESP)

continues to operate normally

during the furnace shutdown

process.

NDCE DBESP 178 2 RF ESP

Cold Startup:

~12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: ~2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor is

introduced to the recovery

furnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved.

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): ~6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner is

removed.

NDCE DBESP 179 1 RF ESP 5 5

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Auxilliary fuel is shut off andliquor is being fed to the

furnace with the intent of

producing smelt 8‐16 16

Emission unit control device

continues to operate during

shutdown.

NDCE DBESP 180 1 RF ESP 7 7

Operate ESP and CEMS during

boiler startup

main 850 psi header pressure is

obtained at temperature of

825 F, superheaters cleared 4 4

Operate ESP and CEMS during

boiler shutdown

NDCE DBESP 181 1 RF ESP 7 7

ESP operational prior tostartup; applicable emission

limits not expected to beexceeded during startup gas out (firing BLS only) 7 7

ESP operational until shutdowncomplete; applicable emissionlimits not expected to be

exceeded during shutdown 

NDCE DBESP 182 1 RF ESP 12 12

The emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup. Practice

good combustion practices and

burns low sulfur oil

Stop the burning of oil and

begin burning black liquor 6 6

Practice good combustion

practices and burn low sulfur

oil 

NDCE DBESP 183 1 RF ESPNDCE DBESP 186 1 RF ESP 10 10 ESP must be in compliance

Startup is considered complete4 hours after black liquor is

fired 12 12 ESP must be in compliance

NDCE DBESP 190 3 RF ESP 30 30

Control device is started up

with emission unit startup.

Startup is complete 24 hours

after black liquor has started

burning 36 36

NDCE DBESP 195 1 RF ESP 8 8

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits) Boiler at Pressure (850 psi) 18 18

All Control Equipment remainon‐line until source is shut

down.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE DBESP 196 2 RF ESP 6.5 6.5

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Combustion temperature is

reached 10 10

Continue operating ESP until

smelt bed ceases burning 

NDCE DBESP 198 1 RF ESP 39 39

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

emission unit firing on black

liquor only (no natural gas) andsteam load is stable with range 39 39

ESP operates until all blackliquor guns are removed fromfurnace

NDCE DBESP 199 1 RF ESP 12 12

ESP is operating once black

liquor is introduced intorecovery furnace

Black liquor flow to recovery

furnace exceeds 160 gpm for at

least 3 hours and steamproduction exceeds 200,000lb/hr for at least 3 hours 6 6

Continue operatingelectrostatic precipitator untilafter liquor firing ceases

NDCE DBESP 200 1 RF ESP 5 5

Follow appropriate pre‐start/startup checklist. ESP

charged and operational.

Black liquor solids and steamload at appropriate operating

range and the no auxiliary fuel

in the firing configuration. 6 6

Follow the appropriateshutdown checklist. Control

device may continue tooperate throughout shutdown.

NDCE DBESP 201 1 RF ESP 10 10

Ensure electrostatic

precipitator is powered upbefore introducing black liquor

into recovery furnace

Black liquor line pressure to

recovery furnace exceeds 10

psig for at least 60 minutes 1 1

Continue operatingelectrostatic precipitator untilblack liquor firing isdiscontinued

NDCE DBESP 202 1 RF ESP

2009 average

startup time is

3.9 hours ‐

Startup is

considered to

begin when

liquor is first

added to the

Recovery

Furnace,

Startup for

NESHAP is not

considered the

time required

when warming

up on natural

gas so liquor

can be added

although CEMS

are oper 3.9

emission unit and control

device operates in compliance

with NSPS and NESHAP

parameter limits duringemission unit startup

All four liquor guns are in

Recovery furance and all six gasguns (for startup) are out of

the Recovery furnace.

2009 average

shutdown time

is 1.5 hours ‐  

Recovery

Furnace shut

down is

considered

complete when

no more liquor

is entering

Recovery

Furnace. 1.5

Continue operatingprecipitator unless need towork on preciptitator evenwhen emission unit down.

Wait until after black liquorguns are out of precipitator

before shutting down

precipitator.

NDCE DBESP 203 1 RF ESP 8 8

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

black liquor flow to furnace >

30 gpm for 3 hrs 24 24

Continue operating ESP untilfurnace is completely shutdown

NDCE DBESP 203 1 RF ESP 8 8

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits during

emission unit startup

black liquor flow to furnace >75 gpm for 3 hrs 24 24

Continue operating ESP untilfurnace is clear

NDCE DBESP 207 1 RF ESP 4.5 4.5

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup Boiler producing steam 5.5 5.5

Transformer rectifier readings

at target.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE DBESP 240 2 RF ESP

4 ‐ 8 hours if

cold startup

from planned

outage 8

Emission unit and control

device operate during emissionunit startup, applicableemission and parameter limits

not expected to be exceeded

during startup.

Recovery Furnace is firing black

liquor solids at normal rates,with stable smelt bed andsmelt generation rates.

4 ‐ 8 hours if

shutting down

to cold

conditions for

planned outage 8

Control device continues tooperate and meet required

operating limits until afterfiring of black liquor solids in

the Recovery Furnace hasceased.

NDCE DBESP 242 1 RF ESP 4 4 Ensure all ESP fields are on

when full strength green liquor

is pumped to the recausticizingoperation. 6 6

Precipitators are operational

during boiler shutdown.

NDCE DBESP 243 1 RF ESP 10 10

emission unit and control

device operates in compliancewith NSPS and NESHAP

parameter limits duringemission unit startup

Operating rate reaches 3.0

MMlbs black liquor solids/day

or greater 12 12

Continue to operateprecipitator shutdown

complete

NDCE DBESP 243 1 RF ESP 10 10

emission unit and control

device operates in compliancewith NSPS and NESHAP

parameter limits duringemission unit startup

Operating rate reaches 4.8

MMlbs black liquor solids/day

or greater 12 12

Continue to operateprecipitator shutdown

complete

NDCE DBESP 340 1 RF ESP 5.5 5.5

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup Liquor in boiler 1.5 1.5

Continue operating ESP and

SDT scrubber until smelt bedburned out. 

NDCE DBESP 531 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Black liquor isintroduced to the recovery

furnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner is

removed.

NDCE DBESP 600 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after the

ESP internal temperature

reaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolving

tank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational until

all black liquor is pulled fromthe recovery furnace and thelast oil or gas burner isremoved.

NDCE DBESP 606 1 RF ESP 12 12

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Stable operation of furnace onBLS at >70% nominal rate 8 8 

NDCE DBESP 606 1 RF ESP 12 12

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Stable operation of furnace on

BLS at >70% nominal rate 8 8 

NDCE DBESP 610 1 RF ESP cold 6; warm 1 6

emission unit and control

device operates in compliancewith NESHAP parameter limits

during emission unit startup

boiler up to 100 gpm of liquor

flow 4 4

emission unit and control

device operates in compliancewith NESHAP parameter limits

during emission unit shutdown

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE DBESP 610 1 RF ESP cold 6; warm 1 6

emission unit and control

device operates in compliance

with NESHAP parameter limits

during emission unit startup

boiler up to 150 gpm of liquor

flow 5 5

emission unit and control

device operates in compliance

with NESHAP parameter limits

during emission unit shutdown

NDCE DBESP 615 1 RF ESP 8 8

esp is turned on prior to black

liquor feed to the recovery

furnace

black liquor entering recoveryfurnace 6 6

esp is left on as long aspossible

NDCE DBESP 617 1 RF ESP 6 6

control device is fullyoperational prior to boiler

startup steam flow reaches 80,000 pph 2.5 2.5

control device is fully

operational until shutdown is

complete

NDCE DBESP

2082285

35 1 RF ESP 12 12

Ensure electrostatic

precipitator is powered upbefore introducing black liquor

into recovery furnace

At least 4 liquor guns have

been placed into service 1 1

Continue operatingelectrostatic precipitator untilblack liquor firing isdiscontinued

NDCE DBESP

2082285

35 1 RF ESP 12 12

Ensure electrostatic

precipitator is powered upbefore introducing black liquor

into recovery furnace

At least 8 liquor guns havebeen placed into service 1 1

Continue operatingelectrostatic precipitator untilblack liquor firing isdiscontinued

NDCE DBESP/SCBR 185 1 RF ESP/SCBR 2 2

NA ‐ applicable emission andparameter limits not expected

to be exceeded during startup

Liquor firing rate is stable and

operating parameters (excessoxygen, TRS, steam rate) arestable 1 1

Emission control devicescontinue to operate until liquorfiring has stopped

NDCE DBESP‐WPR 102 1 RF ESP 60 60

One or more precipitator

chamber is partially poweredup prior to igniting fuel oilburners at beginning of coldstartup. Note that operating RB‐

ESP at low temperature is

contrary to the control device

manufacturere'srecommendation that theprecipitator not be energized

until chamber temperatures

exceed the dewpoint (>230F

for fuel oil firing on cold

startup), due to risk of controlequipment damage fromarcing/sparking and corrosion

given the cold, moistconditions following a cold

shutdown. One or more

precipitator chamber isoperating at full power before

black liquor solids firing begins.

Firing black liquor in at least

three of four nozzles, smeltflowing to dissolver, andauxiliary fuel oil burners

switched off 24 24

Continue operating RB‐ESPuntil fire out of RB10.

NDCE DBESP‐WPR 105 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Black liquor is

introduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational until

all black liquor is pulled fromthe recovery furnace and the

last oil or gas burner isremoved.

NDCE DBESP‐WPR 111 1 RF ESP 12 12

emission unit and control

device operates during

emission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Recovery boiler has reachedsteady state operations and

steam is being generated. 14 14

Emissions controls remain inoperation until shut‐down has

been completed.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE DBESP‐WPR 132 2 RF ESP 12 12

Control device is partially

energized prior to EU startup.

Control device is completely

operational prior to the

introduction of black liquor.

Last oil gun is out and steady

burning liquor. 8 8

Control device remains

operational until the EU is

shutdown

NDCE DBESP‐WPR 137 1 RF ESP 6 6 FOLLOW SSM PLAN

Liquor in boiler and optimized

excess oxygen after boiler hasstabilized: Natural gas flow >0.5 kcfm on a sustanied basisand East and North Liquor Gun

pressure > 15 psig and StackO2 is < or = 18% on a sustained

basis. 38 38 FOLLOW SSM PLAN

NDCE DBESP‐WPR 137 1 RF ESP 6 6 FOLLOW SSM PLAN

Liquor in boiler and optimizedexcess oxygen after boiler has

stabilized: Natural gas flow >300 scfm on a sustanied basis

and East and West Liquor Gun

pressure > 15 psig and StackO2 is < or = 18% on a sustainedbasis. 25 25 FOLLOW SSM PLAN

NDCE DBESP‐WPR 138 1 RF ESP 2 2

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

Energizing ESP fields,

commencement of liquor firing 12 12

liquor firing ceases 2 hours

prior to de‐energizing the ESP

NDCE DBESP‐WPR 146 1 RF ESP 10 10

ESP is to be in operation prior

to introduction of black liquorin the recovery furnace

Introdution of black liquor to

the recovery furnace 1 1

Control device remains inoperation until after black

liquor addition has stopped

NDCE DBESP‐WPR 184 1 RF ESP 10 10

Ensure ESP is energized and

performing properly prior to

lighting a burner in therecovery. When steam is generated. 6 6

Continue operating ESP until

the fire is out in the firebox.

NDCE DBESP‐WPR 184 1 RF ESP 8 8

Ensure ESP is energized and

performing properly prior to

lighting a burner in the

recovery. When steam is generated. 6 6

Continue operating ESP untilthe fire is out in the firebox.

NDCE DBESP‐WPR 525 1 RF ESP 24 24

Precipitator is powered duringstartup. BLS firing is established 3 3

Maintain precipitator power

until smelt bed is burned out

NDCE

DBESP‐WPR/DBESP/DBESP 139 1 RF ESP 4 4

ESP's are in operation prior to

firing black liquor in the boiler.

Target black liquor flow hasbeen reached, and black liquor

recirculation is off. 4 4

ESPs are in operation until no

fuel is ignited in the boiler

NDCE

DB‐WBESP [2‐

sided dry and

wet] 200 1 RF ESP 7 7

Follow appropriate pre‐start/startup checklist. ESP

charged and operational.

Black liquor solids and steamload at appropriate operating

range and the no auxiliary fuel

in the firing configuration. 8 8

Follow the appropriateshutdown checklist. Control

device may continue to

operate throughout shutdown.

NDCE SCBR 153 1 RF SCBRNDCE SCBR 159 1 RF SCBR 8 8

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Steam drum reaches 600 lb of

steam pressure 5 5

continued operation of thescrubber

NDCE WBESP 116 1 RF ESP

Cold Startup:

~12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: ~2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor isintroduced to the recovery

furnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): ~6 Hrs 6

ESP remains operational untilall black liquor is pulled from

the recovery furnace and thelast oil or gas burner isremoved.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE WBESP 126 1 RF ESP

Cold startup:

16 hours (time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot startup: 6

hours 16

Several TRs per precipitator are

operational during start up and

all TRs energized prior tointroducing black liquor to the

recovery furnace.

Black liquor is introduced to

the recovery furnace, a stable

furnace bed is obtained, and aconsistent smelt flow to thedissolving tank is achieved andfuel oil firing ceases.

Controlled

shutdown: 12

hours 12

The ESP remains operational

until all black liquor is pulled

from the recovery furnace andthe last oil burner is removed.

NDCE WBESP 127 1 RF ESP 6 6

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

Recovery Boiler firing only onBLS and at a mimimum rate of

135 Klbs BLS/hr 8 8

NA ‐ applicable emission andparameter limits not expected

to be exceeded during

shutdown

NDCE WBESP 157 1 RF ESP 8 8

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup Online and Liquor in Boiler 8 8

NA ‐ applicable emission andparameter limits not expected

to be exceeded during

shutdown 

NDCE WBESP 163 1 RF ESP

12 (Cold

Startup) 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESP

warm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolvingtank is achieved.

6 (Cold

Shutdown) 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner is

removed.

NDCE WBESP 169 2 RF ESP

Cold Startup: 6

Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 1‐

6 Hrs 6

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches target temperature.

Fossil fuel is burned exclusivelyduring ESP warm‐up. Black

liquor is introduced to therecovery furnace only after theESP is brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolving

tank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 4 Hrs 4

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and thelast oil or gas burner is

removed.

NDCE WBESP 172 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor isintroduced to the recoveryfurnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolving

tank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational until

all black liquor is pulled fromthe recovery furnace and thelast oil or gas burner is

removed.

NDCE WBESP 172 1 RF ESP

Cold Startup:

12 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Power is applied to the

transformer rectifiers after theESP internal temperaturereaches 200  ̊F. Fossil fuel is

burned exclusively during ESPwarm‐up. Black liquor isintroduced to the recovery

furnace only after the ESP is

brought on‐line.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

ESP remains operational untilall black liquor is pulled fromthe recovery furnace and the

last oil or gas burner isremoved.

NDCE WBESP 181 1 RF ESP 7 7

ESP operational prior tostartup; applicable emission

limits not expected to beexceeded during startup gas out (firing BLS only) 7 7

ESP operational until shutdowncomplete; applicable emissionlimits not expected to be

exceeded during shutdown 

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

NDCE WBESP 189 1 RF ESP 8 8

When firing four liquor nozzlesare in service energize the

north and south chamber

precipitator fields.Verify the ESP is heated and

the ESP T‐R sets are powered.

Verify that the ESP control

system is operating normally.

Ensure the ESP ash recovery ysystem is operating normally.Ensure the stack opacity

monitoring system is operatingnormally.Ensure the boiler is operating

on the supplemental fuelburners and producing steam.(100,000 lbs STM before

injecting black liquor)

Verify that a pilot or auxiliaryfuel burner is operating at the

liquor firing nozzles.

Black liquor flow to boiler

reaches 350 GPM (Circulation

Valves Closed) 6 6

Full operation of the ESP and

Opacity meter(s) shouldcontinue after black liquorfiring has ceased, until the flow

of smelt from the spouts has

stopped and the generation of

full strength green liquor has

also ceased.

BLRBAC and standard

operating procg proceduresmust be followed in shutdownof the Chemical RecoveryFurnace.

During shutdown, manage

fossil fuel burning and adjust

combustion air to maintainstack gas opacity less than 20%

during the shutdown period.

Full operation of the ESP and

Opacity meter(s) shouldcontinue after black liquorfiring has ceased, until the flow

of smelt from the spouts has

stopped and the generation of

full strength green liquor has

also ceased.

BLRBAC and standard

operating procedures must befollowed in shutdown of the

NDCE WBESP 226 1 RF ESP 12 12

ESP is operating properly

before black liquor is

introduced into recoveryfurnace

Commencement of operation

of green liquor pump from

smelt dissolving tank 4 4

Continue operatingelectrostatic precipitator untilafter liquor firing ceases

NDCE WBESP 226 1 RF ESP 6 6

ESP is operating properly

before black liquor is

introduced into recovery

furnace

Commencement of operationof green liquor pump from

smelt dissolving tank 4 4

Continue operating

electrostatic precipitator untilafter liquor firing ceases

NDCE DBESP 181 1 RF ESP 7 7

ESP operational prior tostartup; applicable emission

limits not expected to be

exceeded during startup gas out (firing BLS only) 7 7

ESP operational until shutdown

complete; applicable emission

limits not expected to beexceeded during shutdown 

NDCE WBESP 181 1 RF ESP 7 7

ESP operational prior tostartup; applicable emission

limits not expected to be

exceeded during startup gas out (firing BLS only) 7 7

ESP operational until shutdowncomplete; applicable emissionlimits not expected to beexceeded during shutdown 

SDT (Kraft)SDT (Kraft) INC_RF 104 1 SDT INC_RF

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Vents back to Recovery

Furnace

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Emissions are vented to therecovery furnace until all black

liquor is pulled from therecovery furnace, the furnacebed is burned out and smelt is

no longer flowing.

SDT (Kraft) OTH 145 1 SDT OTH 2 2

NA ‐ applicable emission andparameter limits not expected

to be exceeded during startup When smelt flow begins 0.5 0.5 Shut down recirculation pumps

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) OTH 157 1 SDT OTH 8 8

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup Boiler starts smelting 6 6

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during

shutdown 

SDT (Kraft) OTH 171 1 SDT OTH 2 2

Ensure control equipment is

operational as early as possiblein startup procedure.

Document steps for accurateSU through SSM plan and

standard operating procedures.

Startup ends when smelttemperature is greater than

150 deg F. 2 2

Ensure control equipment is

operational as long as possiblein shutdown procedure.

Document steps for specific SDthrough SSM plan and standardoperating procedures.

SDT (Kraft) OTH 206 2 SDT OTH 4 4

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

When on specification greenliquor is pumped from thesmelt tank for one hour or

eight hours from completion ofstart up of the associated

recovery furnace.. 4 4

emission unit and control

device operates in compliance

with all NSPS/NESHAP

parameter limits duringshutdown 

SDT (Kraft) PBSCBR 138 1 SDT SCBR 1 1

NA ‐ applicable emission andparameter limits not expected

to be exceeded during startup

Startup ends when thepressure drop and scrubberflow parameters are met(pressure drop >5.5 inches,

flow >75 gpm) 12 12

SDT (Kraft) PBSCBR 140 1 SDT SCBR

The smelt dissolving ventscrubber fan is to remain on.The lower flow to the smelt

dissolving vent scrubbewr must

be greater than 125 gpm. The

delta P across the scrubber

must be greater than 8 inches

of water.

Black Liquor purge credit is

established and smelt

dissolving vent scrubber fan ison, flow to lower nozzles is

greater than 125 gpm, and the

delta P across the scrubber is

greater than 8 inches of water.

The smelt dissolving ventscrubber fan is to remain on.The lower flow to the smelt

dissolving vent scrubbewr must

be greater than 125 gpm. Thedelta P across the scrubber

must be greater than 8 inches

of water.

SDT (Kraft) PBSCBR 154 1 SDT SCBR 4 4

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

when the weak wash flow in

and the green liquor flows out

have stabilized 4 4

NA ‐ applicable emission andparameter limits not expected

to be exceeded during

shutdown 

SDT (Kraft) PBSCBR 155 1 SDT SCBR 1 1

Ensure scrubber fan is on and

flowrate is greater than 91 gpm

prior to start‐up

Liquor flow greater than 40gpm for 60 minutes 3 3

Scrubber fan is left on andflowrate is kept above 91 gpmuntil shutdown is complete.

SDT (Kraft) PBSCBR 156 3 SDT SCBR 5 5 follow SSM manual procedures 5 5 follow SSM manual procedures

SDT (Kraft) PBSCBR 169 2 SDT SCBR

Cold Startup: 8

Hrs (Time

elapsed after

liquor is

introduced and

smelt is

flowing); Hot

Startup: 3‐8 Hrs 8

Scrubber is operational andscrubber parameter limits

(weak wash/water flow and fanamps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 4 Hrs 4

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out and

smelt is no longer flowing.

SDT (Kraft) PBSCBR 185 1 SDT SCBR 2.5 2.5

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

Smelt Dissolver tank is at

normal operating temperaturefollowing liquor firing 2 2

Dissolver scrubber continues to

operate until smelt run off has

stopped; dissolver scrubber

bypass damper remains closed

until smelt run off has stopped

SDT (Kraft) PBSCBR 207 1 SDT SCBR 2 2

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Smelt flow to smelt dissolving

tank starts 1 1

Smelt dissolving tank scrubberflow maintained

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) PBSCBR 617 1 SDT SCBR 3 3

control device is fullyoperational prior to process

startup

smelt flows from recoveryboiler spouts 4 4

control device is fullyoperational until shutdown is

complete 

SDT (Kraft)

PBSCBR/INC_RF 108 1 SDT SCBR

Cold Startup:

11 Hrs (Time

elapsed from

initial firing of

fossil fuel until

black liquor is

introduced);

Hot Startup: 2

Hrs 11

Scrubber is operational before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 10 Hrs 10

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 100 1 SDT SCBR

7 hours (cold

outage to

burning liquor) 7

Emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved.

~4 hours (take

liquor out but

~3‐4 hours to

burn the "bed"

out of the

recovery

furnace using

natural gas) 4

Once black liquor is removed

from the boiler the scrubberspray flow is maintained

durning the time the boiler bed

is being burned out using

natural gas.

SDT (Kraft) SCBR 102 1 SDT SCBR 12 12

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Dissolver reaches andmaintains operatingtemperature and density

setpoints 24 24

Continue operating scrubberuntil smelt flow to SDTV10

stops

SDT (Kraft) SCBR 105 1 SDT SCBR

SDT (Kraft) SCBR 105 1 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameterlimits(weak wash flow and fanamps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out and

smelt is no longer flowing.

SDT (Kraft) SCBR 107 1 SDT SCBR 10 10

Start scrubber fan andrecirculation pump prior tofeeding smelt into the tank

Liquor flow is greater than 180

gallons/minute and liquor

recirculation valves are closed 8 8

Run scrubber fan and

recirculation pump until smeltis no longer introduced intothe tank

SDT (Kraft) SCBR 109 2 SDT SCBR 10 10

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Begin flow of liquor throughinjection nozzles 12 12

emission unit and contol device

operates in compliance with

NSPS and NESHAP parameter

limits during emission unit

shutdown.

SDT (Kraft) SCBR 112 1 SDT SCBR

SDT (Kraft) SCBR 114 1 SDT SCBR 2 2

Startup scrubber prior to

beginning startup of the Smelt

Dissolving Tank

Black liquor firing is established

in Recovery Furnace andScrubber is fully operational 16 16

Continue operating scrubberuntil Smelt Dissolving Tank isshutdown

SDT (Kraft) SCBR 115 1 SDT SCBR 12 12

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Boiler in the Steam Header and

Smelt Flow 0.5 0.5

NA ‐ applicable emission andparameter limits not expected

to be exceeded during

shutdown 

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR 116 1 SDT SCBR

Cold Startup:

~12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameterlimits(weak wash flow and fanamps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): ~6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 117 1 SDT SCBR 12 12

Operate Scrubber during Start‐

UP

Liquor Flow to Smelt Tank,Liquid Flow to scrubber,Scrubber Fan On and Bypassshut 12 12

the control device is operated

during emission unit shutdown

SDT (Kraft) SCBR 119 2 SDT SCBR 8 8

Flow is established to Ducon

Scrubber before liquor feed to

the furnace begins

smelt dissolving tank liquordissolved solids reaches target

concentration at target

operating rate 16 16

Ducon scrubber is the lastdevice shut down

SDT (Kraft) SCBR 120 1 SDT SCBR 18 18

Operate the scrubber prior toany liquor being fired in RF5

Stable firing of a minimum 160

kpph of liquor solids (typically

12hrs) 24 24

Operate scrubber until no

more smelt is received from

RF5

SDT (Kraft) SCBR 121 2 SDT SCBR 8 8

Ensure absorber and impactor

scrubber liquid is flowing at orabove minimum scrubber flowestablished in the NESHAP MM

initial performance test and ator above minimum pH

Reaching target tank level and

target scrubber parameters 6 6

Ensure absorber and impactorscrubber liquid is flowing at orabove minimum scrubber flowestablished in the NESHAP MMinitial performance test and ator above minimum pH until the

potential to emit has ceasedfrom the smelt dissolving tank

SDT (Kraft) SCBR 124 2 SDT SCBR 4 4

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup Begin smelting 2 2 continue operating scrubber 

SDT (Kraft) SCBR 126 1 SDT SCBR

Cold startup: 8

hours (time

elapsed from

black liquor isintroduced to

smelting and

control device

oper); Hot

startup: 4

hours 8

Scrubber pump is operationaland scrubber only scrubberliquid supply is achieved before

black liquor is introduced to

the recovery furnace.

Start up of the Scrubber ID fan

and compliance with all CPMSrequirements.

Controlled

shutdown: 8

hours 8

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 127 1 SDT SCBR 8 8

emission unit and control

device operates during

emission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Green Liquor reachesacceptable strength forpumping to Caustic Area 8 8

emission unit and control

device operates duringemission unit shutdown (but

not necessarily in compliance

with all NSPS/NESHAP

parameter limits)

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR 130 1 SDT SCBR

Cold Startup: 8

to 12 Hrs (Time

elapsed from

initial auxiliary

fuel firing until

black liquor is

introduced);

Hot Startup: 0.5

to 2 Hrs 8

Emission unit and control

device operate in compliance

with NESHAP parameter limits

during emission unit startup.

SOP: Scrubber is operational(Required Scrubber weak washmakeup flow, weak wash

recycle flow, and scrubber fanamps are attained) beforebliquor is introduced to therecovery furnace.

Black liquor is introduced to

the boiler, a stable funace bed

is obtained, and a consistent

smelt flow to the dissolving

tank is achieved

Controlled

Shutdown

(Time elapsed

from reducing

liquor firing

until furnace

bed is burned

out/smelted

out): 5 to 7 Hrs 7

SOP: Scrubber remainsoperational until all black

liquor is pulled from therecovery furnace and the bed isburned out/smelted out

(recovery furnace isshutdown).

SDT (Kraft) SCBR 130 2 SDT SCBR

Cold Startup: 8

to 12 Hrs (Time

elapsed from

initial auxiliary

fuel firing until

black liquor is

introduced);

Hot Startup: 0.5

to 2 Hrs 12

Emission unit and control

device operate in compliance

with NESHAP parameter limits

during emission unit startup.

SOP: Scrubber is operational(Required Scrubber weak washmakeup flow, weak wash

recycle flow, and scrubber Δ pressure are attained) beforeblack liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable funace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from reducing

liquor firing

until furnace

bed is burned

out/smelted

out): 5 to 7 Hrs 7

SOP: Scrubber remainsoperational until all black

liquor is pulled from therecovery furnace and the bed isburned out/smelted out

(recovery furnace isshutdown).

SDT (Kraft) SCBR 131 1 SDT SCBR 2 2

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Any black liquor spray gun in >

2 hours 5 5

Continue to operate controldevice until unit is down 

SDT (Kraft) SCBR 131 1 SDT SCBR 2 2

emission unit and control

device operates in compliancewith State and NESHAP

parameter limits duringemission unit startup

Any black liquor spray gun in >

2 hours 2 2

Continue to operate controldevice until unit is down 

SDT (Kraft) SCBR 132 2 SDT SCBR 1 1

Control device is started up

and meets required operatingparameter limits before

emission unit is started up.

Last oil gun is out and steady

burning liquor. 8 8

Control device remains

operational until the EU isshutdown

SDT (Kraft) SCBR 133 2 SDT SCBR 16 16

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

The recovery boiler

combustion is selfsustaining onblack liquir, the unit isgenerating steam, smelting and

producing acceptable green

liquor quality 8 8

SDT (Kraft) SCBR 135 1 SDT SCBR

SDT (Kraft) SCBR 135 1 SDT SCBR 6 6

The scrubber is operating prior

to smelt from the boiler is

added to the tank .

Black liquor is firing in theboiler in a continuous and

stable manner. 4 4

The scrubber is operatedduring the shutdown of the

smelt tank.

SDT (Kraft) SCBR 136 1 SDT SCBR 3 3

Operate control equipment atall times emission unit is not

down

Black liquor flow to RB10

greater than 200 gpm for 3

hours 1 1

Continue operating APCE untilunit is down

SDT (Kraft) SCBR 137 1 SDT SCBR 6 6 FOLLOW SSM PLAN

All gun doors OPEN in Recovery

Furnance and Black Liquor

Feed Flow > 250 gpm 38 38 FOLLOW SSM PLAN 

SDT (Kraft) SCBR 137 1 SDT SCBR 6 6 FOLLOW SSM PLAN

All gun doors OPEN in Recovery

Furnance and Black Liquor

Feed Flow > 75 gpm 25 25 FOLLOW SSM PLAN 

SDT (Kraft) SCBR 139 1 SDT SCBR 4 4

Scrubber is running prior tosmelt flow to the dissolvingtank.

Quality green liquor is first

produced 4 4

Scrubber is operating until

smelt no longer exits thespouts flowing to thedissolving tank.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR 142 1 SDT SCBR

~7 hrs (Hot), ~7

Hrs (Cold) 7

Control device is turned on

prior to emission unit startup.

The startup period ends when

liquor is fired in the No. 3

Recovery Furnace for five (5)consecutive hours under

steady‐state conditions. ~15 hrs (Cold) 15

Control device is operated

during emission unit shutdown

SDT (Kraft) SCBR 143 3 SDT SCBR

Hot or Cold: 1‐4

hours AFTER

Recovery

Furnace is up 4

Scrubber is operational and

monitor Scrubber recirculation

and makeup flow and pH

Confirm steady state operating

for 60 minutes and green

liquor density is sufficient to

pump out

Hot or cold: 4‐6

hours 6

Scrubber remains in operation,

maintain Recirculation and

makeup flow and pH 

SDT (Kraft) SCBR 145 1 SDT SCBR 2 2

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup When smelt flow begins 0.5 0.5 Shut down recirculation pumps

SDT (Kraft) SCBR 146 2 SDT SCBR 2 2

Scrubber is to be in operationprior to introduction of blackliquor in the recovery furnace

Introdution of black liquor to

the recovery furnace 1 1

Control device remains inoperation until after black

liquor addition has stopped

SDT (Kraft) SCBR 147 1 SDT SCBR 2 2

Scrubber is to be in operationprior to introduction of black

liquor in the recovery furnace

Introdution of black liquor tothe recovery furnace 1 1

Control device remains in

operation until after black

liquor addition has stopped

SDT (Kraft) SCBR 147 2 SDT SCBR 2 2

Scrubber is to be in operation

prior to introduction of blackliquor in the recovery furnace

Introdution of black liquor tothe recovery furnace 1 1

Control device remains in

operation until after black

liquor addition has stopped

SDT (Kraft) SCBR 148 2 SDT SCBR 7 7

emission unit and control

device operates in compliance

parameter limits duringemission unit startup

When emission unit is firing

black liquor 2 2

emission unit and control

device operates in compliance

parameter limits duringemission unit shutdown 

SDT (Kraft) SCBR 149 1 SDT SCBR 0.5 0.5

Operate all APCDs duringstartup

Liquor Flow to Recovery

Furnance >20 gpm for > 30minutes (Recovery Boilernormal operation) 0.1 0.1

Operate all APCDs duringshutdown

SDT (Kraft) SCBR 150 1 SDT SCBR 16 16

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits) Black liquor flow at setpoint 8 8

Continue operating scrubberuntil smelt tank completes

shutdown 

SDT (Kraft) SCBR 152 1 SDT SCBR 4 4

emission unit and control

device operates in compliancewith NSPS and NESHAP

parameter limits duringemission unit startup

recovery furnace beginssmelting 24 24

continue operatiing scrubber

during cool down

SDT (Kraft) SCBR 153 1 SDT SCBRSDT (Kraft) SCBR 154 2 SDT SCBR 4 4

NA ‐ applicable emission andparameter limits not expected

to be exceeded during startup

when the weak wash flow inand the green liquor flows out

have stabilized 4 4

NA ‐ applicable emission andparameter limits not expected

to be exceeded during

shutdown 

SDT (Kraft) SCBR 159 1 SDT SCBR

1‐2 hrs after

Recovery

Startup 2

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

once the recovery starts, won't

even put a fire in it until ready

to go

3‐4 hours shuts

down with the

Recovery 4

continued operation of thescrubber

SDT (Kraft) SCBR 162 1 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameter limits

(weak wash flow and fan amps)are attained before black liquor

is introduced to the recoveryfurnace.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR 162 1 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameterlimits(weak wash flow and fanamps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 163 1 SDT SCBR

12 (Cold

Startup) 12

Scrubber is operational and

scrubber parameterlimits(weak wash flow and fanamps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolvingtank is achieved.

6 (Cold

Shutdown) 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 163 2 SDT SCBR

12 (Cold

Startup) 12

Scrubber is operational and

scrubber parameterlimits(weak wash flow and fanamps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved.

6 (Cold

Shutdown) 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 164 2 SDT SCBR 0.1 0.1

smelt dissolving tank is on line

when black liquor firing

commences

after black liquor firing begins

and min. scrubber flow ismaintained 4 4

keep S.D.tank scurbber flow onduring bed burn down 

SDT (Kraft) SCBR 165 1 SDT SCBR

Cold Startup:

12 Hrs (time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved.

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 165 1 SDT SCBR

Cold Startup:

12 Hrs (time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameter limits

(liquid flow to fan andscrubber, fan amps) areattained before black liquor isintroduced to the recovery

furnace.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved.

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 166 2 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameterlimits(weak wash flow and fanamps) are attained before

black liquor is introduced to

the recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 167 1 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed from

initial auxiliary

fuel firing until

black liquor is

introduced);

Hot Startup: 2

Hrs 12

Ducon Scrubber is operationaland required scrubber weak

wash flow and fan amps are

attained before black liquor isintroduced to the recoveryfurnace.

Black liquor is introduced to

the boiler, a stable funace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, the

furnace bed is burned out andsmelt is no longer flowing.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR 171 2 SDT SCBR 2 2

Ensure control equipment isoperational as early as possiblein startup procedure.

Document steps for accurate

SU through SSM plan andstandard operating procedures.

Startup ends when smelttemperature is greater than

150 deg F. 2 2

Ensure control equipment isoperational as long as possiblein shutdown procedure.Document steps for specific SD

through SSM plan and standardoperating procedures.

SDT (Kraft) SCBR 172 2 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameterlimits(weak wash flow and fan

amps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistentsmelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 173 1 SDT SCBR

Cold startup:

12 hours (time

elapsed until

black liquor is

introduced);

Hot startup: 2

hours 12

Scrubber is operational and

scrubber parameter limits (flow

and differential pressure) are

achieved before black liquor is

introduced to the recoveryfurnace.

Black liquor is introduced to

the recovery furnace, a stable

furnace bed is obtained, and aconsistent smelt flow to the

dissolving tank is achieved.

Controlled

shutdown: 8

hours 8

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 174 2 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameterlimits(weak wash flow and fanamps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 175 2 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameterlimits(weak wash flow and fanamps) are attained before

black liquor is introduced to

the recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

SDT (Kraft) SCBR 176 1 SDT SCBR

Flame proven in Recovery oil

gun

SDT (Kraft) SCBR 177 1 SDT SCBR 8‐12 hours 12

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Normal operation begins whennormal black liquour firing

rates are reached and thefurnace operation is stable. 8 ‐ 12 hours 12

Control device (EU0801ESP)

continues to operate normally

during the smelt dissolvingtank shutdown process.

SDT (Kraft) SCBR 178 2 SDT SCBR

Cold Startup:

~12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: ~2

Hrs 12

Scrubber is operational and

scrubber parameter

limits(weak wash flow and fanamps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bedis obtained, and a consistent

smelt flow to the dissolvingtank is achieved.

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): ~6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR 179 1 SDT SCBR 5 5

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

The recovery furnace issmelting. 1 1

Emission unit control device

continues to operate during

shutdown.

SDT (Kraft) SCBR 180 1 SDT SCBR 0.1 0.1

Scrubber on‐line and aboveminimum flow of 207 gpm with

pressure above 25 psi

recovery boiler smelting in thedissolving tank 0.1 0.1

Scrubber on‐line and aboveminimum flow of 207 gpm withpressure above 25 psi

SDT (Kraft) SCBR 181 2 SDT SCBR 8 8

scrubber is operational prior tostartup; applicable emission

and parameter limits not

expected to be exceeded

during startup recovery boiler starts smelting 8 8

scrubber is operational until

shutdown complete; applicable

emission and parameter limits

not expected to be exceeded

during shutdown 

SDT (Kraft) SCBR 182 1 SDT SCBR 12 12 6 6

SDT (Kraft) SCBR 183 1 SDT SCBR

SDT (Kraft) SCBR 184 3 SDT SCBR 1 1

Ensure adequate scrubberliquid flow is achieved prior tointroducing liquor to the smeltdissolving tank.

When appropriate level is

reached in tank. (~80%) 1 1

Continue operating scrubberuntil there is no more smeltcoming out of smelt spout.

SDT (Kraft) SCBR 186 1 SDT SCBR 10 10

Scrubber must be in

compliance

When black liquor is fired intothe boiler 12 12

Scrubber must be in

compliance

SDT (Kraft) SCBR 188 2 SDT SCBR 6.3 6.3

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup Smelt runs into dissolving tank 0.5 0.5

Operate Ducon Scubber duringshutdown 

SDT (Kraft) SCBR 189 2 SDT SCBR 4 4

Maintain sufficient scrubber DP

and the scrubber recirculatingflow(s) to avoid established

limit excursions during the

startup period.

Per the SSM plan: Whenrecirculation pump flow toscrubbers is within theestablished range; Fan amps

are on; and the Smelt flow to

tank is visually on. 4 4

The scrubber recirculating flow

should be maintained and thescrubber DP operated as highas possible during theshutdown period until greenliquor is no longer produced

and pumped from the smelt

dissolving tank.

SDT (Kraft) SCBR 190 3 SDT SCBR 10 10

Control device is started up

with emission unit startup.

Startup is complete with agreen liquor baume of 15 or

greater is pumped to the

recausticizing operations 30 30

SDT (Kraft) SCBR 195 1 SDT SCBR 8 8

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits) Firing Black Liquor 18 18

All Control Equipment remainon‐line until source is shut

down. 

SDT (Kraft) SCBR 196 2 SDT SCBR 0.25 0.25

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Proper scrubber dp andrecirculation flow areestablished 0.25 0.25

Continue operating scrubberuntil smelt runoff has ceased 

SDT (Kraft) SCBR 197 1 SDT SCBR 3 3

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

Black Liquor is burning in

Recovery Furnace and

supplying smelt to the SDT 1 1

SDT (Kraft) SCBR 198 1 SDT SCBR 8 8

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Recovery furnace operating

and scrubber pump and fanonline 3 3

scrubber operates until smelt

flow terminates

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR 199 1 SDT SCBR 12 12

Ensure scrubber liquid isflowing prior to introducing

black liquor into recovery

furnace

Black liquor flow to recovery

furnace exceeds 160 gpm for atleast 3 hours and recovery

furnace steam production

exceeds 200,000 lb/hr for at

least 3 hours 6 6

Continue operating scrubberuntil smelt bed has burned

down in furnace

SDT (Kraft) SCBR 200 1 SDT SCBR 5 5

Follw the appropriate pre‐

start/startup checklist.Scrubber fans and weak wash

are available and operational

No. 2 Recovery Boiler isoperational with smelt feed,

the scrubber fan is operational,

and the weak wash pump is

online. 6 6

Follow the appropriateshutdown checklist. Control

device may continue tooperate throughout shutdown.

SDT (Kraft) SCBR 200 1 SDT SCBR 7 7

Follw the appropriate pre‐start/startup checklist.

Scrubber fans and weak wash

are available and operational

No. 3 Recovery Boiler isoperational with smelt feed,

the scrubber fan is operational,

and the weak wash pump is

online. 8 8

Follow the appropriateshutdown checklist. Control

device may continue tooperate throughout shutdown.

SDT (Kraft) SCBR 201 1 SDT SCBR 10 10

Ensure scrubber liquid isflowing prior to introducingblack liquor into recovery

furnace

Black liquor line pressure to

recovery furnace exceeds 10

psig for at least 60 minutes 4 4

Continue operating scrubberuntil smelt bed has burned

down in furnace

SDT (Kraft) SCBR 202 1 SDT SCBR

2009 average

startup time is

3.9 hours ‐ 

Startup is

considered to

begin when

liquor is first

added to the

Recovery

Furnace,

Startup for

NESHAP is not

considered the

time required

when warming

up on natural

gas so liquor

can be added.

recovery

Furnace wa 3.9

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

All four liquor guns are in

Recovery furnace and all six gas

guns (for startup) are out of

the Recovery furnace.

2009 average

shutdown time

is 1.5 hours ‐ 

Smelt

Dissolving Tank

shut down is

considered

complete when

no more liquor

is entering

Recovery

Furnace. 1.5

Continue operating scrubberunless need to work onscrubber even when emission

unit down and verify 3‐hour

block average for flow anddifferential pressure is met. IfRecovery Furnace is off liquor

can shut down scrubber. There

are two identical scrubbersavailable for air pollutioncontrol in the event one

scrubber has to be shut down

the second scrubber can be

used.

SDT (Kraft) SCBR 203 1 SDT SCBR 4 4

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

black liquor flow to furnace >

30 gpm for 3 hrs 8 8

Continue operating scrubberuntil smelt tank is empty

SDT (Kraft) SCBR 203 1 SDT SCBR 4 4

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

black liquor flow to furnace >75 gpm for 3 hrs 8 8

Continue operating scrubberuntil smelt tank is empty

SDT (Kraft) SCBR 205 1 SDT SCBR 10 10

Ensure scrubber liquid isflowing prior to introducing

black liquor into recovery

furnace

Black liquor flow to recovery

furnace exceeds 70,000 lbs/hr

for at least 15 minutes 4 4

Continue operating scrubberuntil smelt bed has burned

down in furnace

SDT (Kraft) SCBR 226 2 SDT SCBR 12 12

Ensure scrubber liquid isflowing prior to introducing

black liquor into recovery

furnace

Commencement of operationof green liquor pump from

smelt dissolving tank 4 4

Continue operating scrubberuntil smelt bed has burned

down in furnace

SDT (Kraft) SCBR 226 1 SDT SCBR 6 6

Ensure scrubber liquid isflowing prior to introducingblack liquor into recovery

furnace

Commencement of operationof green liquor pump from

smelt dissolving tank 4 4

Continue operating scrubber

until smelt bed has burned

down in furnace

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR 240 1 SDT SCBR

4 ‐ 8 hours if

cold startup

from planned

outage 8

Emission unit and control

device operate during emission

unit startup, applicableemission and parameter limits

not expected to be exceeded

during startup.

Recovery Furnace is firing black

liquor solids at normal rates,with stable smelt bed andsmelt generation rates.

4 ‐ 8 hours if

shutting down

to cold

conditions for

planned outage 8

Control device continues tooperate and meet required

operating limits until after

firing of black liquor solids in

the Recovery Furnace hasceased and drainage from thesmelt bed into the dissolving

tank has ceased.

SDT (Kraft) SCBR 240 2 SDT SCBR

4 ‐ 8 hours if

cold startup

from planned

outage 8

Emission unit and control

device operate during emission

unit startup, applicableemission and parameter limits

not expected to be exceeded

during startup.

Recovery Furnace is firing black

liquor solids at normal rates,with stable smelt bed and

smelt generation rates.

4 ‐ 8 hours if

shutting down

to cold

conditions for

planned outage 8

Control device continues to

operate and meet required

operating limits until afterfiring of black liquor solids in

the Recovery Furnace hasceased and drainage from thesmelt bed into the dissolving

tank has ceased.

SDT (Kraft) SCBR 242 1 SDT SCBR 4 4

The startup period ends andoperation begins when full

strength green liquor is

pumped to the recausticizingoperation. 6 6

The scrubber recirculating flowand venturi flow should bemaintained and the scrubberdelta P operated as high aspossible during the shutdown

period until green liquor is no

longer produced and pumpedfrom the smelt dissolving tank.

SDT (Kraft) SCBR 243 1 SDT SCBR 10 10

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Recovery furnace operatingrate reaches 3.0 MMlbs black

liquor solids/day or greater 12 12

Continue to operate scrubbershutdown complete

SDT (Kraft) SCBR 243 1 SDT SCBR 10 10

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Recovery furnace operatingrate reaches 4.8 MMlbs blackliquor solids/day or greater 12 12

Continue to operate scrubber

shutdown complete

SDT (Kraft) SCBR 340 1 SDT SCBR 0.5 0.5

emission unit and control

device operates in compliancewith NSPS and NESHAPparameter limits duringemission unit startup

Scrubber differential pressure,

circulation rate reached 0.5 0.5

Continue operating scrubberuntil smelt bed burned out. 

SDT (Kraft) SCBR 525 2 SDT SCBR 24 24

scrubber flow is establishedduring startup.

when full strength green liquor

is flowing to causticizing

operation 3 3

maintain scrubber flow until

green liquor is no longer

produced 

SDT (Kraft) SCBR 531 1 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational and

scrubber parameter

limits(weak wash flow and fanamps) are attained before

black liquor is introduced to

the recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operational

until all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out and

smelt is no longer flowing.

SDT (Kraft) SCBR 600 2 SDT SCBR

Cold Startup:

12 Hrs (Time

elapsed until

liquor is

introduced);

Hot Startup: 2

Hrs 12

Scrubber is operational andscrubber parameterlimits(weak wash flow and fan

amps) are attained before

black liquor is introduced tothe recovery furnace.

Black liquor is introduced to

the boiler, a stable furnace bed

is obtained, and a consistent

smelt flow to the dissolvingtank is achieved

Controlled

Shutdown

(Time elapsed

from removing

first liquor gun

from service

until furnace

bed is burned

out): 6 Hrs 6

Scrubber remains operationaluntil all black liquor is pulled

from the recovery furnace, thefurnace bed is burned out andsmelt is no longer flowing.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR 606 3 SDT SCBR <1 1

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Smelt flowing to dissolving

tank from recovery furnace <1 1

Scrubber operates until smelt

flow from associated recoveryfurnace stops

SDT (Kraft) SCBR 610 2 SDT SCBR 0.5 0.5

emission unit and control

device operates in compliance

with NESHAP parameter limits

during emission unit startup

scrubber flow at minimumrequired levels 0.08 0.08

emission unit and control

device operates in compliance

with NESHAP parameter limits

during emission unit shutdown

SDT (Kraft) SCBR 613 1 SDT SCBR 2 2

Maintain sufficient scrubber

delta P and scrubber

reirculating flows to avoidestablished limit excursions

during the startup period.

Separator flow is has reached274, venturi flow has reached109.5, and fan delta P has

reached 9.4 2 2

The scrubber recirculating flowand venturi flow should bemaintained and the scrubberdelta P operated as high aspossible during the shutdownperiod until green liquor is no

longer produced and pumpedfrom the smelt dissolving tank.

SDT (Kraft) SCBR 613 1 SDT SCBR 2 2

Maintain sufficient scrubber

delta P and scrubber

reirculating flows to avoidestablished limit excursions

during the startup period.

Separator flow is has reached

276.1, venturi flow has reached

111.2, and fan delta P has

reached 11.9 2 2

The scrubber recirculating flow

and venturi flow should bemaintained and the scrubberdelta P operated as high aspossible during the shutdownperiod until green liquor is no

longer produced and pumpedfrom the smelt dissolving tank.

SDT (Kraft) SCBR 613 1 SDT SCBR 2 2

Maintain sufficient scrubber

delta P and scrubber

reirculating flows to avoidestablished limit excursions

during the startup period.

Separator flow is has reached298, venturi flow has reached

94.8, and fan delta P has

reached 11.05 2 2

The scrubber recirculating flowand venturi flow should bemaintained and the scrubber

delta P operated as high aspossible during the shutdownperiod until green liquor is no

longer produced and pumpedfrom the smelt dissolving tank.

SDT (Kraft) SCBR 613 1 SDT SCBR 2 2

Maintain sufficient scrubber

delta P and scrubber

reirculating flows to avoidestablished limit excursions

during the startup period.

Separator flow is has reached

300.3, venturi flow has reached

94.9, and fan delta P has

reached 10.1 2 2

The scrubber recirculating flowand venturi flow should bemaintained and the scrubberdelta P operated as high aspossible during the shutdownperiod until green liquor is no

longer produced and pumpedfrom the smelt dissolving tank.

SDT (Kraft) SCBR 615 1 SDT SCBR 3 3

scrubber flow is turned onprior to black liquor feed to the

recovery furnace

black liquor entering recoveryfurnace 6 6

scrubber flowrate is

maintained

SDT (Kraft) SCBR

2082285

35 2 SDT SCBR 12 12

Ensure scrubber liquid is

flowing prior to introducing

black liquor into recovery

furnace

At least 8 liquor guns havebeen placed into service 3 3

Continue operating scrubberuntil smelt bed has burned

down in furnace

SDT (Kraft) SCBR/INC_RF 111 1 SDT SCBR 12 12

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits)

Recovery Boiler has completedStart‐up 14 14

Emissions controls remain inoperation until shut‐down has

been completed.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

SDT (Kraft) SCBR/STRIP 151 1 SDT SCBR 16 16

NA ‐ applicable emission andparameter limits not expected

to be exceeded during startup

target scrubber flow rate

achieved 6 6

continue operating scrubberuntil after smelting hasstopped

SDT (Kraft) SCBR/STRIP 151 2 SDT SCBR 9 9

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

target scrubber flow rate

achieved 3 3

continue operating scrubberuntil after smelting hasstopped

SDT (Kraft)

Do Not Count ‐ See RTI Note 135 1 SDT SCBR 6 6

The scrubber is operating prior

to smelt from the boiler isadded to the tank .

Black liquor is firing in theboiler in a continuous andstable manner. 4 4

The scrubber is operatedduring the shutdown of thesmelt tank.

SDT (Kraft) SCBR 105 1 SDT SCBR

SDT (Kraft) SCBR 131 1 SDT SCBR 2 2

emission unit and control

device operates in compliance

with State and NESHAP

parameter limits duringemission unit startup

Any black liquor spray gun in >

2 hours 2 2

Continue to operate control

device until unit is down 

SDT (Kraft) SCBR 150 1 SDT SCBR 16 16

emission unit and control

device operates duringemission unit startup (but not

necessarily in compliance with

all NSPS/NESHAP parameter

limits) Black liquor flow at setpoint 8 8

Continue operating scrubberuntil smelt tank completes

shutdown 

SDT (Kraft) SCBR 196 1 SDT SCBR 0.25 0.25

emission unit and control

device operates in compliance

with NSPS and NESHAPparameter limits duringemission unit startup

Proper scrubber dp andrecirculation flow areestablished 0.25 0.25

Continue operating scrubberuntil smelt runoff has ceased 

SDT (Kraft) SCBR/STRIP 151 1 SDT SCBR 16 16

NA ‐ applicable emission and

parameter limits not expected

to be exceeded during startup

target scrubber flow rate

achieved 6 6

continue operating scrubberuntil after smelting hasstopped

SDT (Kraft) SCBR 103 1 SDT SCBR 4 to 8 8

The North and South smeltdissolving tank vent stack

scrubbers are operatingproperly and ready to acceptthe vent gas streams from the

smelt dissolving tanks.

The transition from startup to

normal operations will be

considered complete when the

listed conditions have been

achieved:1. Specific Gravity of RawGreen Liquor in tank > 1.12

(changed on April 27, 2006 pere‐mail from Kari Cahoon)

2. Level of Raw Green Liquor

achieved. > 50%

3. Exhaust Gas Temperature,

oF > 170

4. Exhaust Gas Pressure, in,

H2O < ‐0.1 4 4

The boiler and smelt dissolvingtanks are shutdown prior to

scrubber being shutdown

SDT (Kraft) SCBR 142 1 SDT SCBR

~7 hrs (Hot), ~7

Hrs (Cold) 7

Control device is turned on

prior to emission unit startup.

The startup period ends whenliquor is fired in the No.1 or No.2 Recovery Furnace for five (5)

consecutive hours understeady‐state conditions. ~13 hrs (Cold) 13

Control device is operated

during emission unit shutdown

*If a range was provided the maximum of the range was entered.

App_C1_NSPS_SSM_Equip_Detail 
Emission

Process

Group

RTI_APCD_Typ

e

RTI

CODE

Count of

RTI

CODE

EU‐APCD Group SU_Duration_h rs SU_Duration_h rs_num* SU_EmissRednMeas SU_MarkEnd SD_Duration_h rs SD_Duration_h rs_num* SD_EmissRednMeas 

DCE NDCE LK SDT

Startup Time

(Hrs)

Min 2 2 0.50 0.10

Max 24 60 72 24

Average 9 11 24 7.2

Median 9 10 24 7

Shutdown Time

(Hrs)

Min 0.5 0.5 0.03 0.08

Max 84 84 48 38

Average 11 10 12 6.5

Median 6 6 6 6

App_C1_NSPS_SSM_Equip_Detail 
Appendix C2

Startup and Shutdown Responses for PM and TRS Controls in the PIII Controls tab of the ICR
Appendix C2 – Startup and Shutdown Responses for PM and TRS Controls in the PIII Controls tab of the ICR

Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kilns

Lime Kiln 100 1 LK ESP < 2 Hrs 2

Power is applied to

transformer rectifiers after

the ESP internaltemperature reaches the

minimum temperaturespecified by Mill

procedures. Mud is

introduced to the lime kiln

only after the ESP is brought

on‐line.

The applicable emissionand parameter limits are

expected to be met

during startup

Power is applied to

transformer rectifiers

after the ESP internal

temperature reaches

the minimum

temperature specified

by Mill procedures.Black liquor isintroduced to the lime

kiln only after the ESP is

brought on‐line.

Startup ends when the

scrubber fan amps andflow limits are achieved. ~1 Hr 1

ESP remains operational

until all mud is pulled

from the and the

combustion is ceased.

The applicable emissionand parameter limits areexpected to be metduring startup

ESP rem

until alfrom thcombus

Lime Kiln 102 1 LK ESP 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up. opacity

Precipitator fields reach

power setpoints. 0 0

LK‐ESP remains on lineuntil after LK is shut

down (lime mud/rockfeed and gas burner

turned off). NA NA

Lime Kiln 104 1 LK ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Lime mud is introduced to

the lime kiln only after the

ESP is brought on‐line.

Power is applied to

tranformer rectifiers

after the ESP internal

temperature reaches

200  ̊F. Lime mud isintroduced to the lime

kiln only after the ESP is

brought on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all mud is out ofthe lime kiln

ESP rem

until althe lim

Lime Kiln 105 1 LK ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Lime Mud is introduced tothe lime kiln only after the

ESP is brought on‐line.

The applicable emissionand parameter limits are

expected to be met

during startup

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Lime Mud is

introduced to the lime

kiln only after the ESP is

brought on‐line.

When ESP internaltemperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all reburned lime is

pulled from the lime

kiln.

The applicable emissionand parameter limits areexpected to be metduring shutdown

ESP rem

until al

pulled f

kiln.

Lime Kiln 107 1 LK ESP 0.5 0.5

Control device cannot start

up until flue gastemperatures reach 240F temperature

fire natural gas only and

no lime mudintroduction into lime

kiln during period of

start up

Startup ends when the

power to all sections is

turned on. 0.5 0.5

Control device is shut

down after lime mud

feed is off

Opacity can be out of

limit due to dusting

Controto oper

emissiodown

Lime Kiln 109 1 LK ESP 24 24

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

Emission Unit is not

started until control is

steady state

When the temperature

startup curve iscompleted and the firing

temperature has been

stable for 1 hour min. 24 24

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Contro

shutdo

Unit is S

Lime Kiln 111 1 LK ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

verify control device isin operation

Power is shut off to the

CD 0.5 0.5

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

CD remoperati

shut do

Lime Kiln 112 1 LK ESP

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

control operating

parameters met before

process start‐up

ESP up to full operating

power 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

control 

process 

Lime Kiln 114 1 LK ESP 24 24

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Total power >75% of

established value in last

performance test 24 24

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

Lime Kiln 115 2 LK ESP 12 12

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup heated up and online

Minimum powerachieved 0 0

Control device operates

until process is downand no emissions being

generated None NA

Lime Kiln 115 2 LK ESP NA

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 127 2 LK ESP 0.05 0.05

Kiln rotation must be at

maximum speed beforestarting ESP

Normal power outputfromtransformer/rectifiers is

confirmed 0.0333 0.0333

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. opacity

Lime Kiln 132 1 LK ESP 0 0

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Control device remains

operational until the EU

is shutdown 

Lime Kiln 132 1 LK ESP 12 12

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Lime mud is not

introduced until controldevice meets

operational limits.

Lime mud is introduced

to EU. 0 0

Control device remains

operational until the EU

is shutdown 

Lime Kiln 137 1 LK ESP 30 30

Control device is started up

after the air temperature

out of the ESP reaches a

minimum temperature

The applicable emission

and parameter limits are

expected to be met

during startup

delay processequipment startup

Natural gas flow > 150

scfm on a sustained

basis and precipitatortemperature > 350 deg.F

and Stack O2 is < or

=16% on a sustainedbasis and precoat belt

mud flow into kiln

operating in a forwardposition and mud flow

to lime kiln > or = 50

gpm on a sustained

basis. 24 24

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be met

during startup

Mainta

control 

long as 

Route H

LVHC to 

Lime Kiln 143 1 LK ESP

Control devicestartup time is

included in the

startup time

provided for the

emissions unit

on the

Equip_Detail

Tab.

The startup of the ESP is

concurrent with fuel firing;

the ESP is online before lime

mud enters the kiln.

The applicable emission

and parameter limits are

expected to be met

during startup (i.e., ESPis on).

The ESP is online before

lime mud is introducedto the lime kiln.

Target fire end

temperature is attainedand consistent mud flowis achieved.

Control device

shutdown time

is included in

the shutdown

time provided

for the

emissions unit

on the

Equip_Detail

Tab

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. N/A

Continu

until m

lime kil

shut do

Lime Kiln 147 1 LK ESP 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Ensure that power is

applied to ESP All T/R are in operation 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

Lime Kiln 148 1 LK ESP 0.1 0.1

Must meet Title V

parameters before addingany fuel to emission unit to

go through the control

device

Control device

parameters are met

before emission unit is

brought up

Control deviceparameters are met

before emission unit is

brought up

Control device

parameters are met

before emission unit isbrought up 0.1 0.1

Control device is not

shutdown until theemission unit isshutdown

Control device

parameters are met

before emission unit is

brought up

Controparamebefore 

brough

Lime Kiln 151 1 LK ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Lime kiln and ESP are

stable and meeting

normal operationprocess conditions.LVHC, HVLC and SOG are

being collected. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

continuESP unt

stopperotatio

Lime Kiln 151 1 LK ESP 0.5 0.5

Hours of operation of

control device are tracked

to perform a bubble

calculation which takes into

account each kilnsoperational hours and hours

of burning unscrubbed NCGs n/a

All NCGs are being

collected, the lime kiln

burning gases is stable,

and the NCG Scrbber

and NCG Cooler areperforming properly 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

continuand tra

burning NCGs 

Lime Kiln 151 1 LK ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Lime kiln and scribber

are stable and meeting

normal operationprocess conditions.

LVHC, HVLC and SOG are

being collected 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

continu

scrubbe

has storotatio

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 156 1 LK ESP 2 2

ESPs are always up and

running prior to emissionunit startup and are shut

down after emission unit is

completely shutdown.

The applicable emissionand parameter limits are

expected to be met

during startup

Follow SSM plans andprocedures

Starting point of an ESP

is completely down until

it is completely

energized to perform itsfunction (T/R units and

rappers on, dust

collection system on and

ESP damper in). 2 2

ESPs are always up and

running prior to

emission unit startupand are shut down after

emission unit iscompletely shutdown.

The applicable emissionand parameter limits areexpected to be met

during startup

Follow 

proced

Lime Kiln 162 1 LK ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.Lime Mud is introduced tothe lime kiln only after the

ESP is brought on‐line.

NA, Facility monitors

opacity

Power is applied to

tranformer rectifiers

after the ESP internal

temperature reaches

200  ̊F. Lime Mud is

introduced to the lime

kiln only after the ESP is

brought on‐line.

Startup ends when ESP

internal temperature

reaches 200  ̊F and

power is applied to

tranformer rectifiers. 1 Hr 1

ESP remains operational

until all rmud feed, fuelfiring, and ID fan is

stopped .

NA, facility monitorsopacity

ESP rem

until mfiring is 

emissio

shutdoESP is s

Lime Kiln 179 1 LK ESP 0.083‐0.167 0.167

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

N/A ‐ Control device isstarted up beforeprocess is started up

ESP is ready to receivegases from the recovery

furnace. 0.083‐0.167 0.167

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

N/A ‐ P

down b

device 

comme

Lime Kiln 196 1 LK ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Ensure power is on the

ESP ESP powered up 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Fuel feefans slo

Lime Kiln 200 1 LK ESP 2 2

Control device is operating

and meets required

operating parameter limits

before emission unit begins

normal operation.

The applicable emissionand parameter limits are

expected to be met

during startup

control device operating

prior to processbeginning normaloperation

Verification that the

fields, rappers, and

hopper screws are

operating and the COMS

is clean and on‐line. UK

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

control to oper

possible 

shuts d

Lime Kiln 240 1 LK ESP <0.5 0.5

To avoid severe corrosion

damage to control device,

the ESP cannot be started

up before fuel‐only firing in

the Lime Kiln can bring the

temperature at back end of

kiln above acid dewpoint

temperatures. However,

during this fuel‐only

firing/kiln heatup process ,

the Lime Kiln is not feedingor processing any lime mud

so the only particulate

generation is from the fuel

combustion.

The applicable emissionand parameter limits are

expected to be met

during startup.

Prior to ESP startup, theLime Kiln goes through aheating ‐up process with

fuel‐only firing. During

this time, the Lime Kiln

is not feeding or

processing any lime mud

so the only particulate

generation is from the

fuel combustion.

Lime Kiln meets

minimum back end

temperature and at

least one precipitatorfield is energized. <0.5 0.5

Control device continues

to operate and meet

required operatinglimits until raw material

lime mud feed to the

emission unit has

ceased, remaining limeproduct has discharged

from the emission unit,and fuel firing to the

unit ceases.

The applicable emissionand parameter limits areexpected to be met

during startup.

Controto oper

require

limits ulime memissioceased, 

produc

from thand fue

unit cea

Lime Kiln 531 1 LK ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internaltemperature reaches 200  ̊F.

Lime Mud is introduced tothe lime kiln only after the

ESP is brought on‐line. NA

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Lime Mud is

introduced to the lime

kiln only after the ESP is

brought on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all reburned lime is

pulled from the lime

kiln.

NA

ESP rem

until al

pulled f

kiln.

Lime Kiln 606 1 LK ESP 1 1

Not integrated. Standard

procedure is for control

device to start up ahead of

emissions unit.

Fields are energized and

ancillary systems startedup.

Fields energized and

stable, ancillary systems

funtioning normally. 1 1

Not integrated.

Standard procedure isfor control device to

shutdown afteremissions unit. no fire 

Lime Kiln 617 1 LK ESP 1 1

control device is fully

operational before processis started up

The applicable emissionand parameter limits are

expected to be met

during startup

process does not startup until control device isready

ESP secondary voltage

at >30 kV 0.5 0.5

control device is not

shut down until process

is down

The applicable emissionand parameter limits areexpected to be metduring startup

continu

control process 

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 2.1E+08 1 LK ESP 4 4

Control device is started up

and meets required

operating parameter limits

at the time that lime mud isfed to kiln.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure drop

parameter limit range isachieved 0.2 0.2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring shutdown.

Lime Kiln 126 1 LK ESP/SCBR 3 hours 3

During cold start up prior to

processing lime mud the

precipitator is bypassed and

emissions treated by

scrubber until flue gastemperature over 400 F

when precipitator is tied in.After heating precipitator

TRs are energized and lime

mud processing begins opacity

Flue gas emissions are

treated by scrubber

(LKScr)

When power is appliedto transformer rectifiers

and compliant opacityachieved <1 hr 1

ESP remains operational

until all lime processingand oil firing ceases. NA

ESP rem

until al

and oil 

Lime Kiln 126 1 LK ESP/SCBR < 1 hour 1

Scrubber flow rate limit is

met before lighting oil

burner. Mud is notintroduced to the kiln until

the scrubber is operational

and scrubber flowrate limits

are achieved.

Scrubber flow limit is

not instantaneously

achieved at startup of

scrubber control device

but is achieved before

lighting the oil burner.

Scrubber flow rate limit

is met before lighting oil

burner. Mud is notintroduced to the kiln

until the scrubber isoperational andscrubber flowrate limits

are achieved.

Startup ends when the

scrubber flow rate limits

are achieved. 0.25 hours 0.25

Scrubber shutdown isonly initiated after mud

is out of the kiln,

potential for dusting is

eliminated and ID fan is

shut down. NA

Scrubbe

only iniis out o

potentieliminashut do

Lime Kiln 137 1 LK ESP/SCBR 30 30

Control device is started up

after the air temperature

out of the ESP reaches a

minimum temperature

The applicable emissionand parameter limits are

expected to be met

during startup

delay processequipment startup

Natural gas flow > 150

scfm on a sustained

basis and precipitatortemperature > 350 deg.F

and Stack O2 is < or =

16% on a sustained basis

and precoat belt mudflow into kiln operating

in a forward position

and mud flow to lime

kiln > or = 50 gpm on a

sustined basis. 24 24

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

Mainta

control 

long as 

Route H

LVHC to 

Lime Kiln 137 1 LK ESP/SCBR 30 30

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

delay processequipment startup

All continuousmonitoring parameters

at set point and flame in

Kiln. 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

Mainta

control 

long as 

Route H

LVHC to 

Lime Kiln 146 1 LK ESP/SCBR 2 2

ESP is to be in operation

prior to introduction of lime

mud NA

Ensure that power is

applied to ESP

Introduction of lime

mud to the lime kiln 0.5 0.5

Control device remains

in operation until lime

mud addition hasstopped NA

Controin oper

mud ad

stoppe

Lime Kiln 146 1 LK ESP/SCBR 0.5 0.5

Scrubber is to be in

operation if NCGs are

introduced into the kiln NA NA

Introduction of lime

mud to the lime kiln 0.5 0.5

Control device remains

in operation until lime

mud addition hasstopped NA

Controin oper

mud ad

stoppe

Lime Kiln 154 1 LK ESP/SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emission

and parameter limits are

expected to be met

during startup

Process does notoperate until ESP isoperating

at least two TRs

powered 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

ESP ope

the kiln 

Lime Kiln 154 1 LK ESP/SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Process does notoperate until scrubber isoperating

Recirculation flow

greater than 150 gpm 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

Scrubbeafter th

Lime Kiln 174 1 LK ESP/SCBR 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internaltemperature reaches 200  ̊F.

Lime Mud is introduced tothe lime kiln only after the

ESP is brought on‐line.

NA Facility MonitorsOpacity

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Lime Mud is

introduced to the lime

kiln only after the ESP is

brought on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all reburned lime is

pulled from the lime

kiln. NA, Facility monitors

opacity

ESP rem

until al

pulled f

kiln.

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 174 1 LK ESP/SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be metonce mud is removed

from the kiln. (Note toconsultants: Some kilns

may be able to meet thedP limit at all times. If

so, please modify

wording accordingly.

Scrubbe

only iniis fed o

potentieliminashut do

Lime Kiln 178 1 LK ESP/SCBR ~2 hr 2

LVHC gases are not

introduced into the kiln until

the permissives to burn

LVHC gases are granted

Not Applicable‐There

are not operating

parameters required.LVHC gases must be

introduced into the

flame zone.

There are no LVHCemissions during kiln

startup. The emission

sources generating LVHCgases are not started up

up until the lime kiln is

in operation.

Kiln burner flame

established. ~2 hr 2

For emergency kiln

shutdowns, the LVHC

gases are routed to

another control device.

Under normal kiln

shutdowns, the LVHC

gases are routed to

another control device

or the emission sources

generating the LVHCgases are shutdown.

Not Applicable‐There

are not operatingparameters required.

LVHC gases must be

introduced into the

flame zone.

For em

shutdogases a

anothe

Under n

shutdogases a

anotheor the e

generat

gases a

Lime Kiln 178 1 LK ESP/SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limit is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. ~0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be met

once mud is removed

from the kiln.

Scrubbe

only ini

is fed o

potentieliminashut do

Lime Kiln 184 1 LK ESP/SCBR 3 3

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up (i.e. introduction

of limemud).

The applicable emissionand parameter limits are

expected to be met

during startup N/A

all TRs on and

functioning 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits are

expected to be metduring startup N/A 

Lime Kiln 184 1 LK ESP/SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup N/A

adequate pressuredrops and liquid flows 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup N/A

Lime Kiln 186 1 LK ESP/SCBR 0.16 0.16

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

ESP is operating asnormal

Once parameters aremet 0.16 0.16

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

ESP is o

normal

Lime Kiln 186 1 LK ESP/SCBR 0.33 0.33

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Scrubber pH and

Recirculation flow

Once parameters aremet 0.33 0.33

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Scrubbe

normal

Lime Kiln 242 1 LK ESP/SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit isstarted up. NA

Control device is startedup and meets required

operating parameter

limits before emission

unit is started up.

Control device is started

up and meets required

operating parameter

limits before emission

unit is started up. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. NA

Controto oper

require

limits wunit is s

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 242 1 LK ESP/SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up. NA

Control device is started

up and meets required

operating parameter

limits before emissionunit is started up.

Control device is started

up and meets required

operating parameter

limits before emission

unit is started up. 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. NA

Controto oper

require

limits wunit is s

Calciner 182 1 LK SCBR 0.05 0.05

Alarms are sounded when

flow and pressure

parameters are not met

Pressure drop and flow

rate target

Adjust damper and

ensure that target flow

rate is achieved

Pressure drop complieswith permit limit, target

flow rate is achieved 0.05 0.05

Alarms are soundedwhen flow and pressure

parameters are not met

Continuscrubbe

cooled 

Lime Kiln 103 1 LK SCBR 0.2 0.2

Control device is operating

prior to start‐up of the

associated process it is

designed to control

operating within controldevice operating

parameters.

pressure drop, liquid

injection rate and nozzlepressure.

Venturi scrubber mustbe started before kiln is

fired. Startup theventuri scrubber

according to the

standard operating

procedures.

The venturi scrubber isoperating normally, as

defined by the mill's

operating manuals andstandard operating

procedures and verifiedby DCS data. Before

lime mud is introduced

to the lime kiln, verify

that the venturiscrubber operation isstable and the

parameters are

operating within the

given ranges:

Scrubber fan

differential pressure(inches of water) ‐   < 5.0

Liquid flow rate to

scrubber ‐ > 800 gpm

Scrubber nozzle header

pressure – 240 to 275psig 0.2 0.2

Control device operates

until emissions unit hascompleted shutdown.

The applicable emissionand parameter limits areexpected to be metduring startup

Ensure 

been shaccordi

operatistandar

proced

beginnithe venShutdo

recircuexhausaccordi

standar

proced

provide

venturi 

shutdoshutdo

occurs.

Lime Kiln 108 1 LK SCBR 1 1

Scrubber is operational and

scrubber parameter limits

(flow and differential

pressure) are achieved

before processing lime mud.

Scrubber pressure drop

limit cannot be met

instantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneously

achieved at startup of

the scrubber control

device but is achievedbefore processing mud.

Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner

Scrubber is operational

and scrubber parameter

limits (flow anddifferential pressure) are

achieved beforeprocessing lime mud.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be metonce mud is removed

from the kiln.

Scrubbe

only iniis fed o

potentieliminashut do

Lime Kiln 116 1 LK SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

(Note to consultants: Some

kilns may not be able to

meet dP until after mudintroduction. If so, please

modify wordingaccordingly.)

Scrubber pressure drop

limit cannot be met

instantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.(Note to consultants:

Some kilns may not be

able to meet dP until

after mud introduction.If so, please modifywording accordingly.)

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. ~0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be metonce mud is removed

from the kiln. (Note toconsultants: Some kilns

may be able to meet thedP limit at all times. If

so, please modify

wording accordingly.

Scrubbe

only iniis fed o

potentieliminashut do

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 117 1 LK SCBR 8 8

Caustic Scrubber Liquid

Needs to be generated by

the process (P36) the

control device is controlling.

Scrubber Flow Rate 3‐

hour average

Starting scrubber fan

and liquid flow as soon

as ID fan is started.

Start‐Up ends when 3‐

hour average scrubberflow rate parameterlimit is achieved. 18 18

Need to allow feed to be

shut off to P36, and then

time to burn out andcool before motor is

shut off.

The applicable emissionand parameter limits areexpected to be metduring shutdown

Keep sc

running burner 

Lime Kiln 119 1 LK SCBR 24 24

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be metduring start‐up.

Start‐up ends when the

front end temperatureof the kiln is 1900F‐

2200F and the kiln isproducing lime. 4 4

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

None expected duringcontrol device shutdowndue to emissions source

down

Lime Kiln 120 2 LK SCBR <1 hr 1

Scrubber started up prior to

lime mud feed to the kiln

and prior to the main

burners being turned on pressure drop

no lime mud is fed to

the kiln

when pressure dropparameter is achieved .

TRS is controlled with

caustic additon whenneededd.

Runs until the

process stops

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring Shutdown

The scr

operati

has sto

Lime Kiln 121 1 LK SCBR

0.166666666666

667 0.166666667

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

meet liquid flow

parameter limit

Minimum scrubbingliquid flow and pressure

drop parameters are

above the minimum

values

0.1666666666

66667 0.16666667

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown

Controto oper

require

limits w

unit is s

Lime Kiln 130 1 LK SCBR < 1 Hr 1

SOP: Kiln ID Fan is only

operated if the scrubber

recycle pumps are

operational. Kiln startup isonly initiated after the

scrubber is opearational andall critical scrubberoperating parameters(scrubber Δ pressure andscrubber recycle liquid flow)

are attained before startup

of kiln.

Scrubber pressure drop

is not instantaneously

achieved at startup of

the scrubber control

device, but is achieved

before initiation of kilnoperational startup.

SOP: Kiln ID Fan is only

operated if the scrubber

recycle pumps areoperational. Kiln startup

is only initiated after the

scrubber is opearational

and all critical scrubber

operating parameters

(scrubber Δ pressureand scrubber recycleliquid flow) are attained

before startup of kiln.

The end of scrubber

startup and beginning of

scrubber normaloperations occur whenthe scrubber is totally

operational and all

critical target operating

parameters (scrubber Δ 

pressure and scrubber

recycle liquid flow) are

achieved. 0.1 Hr 0.1

SOP: Kiln ID Fan is onlyoperated if the scrubber

recycle pumps areoperational. Scrubber

shutdown is onlyinitiated after mud is fed

out of the kiln, potential

for dusting is eliminated,

and ID fan is shut down.

Scrubber pressure drop

is not instantaneously

achieved at startup of

the scrubber control

device, but is achieved

before initiation of kiln

operational startup and

through kiln shutdown.

Scrubber differential

pressure begins todecrease as the ID fan isshutdown.

SOP: Ki

operate

recycle 

operati

shutdo

initiate

out of t

for dustand ID 

Lime Kiln 130 1 LK SCBR < 1 Hr 1

Standard Operating

Procedure (SOP): Kiln ID Fan

is only operated if the

scrubber recycle pumps are

operational. Kiln startup is

only initiated after the

scrubber is opearational andall critical scrubberoperating parameters

(scrubber Δ pressure andscrubber recycle liquid flow)

are attained before startup

of kiln.

Scrubber pressure drop

is not instantaneously

achieved at startup of

the scrubber control

device, but is achieved

before initiation of kilnoperational startup.

Standard Operating

Procedure (SOP): Kiln IDFan is only operated ifthe scrubber recycle

pumps are operational.

Kiln startup is only

initiated after the

scrubber is opearational

and all critical scrubber

operating parameters

(scrubber Δ pressureand scrubber recycleliquid flow) are attained

before startup of kiln.

The end of scrubber

startup and beginning of

scrubber normaloperations occur whenthe scrubber is totally

operational and all

critical target operating

parameters (scrubber Δ 

pressure and scrubber

recycle liquid flow) are

achieved. 0.1 Hr 0.1

SOP: Kiln ID Fan is only

operated if the scrubber

recycle pumps areoperational. Scrubbershutdown is onlyinitiated after mud is fed

out of the kiln, potential

for dusting is eliminated,

and ID fan is shut down.

Scrubber pressure drop

is not instantaneously

achieved at startup of

the scrubber control

device, but is achieved

before initiation of kiln

operational startup andthrough kiln shutdown.

Scrubber differential

pressure begins todecrease as the ID fan isshutdown.

SOP: Ki

operaterecycle operatishutdo

initiate

out of t

for dust

and ID 

Lime Kiln 131 1 LK SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Do not start kiln until

scrubber is operational.

Liquid flow rate and

differential pressuremeet monitoringrequirementsestablished during stack

tests 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be met

during startup

Wait unpresent temper

kiln 

Lime Kiln 131 1 LK SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Do not start kiln until

scrubber is operational.

Liquid flow rate and

differential pressuremeet monitoringrequirementsestablished during stack

tests 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Wait unpresent temper

kiln 

Lime Kiln 133 1 LK SCBR 0.1 0.1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

scrubber liquid flow and

perssure drop is in the

normal operating range 0.1 0.1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 133 1 LK SCBR 0.1 0.1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

scrubber liquid flow andpressure drop hasreached the normaloperating range 0.1 0.1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Lime Kiln 135 1 LK SCBR 0.5 0.5

The kiln scrubber can be

started separate from the

operation of the lime kiln.

If the startup occurs late

in the 3‐hr block average

period, and operation of

the lime kiln startsshortly thereafter within

the same 3‐hr period,

then the scrubber mayshow non compliance

due to the averaging oflimited data.

Control device is startedup prior to startup of

emissions unit.

The scrubber is

operating in compliance

with the 3‐hr averagepressure drop and recirc

flow range. 0.5 0.5

Control device can be

operated separate from

the emissions unit.

If the shutdown occurs

early in the 3‐hr blockaverage period, and

operation of the lime

kiln stops shortly beforescrubber shutdown,

then the scrubber mayshow non compliancedue to the averaging oflimited data.

Controoperateshutdounit.

Lime Kiln 138 1 LK SCBR 1 1

Control device cannot

function until the Lime Kiln

ID fan is started.

The applicable emissionand parameter limits are

expected to be met

during startup

Lime mud is not fed to

the lime kiln until the

pressure drop and liquid

flow rate parameters

are met.

Startup ends when the

pressure drop andscrubber flow

parameters are met

(pressure drop >11.75

inches, flow >585 gpm) 0.1 0.1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Lime Kiln 139 1 LK SCBR 0.5 0.5

Need air and water flow

from emission unit to obtain

pressure drop parameter

limit. APCD must be

operating prior to ignition of

fuels in order to control

stack temperature.

pressure drop, liquid

flow rate

Control devise is started

prior to feeding mud to

the kiln

Pressure drop and liquid

flow parameter limits

are achieved 0.5 0.5

Need air and water flow

from emission unit toobtain pressure drop

parameter limit. APCDmust be operating until

fuels are no longer

ignited in order to

control stack

temperature.

pressure drop, liquidflow rate

Contro

to operlonger f

the kiln

Lime Kiln 140 1 LK SCBR 4 4

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

control device is

operating prior to

emission unit start up.

permissives for flow and

pressure drop are met 4 4

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

delta p, as it is

dependent upon the airrequirements of the kiln,

which depends on theamount of mud.

discont

NCG's p

shutdo

Lime Kiln 142 1 LK SCBR ~3 3

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

DP is hard to achieve

until kiln has mud going

into it.

Increase shower flow

and close damper

Startup ends when the

following is true: :(1)

lime mud flow is > 90GPM, (2) kiln drive is in

continuous rotation, (3)

the feed‐in operating

temperature is >350 deg

F, (4) the desired

differential pressure andshower flow of the

venturi scrubber is

achieved, and (5)

product has been

discharging from the kilnfor at least five hours. ~1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. Pressure Drop Mud ta

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 142 1 LK SCBR ~3 3

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

DP is hard to achieve

until kiln has mud going

into it.

Increase shower flow

and close damper

Startup ends when the

following is true: :(1)

lime mud flow is > 90

GPM, (2) kiln drive is in

continuous rotation, (3)

the feed‐in operating

temperature is >350 degF, (4) the desired

differential pressure andshower flow of the

venturi scrubber is

achieved, and (5)

product has been

discharging from the kilnfor at least five hours. ~1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. Pressure Drop Mud ta

Lime Kiln 145 1 LK SCBRLime Kiln 146 1 LK SCBR 1 1

Scrubber is to be in

operation prior to

introduction of lime mud

Pressure drop on the

scrubber requires

introduction of limemud to allow enough

gas flow through the kiln

to meet the required

setting

Ensure that pressuredrop meets requiredtarget

Introduction of limemud to the lime kiln 0.5 0.5

Control device remains

in operation until lime

mud addition hasstopped NA

Controin oper

mud ad

stoppe

Lime Kiln 147 1 LK SCBR 1 1

Scrubber is brought on line

before lime mud is

introduced to the kiln. Thestart‐up period is irrelevant

for the scrubber as the start‐

up time for the kiln is much

longer.

The applicable emissionand parameter limits are

expected to be met

during startup

Ensure that water flowmeets required target

Desiredflow/pH/pressure drop

obtained 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Lime Kiln 148 1 LK SCBR 0.1 0.1

Must meet Title V

parameters before adding

any fuel to emission unit to

go through the control

device

Control deviceparameters are met

before emission unit is

brought up

Control deviceparameters are metbefore emission unit isbrought up

Control device

parameters are met

before emission unit isbrought up 0.1 0.1

Control device is not

shutdown until theemission unit isshutdown

Control device

parameters are metbefore emission unit is

brought up

Controparamebefore 

brough

Lime Kiln 150 1 LK SCBR 8 8

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

meet liquid flow

parameter limit, meet

differential pressurelimit

scrubber liquid flow rateat setpoint, scrubberdifferential pressure atsetpoint 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be met

during startup

Shutdoemissio

control 

Lime Kiln 151 1 LK SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Lime kiln and ESP are

stable and meeting

normal operationprocess conditions.LVHC, HVLC and SOG are

being collected. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

continuESP unt

stopperotatio

Lime Kiln 151 1 LK SCBR 0.5 0.5

Hours of operation of

control device are tracked

to perform a bubble

calculation which takes into

account each kilnsoperational hours and hours

of burning unscrubbed NCGs n/a

All NCGs are being

collected, the lime kiln

burning gases is stable,and the NCG Scrbber

and NCG Cooler areperforming properly 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

continuand tra

burning NCGs 

Lime Kiln 151 1 LK SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Lime kiln and scribber

are stable and meeting

normal operationprocess conditions.

LVHC, HVLC and SOG are

being collected 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

continu

scrubbe

has storotatio

Lime Kiln 152 1 LK SCBR 0.5 0.5

Control device cannot

function as designed unless

an air flow rate of {15,000}

acfm from the emission unit

is achieved. pressure drop

exceed liquid flowparameter limit

Startup ends when the

pressure dropparameter limit range isachieved 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. 

Lime Kiln 153 1 LK SCBR

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 155 1 LK SCBR 0.5 0.5

scrubber startup achieved in

advance of lime kiln

operation

The applicable emissionand parameter limits are

expected to be met

during startup

liquid flow rate

maintained

liquid flow rate and

pressure drop setpoints

are met 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. dP

Wait un

and ID 

before liquid fLVHC sy

to prim

Lime Kiln 156 2 LK SCBR 0.5 0.5

The controls are always up

and running prior toemission unit startup andare shut down after

emission unit is completely

shutdown.

The applicable emissionand parameter limits are

expected to be met

during startup

Follow SSM plans andprocedures 0.5 0.5

The controls are alwaysup and running prior to

emission unit startupand are shut down after

emission unit iscompletely shutdown.

The applicable emissionand parameter limits areexpected to be met

during startup

Follow 

proced

Lime Kiln 157 1 LK SCBR 0 0 Is not integrated None

Scrubber recirculation

pump operating 0 0 None

Lime Kiln 159 1 LK SCBR

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up. pressure drop

process not operating

until scrubber operatingproperly

meets required pressure

drop

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. pressure drop none 

Lime Kiln 162 1 LK SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

one of the scrubber recycle

pumps are operational.

Scrubber flow rate and

supply pressure limit is met

before fuel firing begins.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and liquid supply

pressure limits are achieved.

Scrubber supplypressure limit cannot be

met instantaneously at

startup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing an oilburner.

Kiln ID Fan is interlocked

with and can only

operate if one of the

scrubber recycle pumps

are operational.Scrubber flow rate and

supply pressure limit is

met before fuel firing

begins. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and liquidsupply pressure limits

are achieved.

Startup ends when the

scrubber flow rate and

supply pressure limits

are achieved. 0.1 Hr 0.1

Scrubber remainsoperational until mud

feed, fuel firing, and ID

fan is stopped . Theemission unit isshutdown before thescrubber is shutdown. None

Scrubbe

operati

feed anstoppe

unit is s

the scru

shutdo

Lime Kiln 163 1 LK SCBR

<1.0 (Cold

Startup) 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.

Startup ends when the

scrubber flow and

pressure dropparameter limits areachieved.

0.1 (Cold

Shutdown) 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

The applicable emissionand parameter limits areexpected to be metduring shtudown.

Scrubbe

only ini

is fed o

potentieliminashut do

Lime Kiln 163 1 LK SCBR

<1.0 (Cold

Startup) 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.

Startup ends when the

scrubber flow and

pressure dropparameter limits areachieved

0.1 (Cold

Shutdown) 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

The applicable emissionand parameter limits areexpected to be metduring shtudown.

Scrubbe

only ini

is fed o

potentieliminashut do

Lime Kiln 164 1 LK SCBR 26 26

26 hour warm up curve for

Lime Kiln (LVHC NCGcontrol). After 18 hours, hot

end is at 1200 F and NCG

can be introduced

kiln hot end

temperature is > 1200 F. 16‐24 24

lime kiln has 16‐24 hourshut down curve whenfeed and fuel are slowly

ramped down before

scrubber can be

shutdown see ear

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 165 2 LK SCBR <1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow limts are achieved.

Scrubber pressure drop

limit cannot be met

instantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber is

operational andscrubber flow limts are

achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be metonce mud is removed

from the kiln.

Scrubbe

only iniis fed o

potentieliminashut do

Lime Kiln 166 2 LK SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be metonce mud is removed

from the kiln.

Scrubbe

only ini

is fed o

potentieliminashut do

Lime Kiln 167 1 LK SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be metonce mud is removed

from the kiln.

Scrubbe

only ini

is fed o

potentieliminashut do

Lime Kiln 169 1 LK SCBR 0.25 0.25

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubberflow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber but is

achieved before lighinga gas or oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.25 0.25

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down. NA

Scrubbe

only iniis fed o

potentielimina

shut do

Lime Kiln 171 2 LK SCBR

LMR to review

SSM

Lime Kiln 172 1 LK SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limit is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limits are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighting a gas oroil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limit is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimits are achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down. None

Scrubbe

only iniis fed o

potentielimina

shut do

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 173 1 LK SCBR < 1 hour 1

Scrubber flow rate limit is

met before lighting oil

burner. Mud is notintroduced to the kiln until

the scrubber is operational

and scrubber flow and

differential pressure limits

are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.

Scrubber flow limit is

not instantaneouslyachieved at startup of

scrubber control device

but is achieved before

lighting the oil burner.

Scrubber flow rate limit

is met before lighting oil

burner. Mud is notintroduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressure

limits are achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits are

achieved. 0.1 hours 0.1

Scrubber shutdown isonly initiated after mud

is out of the kiln,

potential for dusting is

eliminated and ID fan isshut down. NA

Scrubbe

only iniis out o

potentieliminashut do

Lime Kiln 174 1 LK SCBRLime Kiln 174 1 LK SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be metonce mud is removed

from the kiln. (Note toconsultants: Some kilns

may be able to meet thedP limit at all times. If

so, please modify

wording accordingly.

Scrubbe

only iniis fed o

potentieliminashut do

Lime Kiln 175 2 LK SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with and can only operate if

the scrubber recycle pumps

are operational. Scrubber

flow rate limt is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limts are achieved.

(Note to consultants: Some

kilns may not be able to

meet dP until after mudintroduction. If so, please

modify wordingaccordingly.)

Scrubber pressure drop

limit cannot be met

instantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Kiln ID Fan is interlocked

with and can only

operate if the scrubber

recycle pumps areoperational. Scrubberflow rate limt is met

before lighting gas or oil

burners. Mud is not

introduced to the kiln

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.(Note to consultants:

Some kilns may not be

able to meet dP until

after mud introduction.If so, please modifywording accordingly.)

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be metonce mud is removed

from the kiln. (Note toconsultants: Some kilns

may be able to meet thedP limit at all times. If

so, please modify

wording accordingly.

Scrubbe

only iniis fed o

potentieliminashut do

Lime Kiln 176 1 LK SCBR 1 1

Lime kiln scrubber started

and control parameters up

to limits before fire is put in

kiln None

Make sure recirculation

pump is running andflow is at target

Lime kiln scrubber

started and control

parameters up to limits

before fire is put in kiln 1 1

Lime kiln scrubber

including control device

parameters maintained

until four hours after fire

is pulled from kiln None

Lime ki

includinparameuntil thfire is pkiln

Lime Kiln 177 1 LK SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

emission unit is not

operating while

scrubber is down

circulation flow reaches

500 gpm and DP>30 0.0083 0.0083

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

scrubbeoperati

emissio

Lime Kiln 180 2 LK SCBR 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emission

and parameter limits are

expected to be met

during startup

Not feeding mud to kiln

until scrubber is

operating in proper

ranges

scrubber is within limits

on flow (378 gpm) and

dp (9.9 in) 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

Stop fe

before reduce

scrubbeoperati

Lime Kiln 181 2 LK SCBR 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup NA

all operating parameters

limits met 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup NA 

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 184 1 LK SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup N/A

adequate pressuredrops and liquid flows 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup N/A

Lime Kiln 185 1 LK SCBR 1 1

Scrubber circulation flow is

400 gpm or higher and the

output to the scrubber

differential pressurecontroller is in manual at

40% output prior to the

starting the Kiln ID Fan.

Once the ID Fan is running,

adjust the pressure drop

across the venturi to 25

inches of water and then

put the controller in

automatic with a set point

of 25 inches of water

The applicable emissionand parameter limits are

expected to be met

during startup

No. 4 Lime Kiln scrubber

must be operating anddifferential pressure and

circulation flow must be

at or above operating

limits before mud flowto the kiln is initiated

Scrubber differentialpressure and

recirculation rate are at

or above operatinglimits and stable 1 1

Mud flow to the kiln is

shut off, Kiln is put on

slow roll, ID Fan is

turned off and hasstopped, then thescrubber shutdown is

initiated

The applicable emissionand parameter limits areexpected to be metduring shutdown No add

Lime Kiln 188 1 LK SCBR

NA ‐ 

Instantaneous

startup and

shutdown

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Lime Kiln #1 starts after

the control device isstarted up and meetsrequired operating

parameter limits

NA ‐ control device start

up precedes the

emission unit startup.

NA ‐ 

Instantaneous

startup and

shutdown

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Wait un

mud flokiln and has cea

Lime Kiln 188 1 LK SCBR

NA ‐ 

Instantaneous

startup and

shutdown

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Lime Kiln #2 starts after

the control device isstarted up and meetsrequired operating

parameter limits

NA ‐ control device start

up precedes the

emission unit startup.

NA ‐ 

Instantaneous

startup and

shutdown

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Wait un

mud flokiln and has cea

Lime Kiln 188 1 LK SCBR

NA ‐ 

Instantaneous

startup and

shutdown

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Lime Kiln #3 starts after

the control device is

started up and meetsrequired operating

parameter limits

NA ‐ control device start

up precedes the

emission unit startup.

NA ‐ 

Instantaneous

startup and

shutdown

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Wait un

mud flokiln and has cea

Lime Kiln 189 1 LK SCBR 6 6

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Per the SSM Plan,startup and ensure the

minimum scrubber flowrate and differential

pressure have been

established in the

Venturi Scrubber beforeintroducing mud into

the Lime Kiln.

The transition fromstartup to normal

operations will beconsidered completewhen these conditionshave been achieved and

product is flowing outand the operating

temperature is >300F. 3 3

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

Per the 

operati

Scrubbecontinu

has ceaflow of 

stoppe

generat

also cea(approxlater)

Lime Kiln 190 1 LK SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Meet liquid flow and

differential pressureparameter limit 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring shutdown.

Wait unbelow wtemper

switchi

Lime Kiln 190 1 LK SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Meet liquid flow and dp

parameter limit 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits are

expected to be metduring startup

Wait unbelow wtemper

switchi

Lime Kiln 195 1 LK SCBR 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

control device operates

during emission unitstartup Introduction of mud 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

All Cont

remain 

source 

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 196 1 LK SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Ensure scrubber flow

and dp established

Minimum scrubber flowand dp levels achieved 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Fuel feefans slo

Lime Kiln 197 1 LK SCBR 0.08 0.08

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Required operating

parameters are metbefore emission unit isstarted up.

Water is circulatingthrough the system. 1.08 1.08

Control device is

shutdown after emissionunit shutdown.

Emissio

shutdo

Lime Kiln 197 1 LK SCBR 0.1 0.1

Control device can be

started independently of

source startup

Water is circulatingthrough the system. 0.1 0.1

Control device is

shutdown when

emission unit isshutdown

Emissio

shutdo

Lime Kiln 197 1 LK SCBR 0.1 0.1

Control device can be

started independently of

source startup

Water is circulating

through the system. 1.1 1.1

Control device is

shutdown whenemission unit isshutdown

Emissio

shutdo

Lime Kiln 198 1 LK SCBR 8 8

Control device operating

and meets required

scrubbing liquid flow beforeemission unit begins normal

operation. pressure drop

control device operating

prior to processbeginning normaloperation

pressure drop and liquid

flow within normaloperating range, no

alarms 8 8

Control device continues

to operate and meets

required scrubbing

liquid flow while

emission unit is shutdown. pressure drop

control 

to oper

possible shuts d

Lime Kiln 199 1 LK SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure dropparameter limit range isachieved 0.2 0.2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown.

Lime Kiln 201 1 LK SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure dropparameter limit range isachieved 0.2 0.2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown.

Lime Kiln 202 1 LK SCBR

NA ‐ followed by

scrubber NA ‐ No moving parts

The applicable emissionand parameter limits are

expected to be met

during startup Not Applicable Not Defined NA

Bypass valve kept closedduring normal operation

The applicable emissionand parameter limits areexpected to be metduring startup

Keep by 

closed 

Lime Kiln 202 1 LK SCBR 0.02 hour 0.02

Lime kiln does not start up

before kiln scrubber has

been started up.

The applicable emission

and parameter limits are

expected to be met

during startup

Do not start kilnoperation until scrubberflow and supplypressure parameters are

met.

NOT DEFINED ‐ Flow and

dP parameters met for

more than 1 minute 0.02 0.02

Scrubber is keptoperating until, mudflow out of kiln, kilnflame off and gas flow

less than 30.3 SCFM for

more than 1 minute.

Scrubber typicallycontinues to run even if

Emission Unit off unless

scrubber maintenance

needed.

The applicable emissionand parameter limits areexpected to be metduring startup

Keep oas long 

Lime Kiln 203 1 LK SCBR 0.1 0.1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

emission unit shut down

until APCD running

Scrubber operating

parameters established 0.16 0.16

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

lime kil

before 

down 

Lime Kiln 205 1 LK SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure dropparameter limit range is

achieved 0.2 0.2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown.

Lime Kiln 206 1 LK SCBR 0.5 0.5

Control device is operating

with all flows prior to

emission unit start up. pressure drop None

When monitoringparameters are within

specifications 0.5 0.5

Control device remains

in operation until

emission unit has

completed shut down. pressure drop None

Lime Kiln 206 2 LK SCBR 0.5 0.5

Control device is operating

with all flows prior to

emission unit start up. pressure drop None

When monitoringparameters are within

specifications 0.5 0.5

Control device remains

in operation until

emission unit has

completed shut down. pressure drop None

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Lime Kiln 207 1 LK SCBR 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up. differential pressure

differential pressure and

recirculation flow rate

differential at target and

mud flow to kiln 4.5 4.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. differential pressure

Kiln is dbefore shutdo

Lime Kiln 226 2 LK SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure drop minimum

parameter value is

achieved 0.2 0.2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown.

Lime Kiln 340 1 LK SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Pressure drop andcirculation rate

paramters are reached. 0.5 0.5

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

Lime is 

scrubbe

Lime Kiln 525 1 LK SCBR 2 2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

scrubber water is on

during startup

startup ends when

pressure dropparameter limit is met. 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

scrubbe

run dur

Lime Kiln 600 3 LK SCBR < 1 Hr 1

Kiln ID Fan is interlocked

with a minimum scrubberrecirculation flow and can

only operate if the minimum

flow is achieved. Scrubber

flow rate limit is met before

lighting gas or oil burners.

Mud is not introduced to

the kiln until the scrubber is

operational and scrubber

flow and differentialpressure limits can be

achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but can

be achieved beforeprocessing mud.Scrubber flow limit is

not instantaneously

achieved at startup of

the scrubber control

device but is achievedbefore lighting a gas oroil burner.

Kiln ID Fan is interlocked

with a minimum

scrubber recirculation

flow and can onlyoperate if the minimum

flow is achieved.

Scrubber flow rate limit

is met before lighting

gas or oil burners. Mudis not introduced to the

kiln until the scrubber is

operational andscrubber flow and

differential pressurelimits can be achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 Hr 0.1

Scrubber shutdown isonly initiated after mud

is fed out of the kiln,

potential for dusting is

eliminated, and ID fan is

shut down.

Scrubber pressure drop

limit cannot be metonce mud is removed

from the kiln.

Scrubbe

only iniis fed o

potenti

eliminashut do

Lime Kiln 610 1 LK SCBR 0.08 0.08

Control device cannot

function as designed unless

an air flow rate of {8409}

acfm from the emission unit

is achieved. pressure drop

Ensure water is flowing

through the scrubberduring startup

Startup ends when

minimum scrubber flow

and pressure drop isachieved 0.08 0.08

Control device cannot

function as designed

unless an air flow rate of

{8409} acfm from the

emission unit isachieved. pressure drop

Ensure through 

during 

Lime Kiln 610 1 LK SCBR 0.08 0.08

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Startup ends when

minimum scrubber flows

and pressure areachieved 0.08 0.08

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Lime Kiln 613 1 LK SCBR 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Minimum scrubber flow

rate and differential

pressure must meet

minimum requirements.

Scrubber flow rate and

differential pressure

must meet minimum

requirements. 3 3

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

Ensure 

has bee

two ho

lime m

Lime Kiln 615 1 LK SCBR 0.25 0.25

scrubber parameters

established prior to lime

mud feed pressure drop

meet liquid flow

parameter limit

scrubber parameters

accomplished 0.25 0.25

control device continues

to operate after unit is

shutdown; liquid flow ismaintained; however

pressure drop cannot be

maintained due todecrease of air flow pressure drop mainta

Lime Kiln 2.1E+08 1 LK SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure dropparameter limit range is

achieved 0.2 0.2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during shutdown.

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

Recovery Furnaces

DCE 105 1 RF ESP

DCE 119 1 RF ESP

DCE 119 1 RF ESP 2 2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be metduring start‐up.

Normal operation is

achieved when therecovery furnace is off

fuel oil and is burning

black liquor solids. 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

None expected duringcontrol device shutdowndue to emissions source

down.

DCE 121 2 RF ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup ESP is on ESP is powered up 0.75 0.75

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown

Controto oper

require

limits wunit is s

DCE 124 1 RF ESP 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

All fields in operation, at

temperature 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. 

DCE 124 2 RF ESP 2 2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

All fields in operation, at

temperature 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. 

DCE 130 2 RF ESP 6 Hrs 6

SOP: ESP is operational

(Power is applied to

tranformer rectifiers afterESP penthouse heaters have

been on 4 to 6 hours) before

black liquor is introduced to

the recovery furnace.

Power is applied to

tranformer rectifiers

after ESP penthouse

heaters have been on 4to 6 hours, but before

black liquor is

introduced to the

recovery furnace.

SOP: ESP is operational

(Power is applied totranformer rectifiersafter ESP penthouse

heaters have been on 4

to 6 hours) before blackliquor is introduced tothe recovery furnace.

The end of ESP startup

and beginning of normaloperations occur when

all ESP components aretotally operational(Power is applied to

tranformer rectifiersafter ESP penthouse

heaters have been on 4

to 6 hours). 4 to 6 Hrs 6

SOP: ESP continues to

operate while Recovery

Furnace is shut down.ESP remains fully

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out/smelted

out, and the last oil or

gas burner is removed.

Power is applied to

tranformer rectifiersafter ESP penthouseheaters have been on 4

to 6 hours, but beforeblack liquor is

introduced to the

recovery furnace. ESPcomponents aredeenergized during the

ESP shutdown process.

SOP: ES

operate 

Furnace 

ESP rem

operatiblack liq

from thfurnace

is burne

out, an

gas bur

DCE 131 3 RF ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Do not start furnaceuntil precipitator fieldsare operational All fields on 5 5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Wait un

furnace shutdo

DCE 142 1 RF ESP ~0.01 0.01

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emission

and parameter limits are

expected to be met

during startup.

Startup of control deviceis near instantaneous.

Startup ends when the

power to all sections is

turned on. ~0.01 0.01

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during shutdown

Shutdodevice instant

DCE 142 1 RF ESP ~0.01 0.01

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup.

Startup of control device

is near instantaneous.

Startup ends when the

power to all sections is

turned on. ~0.01 0.01

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown

Shutdodevice instant

DCE 143 3 RF ESP

Control devicestartup time is

included in the

startup time

provided for the

emissions unit

on the

Equip_Detail

Tab.

Control device is started up

and meets operational

parameters when

operational permissivespecified in the SSM Plan

are met, including transition

from fossil fuel to black

liquor firing

Opacity and Total

Secondary Power to the

ESP may not be met

until the recoveryfurnace is fully online.

ESP is ready to start atthe time black liquor is

introduced to therecovery furnace.

ESP is fully operationalwithin 1 hour of the

time black liquor is

introduced to the

recovery furnace.

Control device

shutdown time

is included in

the shutdown

time provided

for the

emissions unit

on the

Equip_Detail

Tab

Control device continues

to operate until black

liquor firing ceases.

Opacity and Total

Secondary Power to the

ESP may not be met as

the recovery furnace is

being shutdown .

ESP conoperate 

liquor f

DCE 145 4 RF ESP 2 2

Control device cannot

function as designed unless

an air flow rate of 27,000

acfm from the emission unit

is achieved.

The applicable emissionand parameter limits are

expected to be met

during startup

Activate heating and

purge system

Black liquor firing beginsand precipitatortemperatures attainnormal operatingtemperatures 0.5 0.5

Control device cannot

function as designedunless an air flow rate of

27,000 acfm from the

emission unit isachieved.

The applicable emissionand parameter limits areexpected to be metduring startup

Precipit

isolated 

with an 

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

DCE 146 1 RF ESP 2 2

ESP is to be in operation

prior to introduction of

black liquor in the recovery

furnace NA

Ensure that power is

applied to ESP

Introdution of blackliquor to the recoveryfurnace 0.5 0.5

Control device remains

in operation until after

black liquor addition has

stopped NA

Controin oper

black liq

stoppe

DCE 151 1 RF ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Five ESP T/R sets are in

service and powered up

when on oil only, and

nine ESP T/R sets are in

service and powered up

before plaing liquor in

the recovery boiler. TheESP inlet and outlet

damplers are open, and

all ESP access doors areclosed. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

continu

until bl

stopperecover

DCE 154 2 RF ESP 8 8

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emission

and parameter limits are

expected to be met

during startup

Process does notoperate until ESP isoperating

when wet bottom levelset point is met and the

TR controllers are

normal and the boiler is

operating 6 6

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

ESP opethe recdown.

DCE 154 1 RF ESP 8 8

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Process does not

operate until ESP isoperating

when wet bottom levelset point is met and the

TR controllers are

normal and the boiler is

operating 6 6

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

ESP opethe recdown.

DCE 156 2 RF ESP 6 6

ESPs are always up and

running prior to emission

unit startup and are shut

down after emission unit is

completely shutdown.

The applicable emissionand parameter limits are

expected to be met

during startup

Follow SSM plans andprocedures

Starting point of an ESP

is completely down until

it is completely

energized to perform itsfunction (T/R units and

rappers on, dust

collection system on and

ESP damper in). 6 6

ESPs are always up and

running prior to

emission unit startupand are shut down after

emission unit iscompletely shutdown.

The applicable emissionand parameter limits areexpected to be metduring startup

Follow 

proced

DCE 163 2 RF ESP 12 (Cold Startup) 12

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

The applicable emissionand parameter limits are

expected to be met

during startup

Power is applied to

tranformer rectifiers

after the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace only

after the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers.

1 (Cold

Shutdown) 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bed

is burned out/smelted

out and the last oil or

gas burner is removed.

The applicable emissionand parameter limits areexpected to be metduring shtudown

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

DCE 166 1 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line. NA

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

NA

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

DCE 167 2 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line. NA

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

NA

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

DCE 171 3 RF ESP

LMR to review

SSM

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

DCE 174 1 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

NA Facility MonitorsOpacity

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internaltemperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed. NA, Facility monitors

opacity

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

DCE 175 1 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line. NA

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

NA

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

DCE 188 1 RF ESP

NA ‐ 

Instantaneous

startup and

shutdown

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Recovery Boiler #1 starts

after the control device

is started up and

compliance with opacitystandard isdemonstrated

NA ‐ control device start

up precedes the

emission unit startup.

NA ‐ 

Instantaneous

startup and

shutdown

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

ESP left 

is burne

DCE 188 1 RF ESP

NA ‐ 

Instantaneous

startup and

shutdown

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Recovery Boiler #2 starts

after the control device

is started up and

compliance with opacitystandard isdemonstrated

NA ‐ control device start

up precedes the

emission unit startup.

NA ‐ 

Instantaneous

startup and

shutdown

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

ESP left 

is burne

DCE 205 2 RF ESP 8 8

Control device is started up

and meets required

operating parameter limitsat the time that black liquor

firing is commenced.

Startup ends when black

liquor is introduced into

recovery furnace 0.2 0.2

Control device continues

to operate and meets

required operatinglimits until black liquor

firing is ceased.

DCE 206 1 RF ESP 0.5 0.5

ESP put in operation prior to

firing blackliquor

The applicable emissionand parameter limits are

expected to be met

during startup None

When normal operating

voltages in each

chaimber are achieved. 0.5 0.5

ESP not shut down untilthe recovery furnace

discontinues black liquor

firing

The applicable emissionand parameter limits areexpected to be metduring startup None

DCE 206 1 RF ESP 0.5 0.5

ESP put in operation prior to

firing blackliquor

The applicable emissionand parameter limits are

expected to be met

during startup None

When normal operating

voltages in each

chaimber are achieved. 0.5 0.5

ESP not shut down untilthe recovery furnace

discontinues black liquor

firing

The applicable emissionand parameter limits areexpected to be metduring startup None

DCE 600 1 RF ESP 10 Hrs 10

Power is applied to

transformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

The applicable emissionand parameter limits are

expected to be met

during startup

Power is applied to

transformer rectifiers

after the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to the

recovery furnace only

after the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to transformerrectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

NA

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

DCE 606 1 RF ESP 1 1

Not integrated. Standard

procedure is for control

device to start up ahead of

emissions unit.

Fields are energized and

ancillary systems startedup.

Fields energized andstable, ancillary systems

funtioning normally. 1 1

Not integrated.

Standard procedure isfor control device to

shutdown afteremissions unit. no fire 

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

DCE 613 2 RF ESP 2 2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

Inlet and outlettemperatures are

monitored as theprecipitators warm up

while the boiler is

concurrently started up.

Outlet, inlet and center

field power is at 100%.

Rappers must be in

operation. 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Power and rap

minimuliquor iboiler. have be

mins, th

graduaopacity 

during 

power 

manua

increasshutdo

DCE 613 1 RF ESP 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Inlet and outlettemperatures are

monitored as theprecipitators warm up

while the boiler is

concurrently started up.

Outlet, inlet and center

field power is at 100%.

Rappers must be in

operation. 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Power and rap

minimuliquor i

boiler. 

have be

mins, th

graduaopacity 

during 

power 

manua

increasshutdo

DCE 613 1 RF ESP 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Inlet and outlettemperatures are

monitored as the

precipitators warm up

while the boiler is

concurrently started up.

Outlet, inlet and center

field power is at 100%.

Rappers must be in

operation. 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Power 

and rap

minimuliquor iboiler. have be

mins, th

graduaopacity 

during 

power 

manua

increasshutdo

NDCE 100 1 RF ESP ~7 Hrs 7

Power is applied to

transformer rectifiers afterthe ESP internal

temperature reaches the

minimum temperaturespecified by Mill

procedures. Black liquor isintroduced to the recovery

furnace only after the ESP is

brought on‐line.

The applicable emissionand parameter limits are

expected to be met

during startup

Power is applied to

transformer rectifiers

after the ESP internal

temperature reaches

the minimum

temperature specified

by Mill procedures.

Black liquor isintroduced to therecovery furnance only

after the ESP is brought

on‐line.

Startup ends when the

scrubber flow rate and

pressure drop limits are

achieved. ~0.1 Hr 0.1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

The applicable emissionand parameter limits areexpected to be metduring startup

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 102 1 RF ESP 3 3

One or more precipitator

chamber is partiallypowered up prior to igniting

fuel oil burners at beginning

of cold startup. One or more

precipitator chamber isoperating at full power

before black liquor solidsfiring begins. See Part III

response for more. opacity

The precipitator is

operated on partial

power to minimize

emissions during

startup, unless there isexcessive mositure,arcing or sparking for

safe operation.

Precipitator fields reach

power setpoints. 0 0

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Controto oper

require

limits wunit is s

NDCE 103 1 RF ESP 8 8

Control device is operating

within specifications prior to

start‐up of the recovery

furnace. opacity

ESP remains in service

until the emissions unit

has completedshutdown.

The ESP reaches the

required operating

temperature. 0.2 0.2

Control device operates

until emissions unit hascompleted shutdown.

The applicable emissionand parameter limits areexpected to be metduring startup

Contro

until em

comple

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 104 1 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor is

introduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bed

is burned out/smelted

out and the last oil or

gas burner is removed.

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 105 1 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

The applicable emissionand parameter limits are

expected to be met

during startup

Power is applied to

tranformer rectifiers

after the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace only

after the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

The applicable emissionand parameter limits areexpected to be metduring shutdown

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 107 1 RF ESP 0.5 0.5

Control device cannot start

up until flue gastemperatures reach 240F temperature

fire natural gas only

during period of start up

Control device start up

is complete one

precipitator is in service.

Normal operating

conditions begin after afiring rate of 180 gpm of

black liquor has been

reached. 0.5 0.5

One hour after emission

unit is shutdown the

power is shut off to the

precipitator.

Control device is started

up and meets required

operating parameter

limits before emission

unit is started up.

Controto oper

emissiodown

NDCE 108 1 RF ESP 1‐4 4

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

No applicable operatinglimits

Black liquor isintroduced to the

recovery furnace onlyafter the ESP is brought

on‐line.

When ESP internaltemperature reaches

target value and power

is applied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

Not applicable

ESP rem

until al

pulled f

furnace

is burne

out and 

gas bur

NDCE 109 1 RF ESP 10 10

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Emission Unit is not

started until control is

steady state

When ESP tempeature is

at target and steady

state 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Controshutdo

Unit is S

NDCE 109 1 RF ESP 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Emission Unit is notstarted until control is

steady state

When ESP tempeature is

at target and steady

state 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Controshutdo

Unit is S

NDCE 111 1 RF ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

verify control device isin operation

Power is shut off to the

CD 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

CD remoperatishut do

NDCE 112 1 RF ESP

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

control operating

parameters met before

process start‐up

ESP up to full operating

power 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

control 

process 

NDCE 114 1 RF ESP 6 6

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Total power >75% of

established value in last

performance test 7 7

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 115 2 RF ESP 12 12

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup heated up and online

Minimum power

achieved 0 0

Control device operates

until process is downand no emissions being

generated None NA

NDCE 115 4 RF ESP NA

NDCE 116 1 RF ESP ~10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

Note to consultants:

Likely NA unless boiler

cannot meet opacitywhen starting up on oilbefore ESP is entergized.

If a facility is required tomonitor power, current

and/or voltage, as ESP

parameters, describe if

these cannot be metduring ESP startup.

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internaltemperature reaches200  ̊F and power is

applied to tranformer

rectifiers. ~1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

Note to consultants:

Likely NA if only requred

to meet opacity(confirm with the mill).If requried to monitor

power, current and/orvoltage as ESP

parameters, describe if

these cannot be metduring ESP shtdown.

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 117 1 RF ESP 12‐16 16

Precipitator does notcontrol as efficiently on start‐up because of sooty oil

deposits at coolertemperatures. The

precipitator operates

efficiently after thetemperature is hotter, the

oil deposits are burned off

and the plates get a light

coating of salt cake. Opacity (20%)

Minimizing Oil Use onStart‐Up, minimizing

Black Liquor Firing Ratein B21, Starting Up C21

before Start‐Up of B21.Burning Natural Gas on

Start‐Up to get a hooter

temperature to prevent

sooty oil deposits in the

precipitator.

Opacity <20% with B21

at full production rate. 12 12

Need to allow Recovery

Boiler (B21) to burndown entirely beforeC21 is shutdown.. Opacity (20%)

Minimi

Firing R

Shuttin

shutdo

NDCE 119 1 RF ESP

NDCE 119 1 RF ESP 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be metduring start‐up.

Normal operation is

achieved when therecovery furnace is offfuel oil and is burningblack liquor solids. 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

None expected duringcontrol device shutdowndue to emissions source

down.

NDCE 120 1 RF ESP <1hr 1

Two cells are brought up to

temperature before furnace

start up & Transformer on Total Power No liquor is fired Full power and ESP temp

Runs until the

process stops

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Contiues to operateuntil no fuels feed to the

furnace

Power 

liquor i

furnace

NDCE 126 1 RF ESP 3 hours 3

Several TRs per precipitator

are operational during start

up and all TRs energized

prior to introducing black

liquor to the recovery

furnace. NA

Several TRs per

precipitator areoperational during start

up and all TRs energized

prior to introducingblack liquor to the

recovery furnace.

Black liquor is

introduced to the

recovery furnace, astable furnace bed is

obtained, and a

consistent smelt flow to

the dissolving tank is

achieved and fuel oil

firing ceases. <1 hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out, and the last oil

burner is removed. NA

ESP rem

until al

pulled f

furnace

is burne

out, an

burner 

NDCE 127 1 RF ESP 0.5 0.5

must establish black liquor

solids feed to Recovery

Boiler before starting ESP

Normal power outputfromtransformer/rectifiers is

established and normaloperation of rappers isvisually confirmed 0.5 0.5

must shut down ESP

when no longer feedingblack liquor solids to

Recovery Boiler opacity

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 130 1 RF ESP 6 Hrs 6

SOP: ESP is operational

(Power is applied to

tranformer rectifiers afterESP penthouse heaters have

been on 4 to 6 hours) before

black liquor is introduced to

the recovery furnace.

Power is applied to

tranformer rectifiers

after ESP penthouse

heaters have been on 4

to 6 hours, but before

black liquor is

introduced to the

recovery furnace.

SOP: ESP is operational

(Power is applied to

tranformer rectifiersafter ESP penthouse

heaters have been on 4to 6 hours) before blackliquor is introduced tothe recovery furnace.

The end of ESP startup

and beginning of normal

operations occur whenall ESP components are

totally operational(Power is applied to

tranformer rectifiersafter ESP penthouse

heaters have been on 4

to 6 hours). 4 to 6 Hrs 6

SOP: ESP continues to

operate while Recovery

Furnace is shut down.ESP remains fully

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out/smelted

out, and the last oil or

gas burner is removed.

Power is applied to

tranformer rectifiersafter ESP penthouseheaters have been on 4

to 6 hours, but beforeblack liquor is

introduced to the

recovery furnace. ESPcomponents aredeenergized during the

ESP shutdown process.

SOP: ES

operate 

Furnace 

ESP rem

operatiblack liq

from thfurnace

is burne

out, an

gas bur

NDCE 131 2 RF ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Do not start furnaceuntil precipitator fieldsare operational All fields on 6 6

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Wait un

furnace shutdo

NDCE 132 2 RF ESP 6 6

Control device is partially

energized prior to EU

startup. Control device iscompletely operational prior

to the introduction of black

liquor.

Black Liquor is not

introduced until controldevices meet

operational limits.

Black Liquor isintroduced to EU. 1 1

Control device remains

operational until the EU

is shutdown

NDCE 133 1 RF ESP 0.1 0.1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

precipitator is fully

energized 0.1 0.1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

NDCE 135 3 RF ESP 6 6

The precip chamber can be

started on limited TR's using

heater systems prior to

operation of the Recovery

Boiler opacity

Control device is started

up prior to the firing of

any fuel in the boiler.

All precipitator chamber

TRs are on. 0.5 0.5

Control device can be

operated separate from

the emissions unit until

the temperature is

below dew point. opacity

Controoperateshutdounit.

NDCE 137 1 RF ESP 3.5 3.5

Follow boiler warm up curve

prior to starting

The applicable emissionand parameter limits are

expected to be met

during startup

delay process

equipment startup

Precipitator inlet andoutlet dampers are

open, and all

precipitator acess doors

are closed. Chambersare keyed in andpowered up by an

electrical and

instrument technician.

The chamber floor

heaters are turned on.

The precipitator ash

handling system,including the rotary sealvalve, transfer drag

conveyor, east and west

cross conveyors and

precipitator drag scraperhas been started. 24 24

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Mainta

control 

long as 

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 137 1 RF ESP 4.5 4.5

Follow boiler warm up curve

prior to starting

The applicable emissionand parameter limits are

expected to be met

during startup

delay process

equipment startup

Precipitator inlet and

outlet dampers areopen, and all

precipitator acess doors

are closed. Chambersare keyed in andpowered up by an

electrical and

instrument technician.

The chamber floor

heaters are turned on.

The precipitator ash

handling system,including the rotary sealvalve, transfer drag

conveyor, east and west

cross conveyors and

precipitator drag scraperhas been started. 38 38

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

Mainta

control 

long as 

NDCE 138 1 RF ESP 2 2

A natural gas fire is

established in the Recovery

Furnace and maintained to

heat up and dry out the ESP.

The control device can not

be energized until the ESP is

dry.

The applicable emissionand parameter limits are

expected to be met

during startup

Proper operation andstartup of the recovery

furnace

Energizing ESP fields,

commencement ofliquor firing 3 3

liquor firing ceases 2hours prior to de‐

energizing the ESP Opacity

Rappin

plates i

to de‐e

ESP. Ai

NDCE 139 1 RF ESP 2 2

Discharge temperature

must be above 240 F by

using penthouse heatersand oil during warm‐up

period, prior to startup of

T/R controls

Control devise is started

prior to initiating black

liquor flow to furnace

Power is supplied tofields and ashconveyance system is in

operation 0.5 0.5

Contro

to oper

longer 

liquor f

NDCE 139 1 RF ESP 2 2

Discharge temperaturemust be above 240 F by

using penthouse heaters

and oil during warm‐up

period, prior to startup of

T/R controls

Control devise is started

prior to initiating black

liquor flow to furnace

Power is supplied tofields and ash

conveyance system is in

operation 0.5 0.5

Contro

to operlonger 

liquor f

NDCE 140 1 RF ESP 4 4

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

control device is

operating prior to

emission unit start up.

ESP is up to temperature

and all fields are

energized 4 4

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

RF liquo

discontESP shu

continu

RF cool

NDCE 142 1 RF ESP ~0.01 0.01

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup.

Startup of control deviceis near instantaneous.

Startup ends when the

power to all sections is

turned on. ~0.01 0.01

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring shutdown

Shutdodevice 

instant

NDCE 146 1 RF ESP 2 2

ESP is to be in operation

prior to introduction of

black liquor in the recovery

furnace NA

Ensure that power is

applied to ESP

Introdution of blackliquor to the recoveryfurnace 0.5 0.5

Control device remains

in operation until after

black liquor addition has

stopped NA

Controin oper

black liq

stoppe

NDCE 147 2 RF ESP 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Ensure that power is

applied to ESP All T/R are in operation 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

NDCE 148 2 RF ESP 0.25 0.25

Must meet Title V

parameters before adding

any fuel to emission unit to

go through the control

device

Control deviceparameters are met

before emission unit is

brought up

Control deviceparameters are metbefore emission unit isbrought up

Control device

parameters are met

before emission unit isbrought up 0.25 0.25

Control device is not

shutdown until theemission unit is

shutdown

Control device

parameters are metbefore emission unit is

brought up

Controparamebefore 

brough

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 149 1 RF ESP 4 4

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

T/R units are turned on

and flue gas

temperature of the

emission unit is > 200

deg F. 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

NDCE 150 1 RF ESP 10 10

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

all precipitatorchambers are energized 8 8

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

NDCE 151 1 RF ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Five ESP T/R sets are in

service and powered up

when on oil only, andnine ESP T/R sets are in

service and powered up

before plaing liquor in

the recovery boiler. TheESP inlet and outlet

damplers are open, and

all ESP access doors are

closed. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

continu

until bl

stopperecover

NDCE 155 1 RF ESP 2 2

voltage to rear fields will be

limited and staged throughrecovery furnace operation

on black liquor solids

The applicable emissionand parameter limits are

expected to be met

during startup

monitoring of stack

opacity values during

startup curve on blackliquor solids 2 2

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

If two o

fields a

service 

of the E

line, resolids f

77,600 

is taken 

the rec

shut do

NDCE 156 1 RF ESP 6 6

ESPs are always up and

running prior to emission

unit startup and are shut

down after emission unit is

completely shutdown.

The applicable emissionand parameter limits are

expected to be met

during startup

Follow SSM plans and

procedures

Starting point of an ESP

is completely down until

it is completely

energized to perform itsfunction (T/R units and

rappers on, dust

collection system on and

ESP damper in). 6 6

ESPs are always up and

running prior to

emission unit startupand are shut down after

emission unit iscompletely shutdown.

The applicable emissionand parameter limits areexpected to be metduring startup

Follow 

proced

NDCE 157 1 RF ESP 2 2 Is not integrated None

Power on transformer

recifiers 0 0 None

NDCE 162 2 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

NA, Facility monitors

opacity

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor is

introduced to therecovery furnace onlyafter the ESP is brought

on‐line.

Startup ends when ESP

internal temperature

reaches 200  ̊F and

power is applied to

tranformer rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bed

is burned out/smelted

out and the last oil

burner is removed. NA, facility monitors

opacity

ESP rem

until alpulled f

furnace

is burne

out and 

burner 

NDCE 163 2 RF ESP 12 (Cold Startup) 12

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

The applicable emissionand parameter limits are

expected to be met

during startup

Power is applied to

tranformer rectifiers

after the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace only

after the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers.

1 (Cold

Shutdown) 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bed

is burned out/smelted

out and the last oil or

gas burner is removed.

The applicable emissionand parameter limits areexpected to be metduring shtudown

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 164 4 RF ESP 9 9

9 hours from cold startup 8

hour warmup for ESP case

heaters + 1 hour for TR sets

ESP case heater is up to

temperature and TR sets

is energized for hour 5.5 5.5

ESP must operate for 2hours after black liquor

burning has stopped see ear

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 165 4 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

The applicable emissionand parameter limits are

expected to be met

during startup

Power is applied to

tranformer rectifiers

after the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace only

after the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

The applicable emissionand parameter limits areexpected to be metduring startup

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 169 2 RF ESP 0.25 0.25

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches Target

value. Black liquor is

introduced to the recovery

furnace only after the ESP is

brought on‐line. NA

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

target value. Blackliquor is introduced to

the recovery furnace

only after the ESP isbrought on‐line.

When ESP internal

temperaturereachestarget value and

power is applied to

tranformer rectifiers. 0.25 0.25

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

NA

ESP rem

until al

pulled f

furnace

is burne

out and 

gas bur

NDCE 172 2 RF ESP 10 Hrs 10

Power is applied to

transformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line. Opacity when firing oil

Power is applied to

transformer rectifiers

after the ESP internal

temperature reaches

200  ̊F. Black liquor is

introduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internaltemperature reaches200  ̊F and power isapplied to transformerrectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

Not Applicable

ESP rem

until al

pulled f

furnace

is burne

out and 

gas bur

NDCE 173 1 RF ESP 1 hour 1

Oil and black liquor are

introduced to the recovery

furnace only after the ESP is

brought on‐line. NA

Oil and black liquor are

introduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When power is appliedto transformer rectifiers. <1 hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out, and the last oil

burner is removed. NA

ESP rem

until al

pulled f

furnace

is burne

out, an

burner 

NDCE 173 1 RF ESP 1 hour 1

Oil and black liquor are

introduced to the recovery

furnace only after the ESP is

brought on‐line. NA

Oil and black liquor are

introduced to the

recovery furnace only

after the ESP is brought

on‐line.

When power is applied

to transformer rectifiers. <1 hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out, and the last oil

burner is removed. NA

ESP rem

until al

pulled f

furnace

is burne

out, an

burner 

NDCE 174 1 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

NA Facility MonitorsOpacity

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internaltemperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed. NA, Facility monitors

opacity

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 175 1 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line. NA

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

NA

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 176 1 RF ESP 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up. None 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. None

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 177 1 RF ESP

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

emission unit is not

operating while

scrubber is down Voltage Off 0.4 0.4

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

NDCE 178 2 RF ESP ~10 Hrs 10

Power is applied to

tranformer rectifiers after

the ESP internaltemperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line. N/A

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. ~1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

N/A

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 179 1 RF ESP 0.083‐0.167 0.167

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

N/A ‐ Control device isstarted up beforeprocess is started up

ESP is ready to receivegases from the recovery

furnace. 0.083‐0.167 0.167

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

N/A ‐ P

down b

device 

comme

NDCE 180 1 RF ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Power up ESP prior toboiler startup, drag

conveyors running ESP powered up 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Mainta

during 

NDCE 181 1 RF ESP 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup NA all fields energized 1 1

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup NA 

NDCE 181 1 RF ESP 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emission

and parameter limits are

expected to be met

during startup NA all fields energized 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup NA 

NDCE 181 1 RF ESP 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup NA all fields energized 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup NA 

NDCE 181 1 RF ESP 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup NA all fields energized 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup NA 

NDCE 182 1 RF ESP 0.5 0.5

There is not interlock

device. Policy and

Procedures mandate that

fields are fully energized

prior to burning of black

liquor none

No possible emissions.

Black liquor is notintroduced until all field

are fully energized. All fields are energized 0.5 0.5

There is not interlockdevice. Policy andProcedures are

implemented. none

No posBLS flow 

Dampe

NDCE 184 2 RF ESP 3 3

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up (i.e. firing blackliquor).

The applicable emission

and parameter limits are

expected to be met

during startup N/A

all TRs on and

functioning 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup N/A 

NDCE 186 1 RF ESP 0.16 0.16

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

ESP is operating asnormal

Once parameters aremet 0.16 0.16

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

ESP is onormal

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 186 1 RF ESP 0.33 0.33

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Scrubber fan amps and

recirculation flow

Once parameters aremet 0.33 0.33

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Scrubbe

normal

NDCE 189 1 RF ESP 8 8

When firing four liquornozzles are in service

energize the north andsouth chamber precipitator

fields.Verify that a pilot or

auxiliary fuel burner is

operating at the liquor firing

nozzles.Ensure the boiler is

operating on thesupplemental fuel burner

and producing steam.

(100,000 lbs STM before

injecting black liquor)

Ensure the stack opacity

monitoring system is

operating normally.Ensure the ESP ash recovery

system is operating

normally.Verify the ESP is heated andthe ESP T‐R sets are

powered.Verify that the ESP control

system is operating

normally.

The applicable emissionand parameter limits are

expected to be met

during startup

The recovery furnaceshould be fully

operational firing

supplemental fuel and

the ESP heated and fully

operational prior to the

introduction of black

liquor into the boiler.

The startup period ends

and operation beginswhen full strength green

liquor is pumped to the

recausticizing operation. 6 6

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

Per the 

ESP seremissioRecoveshould 

operatiliquor iburned longer 

NDCE 190 1 RF ESP 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

When secondary voltage

and current meetsminimum criteria 1 1

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

NDCE 190 2 RF ESP 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

When secondary voltage

and current meetsminimum criteria 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

NDCE 195 1 RF ESP 10 10

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

control device operates

during emission unitstartup

Boiler at Pressure (850

psi) 18 18

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

All Cont

remain source 

NDCE 196 2 RF ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Ensure power is on the

ESP ESP powered up 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Fuel fee

fans slo

NDCE 198 1 RF ESP 39 39

Control device is operating

and meets required

operating parameter limitsbefore emission unit begins

normal operation.

control device operating

prior to processbeginning normaloperation

opacity within normal

operating range, no

alarms 39 39

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

control 

to oper

possible shuts d

NDCE 199 1 RF ESP 0.2 0.2

Control device is started up

and meets required

operating parameter limits

at the time that black liquorfiring is commenced.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when black

liquor is introduced into

recovery furnace 0.2 0.2

Control device continues

to operate and meets

required operatinglimits until black liquor

firing is ceased.

The applicable emissionand parameter limits areexpected to be metduring shutdown.

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 200 1 RF ESP 2 2

Control device is operating

and meets required

operating parameter limits

before emission unit begins

normal operation.

The applicable emissionand parameter limits are

expected to be met

during startup

control device operating

prior to processbeginning normaloperation

Verification that the

fields, rappers, andhopper screws are

operating and the COMS

is clean and on‐line. UK

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

control to oper

possible shuts d

NDCE 200 1 RF ESP 2 2

Control device is operating

and meets required

operating parameter limitsbefore emission unit begins

normal operation.

The applicable emissionand parameter limits are

expected to be met

during startup

control device operating

prior to processbeginning normaloperation

Verification that the

fields, rappers, andhopper screws are

operating and the COMS

is clean and on‐line. UK

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

control to oper

possible shuts d

NDCE 201 1 RF ESP 1 1

Control device is started up

and meets required

operating parameter limitsat the time that black liquor

firing is commenced.

Startup ends when black

liquor is introduced into

recovery furnace 0.2 0.2

Control device continues

to operate and meets

required operating

limits until black liquor

firing is ceased.

NDCE 207 1 RF ESP 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Unit on before start up

of recovery boiler

voltages, spark rate,

current have to be at

target before recovery

boiler started 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

unit norecover

and ID 

NDCE 226 1 RF ESP 2 2

Control device is started up

and meets required

operating parameter limitsat the time that black liquor

firing is commenced.

Startup ends when black

liquor is introduced into

recovery furnace 0.2 0.2

Control device continues

to operate and meets

required operatinglimits until black liquor

firing is ceased.

NDCE 226 1 RF ESP 2 2

Control device is started up

and meets required

operating parameter limits

at the time that black liquorfiring is commenced.

Startup ends when black

liquor is introduced into

recovery furnace 0.2 0.2

Control device continues

to operate and meets

required operating

limits until black liquor

firing is ceased.

NDCE 240 2 RF ESP <0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup.

Control device is startedup before emission unitis started up.

Precipitator fields are

energized. <0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup.

Emissiodown b

device 

NDCE 240 2 RF ESP <0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup.

Control device is startedup before emission unitis started up.

Precipitator fields are

energized. <0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup.

Emissiodown b

device 

NDCE 242 1 RF ESP 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up. NA

All ESP fields are

operation before

emissions unit is start up

All fields on and inlet

and outlet dampersopen 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. NA

Controto oper

require

limits wunit is s

NDCE 243 2 RF ESP 0.25 0.25

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Meet required permitparameter limits

Startup ends when all of

the permitted

parameter limits areachieved 0.1 0.1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Meet re

parame

NDCE 340 1 RF ESP 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

Amp Load increases astemperature is reached. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Liquor s

boiler b

down

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

NDCE 525 1 RF ESP 2 2

Control device cannot be

started prior to emission

unit starting up due to

safety issue or risk of

property damage. {Explain}

Risk of damage to electrical

equipment in precipitatordue to moisture and low

temperature. Precipitator isenergized as unit is warmed

up.

The applicable emissionand parameter limits are

expected to be met

during startup

precipitator is energized

before BLS are fired.

precipitator is fully

energized 2 2

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

precipit

during 

NDCE 531 1 RF ESP 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line. NA

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

NA

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 600 1 RF ESP

Power is applied to

transformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line.

The applicable emissionand parameter limits are

expected to be met

during startup

Power is applied to

transformer rectifiers

after the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to the

recovery furnace only

after the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to transformerrectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

NA

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

NDCE 606 1 RF ESP 1 1

Not integrated. Standard

procedure is for control

device to start up ahead of

emissions unit.

Fields are energized and

ancillary systems startedup.

Fields energized andstable, ancillary systems

funtioning normally. 1 1

Not integrated.

Standard procedure isfor control device to

shutdown afteremissions unit. no fire 

NDCE 606 1 RF ESP 1 1

Not integrated. Standard

procedure is for control

device to start up ahead of

emissions unit.

Fields are energized and

ancillary systems startedup.

Fields energized andstable, ancillary systems

funtioning normally. 1 1

Not integrated.

Standard procedure isfor control device to

shutdown afteremissions unit. no fire 

NDCE 610 2 RF ESP 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Precipitator startup

occurs when the power

is placed on the fields

and the dampers are

opened. The end ofstartup is when thedampers are fully

opened. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Recoveand oil 

NDCE 615 1 RF ESP 0.25 0.25

esp parameters on prior to

black liquor feed

esp parameters

accomplished 0.25 0.25

control device continues

to operate after unit is

shutdown

mainta

after bl

nozzles 

NDCE 617 1 RF ESP 0.5 0.5

control device is fully

operational before process

is started up

The applicable emissionand parameter limits are

expected to be met

during startup

process does not startup until control device isready

ESP secondary voltage

at 30‐60 kV 0.5 0.5

control device is not

shut down until process

is down

The applicable emissionand parameter limits areexpected to be met

during startup

continu

control process 

NDCE 2.1E+08 2 RF ESP 4 4

Control device is started up

and meets required

operating parameter limits

at the time that black liquor

firing is commenced.

Black liquor is notburned until control

device startup has been

completed.

Startup ends when black

liquor is introduced into

recovery furnace 0.2 0.2

Control device continues

to operate and meets

required operatinglimits until black liquor

firing is ceased.

Black liceased 

control 

shutdo

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

DCE 152 1 RF ESP/SCBR 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when

recirculation flowexceeds the minimum

flow rate 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. 

DCE 152 1 RF ESP/SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when all

precipitator fields are

powered up andmeeting minimum

voltages 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

DCE 166 1 RF ESP/SCBR < 1 Hr 1

Recovery Furnace ID Fan is

interlocked with and can

only operate if the scrubber

recycle pumps are

operational. Scrubber flow

rate limt is met before

lighting gas or oil burners.

Liquor is not introduced tothe recovery furnace until

the scrubber is operational

and scrubber flow and

differential pressure limtsare achieved.

Scrubber pressure drop

limit cannot be metinstantaneously atstartup of the scrubber

control device, but is

achieved beforeprocessing mud.Scrubber flow limit is

not instantaneouslyachieved at startup of

the scrubber control

device but is achievedbefore lighing a gas or

oil burner.

Recovery Furnace ID Fan

is interlocked with and

can only operate if the

scrubber recycle pumps

are operational.Scrubber flow rate limt

is met before lighting

gas or oil burners.Liquor is not introduced

to the recovery furnace

until the scrubber isoperational andscrubber flow and

differential pressurelimts are achieved.

Startup ends when the

scrubber flow rate and

pressure drop limits areachieved. 0.1 Hr 0.1

Scrubber shutdown isonly initiated after

liquor is fed out of the

kiln, potential for

dusting is eliminated,

and ID fan is shut down.

Scrubber pressure drop

limit cannot be metonce liquor is removed

from the recovery

furnace.

Scrubbe

only iniliquor i

recover

potentieliminashut do

DCE 166 1 RF ESP/SCBR 10 Hrs 10

Power is applied to

tranformer rectifiers afterthe ESP internal

temperature reaches 200  ̊F.

Black liquor is introduced to

the recovery furnace only

after the ESP is brought on‐

line. NA

Power is applied to

tranformer rectifiersafter the ESP internal

temperature reaches

200  ̊F. Black liquor isintroduced to therecovery furnace onlyafter the ESP is brought

on‐line.

When ESP internal

temperature reaches200  ̊F and power isapplied to tranformer

rectifiers. 1 Hr 1

ESP remains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out/smelted

out and the last oil or

gas burner is removed.

NA

ESP rem

until alpulled f

furnace

is burne

out and 

gas bur

DCE 197 1 RF ESP/SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Don't fire liquor in boileruntil control device is

started

When all 4 fields have

power and meet kw

requirement 0.25 0.25

Control device is

shutdown after emissionsource is shutdown

Emissio

shutdo

DCE 197 1 RF ESP/SCBR 0.08 0.08

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Required operating

parameters are metbefore emission unit isstarted up.

Water is circulatingthrough the system. 0.08 0.08

Control device is

shutdown after emissionunit shutdown.

Emissio

shutdo

NDCE 153 1 RF SCRB

NDCE 159 2 RF SCRB

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up. pressure drop

process not operating

until scrubber operatingproperly

meets required pressure

drop

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. pressure drop none 

NDCE 186 1 RF SCRB 0.16 0.16

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

ESP is operating asnormal

Once parameters aremet 0.16 0.16

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

ESP is onormal

NDCE 186 1 RF SCRB 0.33 0.33

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Scrubber fan amps and

recirculation flow

Once parameters aremet 0.33 0.33

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

Scrubbe

normal

Smelt Dissolving Tanks

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 145 1 SDT OTH 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Confirm normal air flow

at smelt spouts When smelt flow begins 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Shut dopumps

SDT 157 1 SDT OTH 0 0 Is not integrated None

Scrubbing media flowstarts 0 0 None

SDT 171 1 SDT OTH

LMR to review

SSM

SDT 206 2 SDT OTH 6 6

Smelt tank showers turned

on when the green liquor in

the tank reaches strengthspecification.

pressure drop and spray

flow

Route emissionsthrough the demister

When required pressuredrop is achieved 0.5 0.5

Showers remain inoperation until green

liquor pumping isdiscontinued

The applicable emissionand parameter limits are

expected to be metduring shutdown None

SDT 100 2 SDT SCBR < 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and pressuredrop) are attained before

black liquor is introduced to

the recovery furnace.

The applicable emission

and parameter limits are

expected to be met

during startup

Scrubber is operationaland scrubber parameter

limits (flow rate and

pressure drop) are

attained before black

liquor is introduced tothe recovery furnace.

When ESP internaltemperature reachesminimum temperature

specified by Millprocedures and power isapplied to transformerrectifiers. ~1 Hr 1

Scrubber continues to

operate and meet

pressure drop and flow

limits while the

Recovery Furnace is shut

down. Scrubberremains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

The applicable emissionand parameter limits are

expected to be metduring startup

Scrubbe

operate pressurlimits w

Recove

down. remain

until alpulled f

furnace

is burne

is no lo

SDT 102 1 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Startup ends when the

liquid flowrate andpressure dropparameter limit ranges

are achieved 0 0

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

SDT 103 2 SDT SCBR 0.2 0.2

Control device is operating

prior to start‐up of the

associated process withincontrol device operating

parameters.

pressure drop, fan

status, and liquid

injection rates

Ensure explosion

damper is closed and

workingproperly.Startup the

vent stack scrubberaccording to the

standard operating

procedures.

The emission unit is

operating normally, as

defined by the mill'soperating manuals andstandard operating

procedures and verifiedby DCS data 0.2 0.2

Ensure the smelt

dissolving tanks have

been shutdown

according to the mill’soperating manuals and

standard operating

procedures prior to

beginning shutdown of

the north and south

vent stack scrubbers.

Shutdown the

recirculation pump and

exhaust gas fansaccording to thestandard operating

procedures. DCS displayprovides information ofnorth and south ventstack scrubbers before

shutdown of the smelt

dissolving tanks occur.

The applicable emissionand parameter limits areexpected to be metduring startup

Contro

until em

comple

SDT 105 2 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

The applicable emissionand parameter limits are

expected to be met

during startup

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced tothe recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

The applicable emissionand parameter limits areexpected to be metduring shutdown

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operatiblack liq

from thfurnace

is burne

is no lo

SDT 105 1 SDT SCBR

SDT 105 1 SDT SCBR

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 107 1 SDT SCBR 0.5 0.5 Prior to firing black liquor

Control device is startedup and meets required

operating parameter

limits before emissionunit is started up.

air pressure, flow and

differential pressureparameter limits must

be met Firing of any black liquor 0.5 0.5

Control device is not

shut down until boiler

has quit smelting into

smelt dissolving tank

Control device is started

up and meets required

operating parameter

limits before emission

unit is started up.

Controto oper

emissiodown

SDT 108 2 SDT SCBR 3 3

Scrubber is operational

before black liquor is

introduced to the recovery

furnace.

No applicable operating

limits (Smelt tank

exhaust is routed to the

No. 3 Recovery Boiler)

Scrubber is operationalbefore black liquor is

introduced to the

recovery furnace.

Startup ends when the

scrubber is operational 1 Hr 1

Scrubber continues to

operate while the

Recovery Furnace is shut

down. Scrubberremains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing. Not applicable

Scrubbe

operate Recove

down. remain

until alpulled f

furnace

is burne

is no lo

SDT 109 2 SDT SCBR 10 10

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Emission Unit is notstarted until control is

steady state

When liquor is put into

the Recovery

Boiler/Furnace 7 7

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Controshutdo

Unit is S

SDT 111 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emission

and parameter limits are

expected to be met

during startup

verify control device isin operation, and liquid

recircualtion hasreached 735 gpm.

Scrubber liquor flow

drops below 735 gpm 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

CD remoperatishut do

SDT 112 1 SDT SCBR

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

control operating

parameters met before

process start‐up

weak wash flow target

established 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

control 

process 

SDT 114 1 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Scrubber liquid pressuredrop >9.1 in WC andflow rate >360 gpm 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be met

during startup

SDT 115 2 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Achieve Flow rate, Dp,and recirc pressure

(CMS)

Achieve Flow rate, Dp,

and recirc pressure

(CMS) 0 0

Control device operates

until process is down

and no emissions being

generated None NA

SDT 116 1 SDT SCBR ~1 ‐ ~2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. ~1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operati

black liq

from thfurnace

is burne

is no lo

SDT 117 1 SDT SCBR 8 8

Caustic Scrubber Liquid

Needs to be generated by

the process (P30) the

control device is controlling.

Scrubber Flow Rate 3‐

hour average

Starting scrubber fanand liquid flow prior to

putting liquor on B21.

Start‐Up ends when 3‐hour average scrubberflow rate parameterlimit is achieved. 12 12

Need to allow Recovery

Boiler (B21) to burndown so liquor flow to

Emission Unit P30ceases.

The applicable emissionand parameter limits areexpected to be metduring shutdown

Shutdo

and fan 

stops

SDT 119 2 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during start‐up.

Normal operation is

achieved when therecovery furnace is off

fuel oil and is burningblack liquor solids. 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

None expected duringcontrol device shutdowndue to emissions source

down.

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 120 1 SDT SCBR <1 hr 1

Scrubber started up before

liquor is sent to the furnace none no liquor fired liquor flow

Runs until the

process stops

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. none none

SDT 121 2 SDT SCBR

0.166666666666

667 0.166666667

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

meet liquid flow

parameter limits

Minimum scrubbingliquid flow parameters

are above the minimum

values

0.1666666666

66667 0.16666667

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown

Controto oper

require

limits wunit is s

SDT 124 1 SDT SCBR 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Stabilize CPMS

Parameters 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. 

SDT 126 1 SDT SCBR 4‐6 hours 6

Scrubber pump is

operational and scrubber

liquid supply flowrate may

be achieved before blackliquor is introduced to the

recovery furnace.

Flue gas differential

pressure and dependingon time of year andduration of outage

scrubbing liquid flowrate and/or supplypressure.

Scrubber pump is

operational andscrubber liquid supply

flowrate may be

achieved.

Start up of the Scrubber

ID fan and compliancewith all CPMSrequirements. 0.25 hours 0.25

Scrubber continues to

operate and meet liquid

supply flow and

pressure while therecovery furnace is shutdown. Scrubberremains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Depending on ambientremperature the gas dPmay not be met

Scrubbe

operate supply 

pressur

recoverdown. remain

until alpulled f

furnace

is burne

is no lo

SDT 127 2 SDT SCBR 0.75 0.75

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Normal recirculation

flow rate and normal

recirculation pumpamps are established 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

SDT 130 1 SDT SCBR 1 ‐ 2 Hrs 2

SOP: Ducon Scrubber is

started up and meetsrequired operating

parameter limits before

Recovery Furnace is started

up. Scrubber is operational

(Required Scrubber weak

wash makeup flow, weak

wash recycle flow, and

scrubber fan amps are

attained) before black liquor

is introduced to the

recovery furnace.

Scrubber fan amps

minimum operating

parameter value is not

instantaneouslyachieved at startup of

the scrubber control

device, but is achieved

before black liquor is

introduced to the

recovery furnace.

SOP: Ducon Scrubber isstarted up and meetsrequired operating

parameter limits before

Recovery Furnace is

started up. Scrubber is

operational (Required

Scrubber weak washmakeup flow, weak

wash recycle flow, and

scrubber fan amps are

attained) before blackliquor is introduced tothe recovery furnace.

The end of scrubber

startup and beginning of

scrubber normaloperations occur whenthe scrubber is totally

operational and all

critical target operating

parameters (Required

Scrubber weak wash

makeup flow, weak

wash recycle flow, andscrubber fan amps) are

achieved. 3 to 5 Hrs 5

SOP: Scrubber continues

to operate and meets

required operatingparameter limits(Scrubber weak washmakeup flow, weak

wash recycle flow, and

scrubber fan amps)while Recovery Furnace

is shut down. Scrubber

remains operational

until all black liquor is

pulled from the

Recovery Furnace, thefurnace bed is burnedout, and smelt is no

longer flowing.

Scrubber Δ pressure

minimum operatingparameter value is notinstantaneouslyachieved at startup of

the scrubber control

device, but is achieved

before black liquor is

introduced to the

recovery furnace.Scrubber fan amps begin

to decrease as thescubber fan is shutdown.

SOP: Scto oper

require

limits wFurnace 

Scrubbe

operatiblack liq

from thFurnaceburned 

no long

SDT 130 2 SDT SCBR 1 ‐ 2 Hrs 2

SOP: Scrubber is started up

and meets required

operating parameter limits

before Recovery Furnace is

started up. Scrubber is

operational (Required

Scrubber weak wash

makeup flow, weak wash

recycle flow, and scrubber Δ 

pressure are attained)

before black liquor is

introduced to the recovery

furnace.

Scrubber Δ pressure

minimum operating

parameter value is not

instantaneouslyachieved at startup of

the scrubber control

device, but is achieved

before black liquor is

introduced to the

recovery furnace.

SOP: Scrubber is started

up and meets required

operating parameter

limits before Recovery

Furnace is started up.

Scrubber is operational(Required Scrubber

weak wash makeup

flow, weak wash recycle

flow, and scrubber Δ 

pressure are attained)before black liquor is

introduced to therecovery furnace.

The end of scrubber

startup and beginning of

scrubber normaloperations occur whenthe scrubber is totally

operational and all

critical target operating

parameters (Required

Scrubber weak washmakeup flow, weakwash recycle flow, andscrubber Δ pressure) are

achieved. 1 to 3 Hrs 3

SOP: Scrubber continues

to operate and meets

required operatingparameter limits(Scrubber weak washmakeup flow, weak

wash recycle flow, and

scrubber Δ pressure)while Recovery Furnace

is shut down. Scrubber

remains operational

until all black liquor is

pulled from the

Recovery Furnace, thefurnace bed is burnedout, and smelt is no

longer flowing.

Scrubber Δ pressure

minimum operatingparameter value is notinstantaneouslyachieved at startup of

the scrubber control

device, but is achieved

before black liquor is

introduced to the

recovery furnace.Scrubber Δ pressure

begins to decrease as

the scubber fan is shutdown.

SOP: Scto oper

require

limits wFurnace 

Scrubbe

operatiblack liq

from thFurnaceburned 

no long

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 131 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Do not begin smelting

until scrubber is

operational.

Liquid flow rate and fan

amps meet monitoringrequirementsestablished during stack

tests 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

All liquo

for at le

SDT 131 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Do not begin smeltinguntil scrubber is

operational.

Liquid flow rate, fanamps and differential

pressure meetmonitoringrequirementsestablished during stack

tests 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

All liquo

for at le

SDT 131 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Do not begin smeltinguntil scrubber is

operational.

Liquid flow rate, fanamps and differential

pressure meetmonitoringrequirementsestablished during stack

tests 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

All liquo

for at le

SDT 132 2 SDT SCBR 0 0

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

Black Liquor is not

introduced until control

devices meetoperational limits.

Black Liquor isintroduced to EU. 0 0

Control device remains

operational until the EU

is shutdown

SDT 133 1 SDT SCBR 0.1 0.1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

scrubber fan isoperating and scrubberliquid flow is in normal

operating range 0.1 0.1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

SDT 133 1 SDT SCBR 0.1 0.1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

scrubber liquid flow andpressure drop hasreached the normal

operating range 0.1 0.1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

SDT 135 2 SDT SCBR 0.5 0.5

The scrubber can be started

separate from the operation

of the smelt tank.

If the startup occurs late

in the 3‐hr block average

period, and operation of

the smelt tank starts

shortly thereafter withinthe same 3‐hr period,

then the scrubber mayshow non compliance

due to the averaging oflimited data.

Control device is startedup prior to startup of

emissions unit.

The scrubber is

operating in compliance

with the 3‐hr averagefan amps and recirc flow

range. 0.5 0.5

Control device can be

operated separate from

the emissions unit.

If the shutdown occurs

early in the 3‐hr blockaverage period, andoperation of the smelt

tank stops shortlybefore scrubber

shutdown, then thescrubber may show noncompliance due to the

averaging of limited

data.

Contro

operateshutdounit.

SDT 137 1 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

delay process

equipment startup

The following dissolving

tank scrubber systemconditions must be

satisfied prior to startupof the No.4 RecoveryFurnance. Scrubberliquid influent flowgreated than 43 gpm

and Scrubberdifferential pressure(DP) greater than 17

inches of water column. 8 8

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

Mainta

control 

long as 

SDT 137 1 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

delay processequipment startup

The following dissolvingtank scrubber systemconditions must be

satisfied prior to startupof the No.5 RecoveryFurnance. Scrubberliquid influent flowgreated than 351 gpm

and Scrubber fan load

greater than or equal to

55%. 8 8

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

Mainta

control 

long as 

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 138 1 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Liquor is not added to

the recovery furnace

until scrubberparameter limits are

met.

Startup ends when the

liquid pH and scrubber

flow parameters are met

(pH >9 s.u., flow >150gpm) 12 12

Control device continues

to operate during the

shutdown of the

Recovery Furnace.Shutdown of theRecovery Furnace is not

complete until the smelt

bed is burned out.

The applicable emissionand parameter limits areexpected to be metduring startup

SDT 138 1 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Liquor is not added to

the recovery furnace

until scrubberparameter limits are

met.

Startup ends when the

pressure drop andscrubber flow

parameters are met

(pressure drop >5.5

inches, flow >75 gpm) 12 12

Control device continues

to operate during the

shutdown of the

Recovery Furnace.Shutdown of theRecovery Furnace is not

complete until the smelt

bed is burned out.

The applicable emissionand parameter limits are

expected to be metduring startup

SDT 139 1 SDT SCBR 0.5 0.5 liquid flow rate

Control devise is started

prior to the flow of

smelt to smelt dissolvingtank

Liquid flow parameterlimit is achieved 0.5 0.5 liquid flow rate

Contro

to operno longspouts 

dissolvi

SDT 140 1 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

control device is

operating prior to

emission unit start up.

permissives for flow and

pressure drop are met 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

smelt bprior to shutdo

SDT 142 1 SDT SCBR ~0.01 0.01

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup.

Liquid flow parameter

limit is met.

Liquid flow pumps areturned on. ~0.01 0.01

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring shutdown

Liquid flimit is 

SDT 142 1 SDT SCBR ~0.01 0.01

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup.

Liquid flow parameter

limit is met.

Liquid flow pumps are

turned on. ~0.01 0.01

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown

Liquid flimit is 

SDT 143 3 SDT SCBR

Control devicestartup time is

included in the

startup time

provided for the

emissions unit

on the

Equip_Detail

Tab.

Control device is started up

and meets required

operating parameter limits

before feeding smelt to the

tank.

The applicable emissionand parameter limits are

expected to be met

during startup

The scrubber is

operational andrecirculation, makeupflow and pH are being

monitored.

Scrubber recirculation

and makeup flow rate

are achieved and innormal state

Control device

shutdown time

is included in

the shutdown

time provided

for the

emissions unit

on the

Equip_Detail

Tab

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

Scrubbe

operate requirerecoverdown. remain

until smflowing

SDT 145 1 SDT SCBR 2 2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Start weak black liquor

wash flow to scrubberfan, minimum 20 gpm When smelt flow begins 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Shut do

liquor w

fan

SDT 146 3 SDT SCBR 1 1

Scrubber is to be in

operation prior to

introduction of black liquor

in the recovery furnace NA

Ensure that water flowmeets required target

Introdution of black

liquor to the recoveryfurnace 0.5 0.5

Control device remains

in operation until after

black liquor addition has

stopped NA

Controin oper

black liq

stoppe

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 147 3 SDT SCBR 1 1

Scrubbers are brought on

line before black liquor is

introduced to the recovery

furnace. Until black liquor

firing is started, then the

smelt dissolving tanks are

not in operation. The tanks

essentially contain only

weak wash at that point.The start‐up period is

irrelevant for the scrubbers

as the start‐up time for the

furnace is much longer.

The applicable emissionand parameter limits are

expected to be met

during startup

Ensure that water flowmeets required target

Desiredflow/pH/pressure drop

obtained 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

SDT 148 4 SDT SCBR 0.1 0.1

Must meet Title V

parameters before adding

any fuel to emission unit to

go through the control

device

Control deviceparameters are met

before emission unit is

brought up

Control deviceparameters are metbefore emission unit is

brought up

Control device

parameters are met

before emission unit isbrought up 0.1 0.1

Control device is not

shutdown until theemission unit isshutdown

Control device

parameters are metbefore emission unit is

brought up

Controparamebefore 

brough

SDT 149 1 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Scrubbing liquid flowand scrubber gaspressure drop are both

above the parametric

limits and the emission

unit is firing black liquor. 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

SDT 150 1 SDT SCBR 6 6

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

meet liquid flow

parameter limit, meet

differential pressurelimit

scrubber liquid flow rate

at setpoint, scrubberdifferential pressure at

setpoint 6 6

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be met

during startup

Shutdoemissio

control 

SDT 150 1 SDT SCBR 6 6

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

meet liquid flow

parameter limit, meet

differential pressurelimit

scrubber liquid flow rate

at setpoint, scrubberdifferential pressure atsetpoint 6 6

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring startup

Shutdoemissio

control 

SDT 151 3 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

SDT and scrubber are

stable and meeting

normal operationprocess conditions. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Keep smtank sc

until afstoppe

SDT 151 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emission

and parameter limits are

expected to be met

during startup

SDT and scrubber are

stable and meeting

normal operationprocess conditions. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

Keep smtank sc

until af

stoppe

SDT 152 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when

recirculation flowexceeds the minimum

flow rate 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. 

SDT 153 1 SDT SCBR

SDT 154 1 SDT SCBR 4 4

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Process does notoperate until scrubber isoperating

when level, flow and Dp

readings are normal and

the boiler is operating 4 4

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Scrubbeafter th

SDT 154 2 SDT SCBR 4 4

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Process does not

operate until scrubber isoperating

when level, flow and Dp

readings are normal and

the boiler is operating 4 4

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Scrubbeafter th

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 155 1 SDT SCBR 0.5 0.5

scrubber system started up

in advance of black liquorsolids feed into recovery

furnace

The applicable emissionand parameter limits are

expected to be met

during startup

liquid flow rate

maintained

liquid flow rate setpoint

is met 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Mainta

feed ra

running 

SDT 156 1 SDT SCBR 5 5

The controls are always up

and running prior toemission unit startup andare shut down after

emission unit is completelyshutdown.

The applicable emission

and parameter limits are

expected to be met

during startup

Follow SSM plans andprocedures 5 5

The controls are alwaysup and running prior to

emission unit startupand are shut down after

emission unit iscompletely shutdown.

The applicable emissionand parameter limits areexpected to be metduring startup

Follow 

proced

SDT 156 2 SDT SCBR 5 5

The controls are always up

and running prior to

emission unit startup andare shut down after

emission unit is completelyshutdown.

The applicable emissionand parameter limits are

expected to be met

during startup

Follow SSM plans andprocedures 5 5

The controls are alwaysup and running prior to

emission unit startupand are shut down after

emission unit iscompletely shutdown.

The applicable emission

and parameter limits areexpected to be metduring startup

Follow 

proced

SDT 162 2 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing. None

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operatiblack liq

from thfurnace

is burne

is no lo

SDT 163 3 SDT SCBR

1‐2 (Cold

Startup) 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved.

1 (Cold

Shutdown) 1

Scrubber continues to

operate and meet fan

amp and flow limits

while the RecoveryFurnace is shut down.

Scrubber remainsoperational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operatiblack liq

from thfurnace

is burne

is no lo

SDT 164 4 SDT SCBR 0.1 0.1

smelt dissolving tank

scubber is on line for PM

control when minimum flow

is achieved

scrubber flow is morethan minimum required 0.1 0.1

s.d.tank scrubber mustoperate for 4 hours after

boiler shuts down toallow for a bed

burndown see ear

SDT 165 2 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate to the scrubberand the fan and fan amps)

are attained before black

liquor is introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before black

liquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced tothe recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the Recovery

Furnace is shut down.Scrubber remainsoperational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operatiblack liq

from thfurnace

is burne

is no lo

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 166 2 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operati

black liq

from thfurnace

is burne

is no lo

SDT 167 1 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operati

black liq

from thfurnace

is burne

is no lo

SDT 169 2 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber,

but are achieved beforeblack liquor is

introduced to the

recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced tothe recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 to 2 hours 2

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remainsoperational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing. NA

Scrubbe

operate amp an

while thFurnace 

Scrubbe

operatiblack liq

from thfurnace

is burne

is no lo

SDT 171 2 SDT SCBR

LMR to review

SSM

SDT 172 4 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operati

black liq

from thfurnace

is burne

is no lo

SDT 173 1 SDT SCBR 1‐2 hours 2

Scrubber is operational and

scrubber parameter limits

(flow rate and dP) areattained before black liquoris introduced to the

recovery furnace.

Scrubber flow and dP

limits cannot be met

instantaneously atstartup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber flow and dP

limits are attained

before black liquor is

introduced to therecovery furnace.

Startup ends when the

scrubber flow and dP

limits are achieved. 1 hour 1

Scrubber continues to

operate and meet flow

and dP limits while the

recovery furnace is shutdown. Scrubberremains operational

until all black liquor is

pulled from the recovery

furnace, the furnace bed

is burned out and smelt

is no longer flowing. NA

Scrubbe

operate and dP 

recover

down. remain

until alpulled f

furnace

is burne

is no lo

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 174 2 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operati

black liq

from thfurnace

is burne

is no lo

SDT 175 2 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operati

black liq

from thfurnace

is burne

is no lo

SDT 176 2 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up. None

Flame proven in

Recovery oil gun 1 1

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. None

SDT 177 1 SDT SCBR 2 min 0.03

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup Scrubber Fan Off 0.4 0.4

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

SDT 178 2 SDT SCBR ~1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. ~1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operati

black liq

from thfurnace

is burne

is no lo

SDT 179 1 SDT SCBR 0.083‐0.167 0.167

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

N/A ‐ Control device isstarted up beforeprocess is started up

Scrubber pH andrecirculation rateparameters have beenestablished and met. 0.083‐0.167 0.167

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

N/A ‐ P

down b

device 

comme

SDT 180 2 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Ensure adequatescrubber flow

Minimum flow and psirequirements are met 0.5 0.5

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

Mainta

until fa

SDT 181 4 SDT SCBR 2 2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup NA

all operating parameters

limits met 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup NA 

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 182 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

No emissions since fuel

is not introduced until

scrubber meets targetoperating perameters

Pressure drop complieswith permit limit, target

flow rate is achieved 0.5 0.5

There is not interlockdevice. Policy andProcedures areimplemented. none

No emiemissio

present

SDT 184 2 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup N/A adequate flow 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup N/A

SDT 184 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup N/A proper flow 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup N/A

SDT 185 1 SDT SCBR 1 1

Dissolver scrubber start up

is completed and

continuous monitoring

systems parameter limits

met prior to commencing

black liquor firing in the

furnace

The applicable emissionand parameter limits are

expected to be met

during startup

Black liquor firing in the

furnace is not initiated

until control device start

up is complete

Continuous monitoringparameters for

recirculation flow,differential pressure andpH are stable and at or

above limits 0.5 0.5

Black liquor firing in the

furnace has stopped andall smelt run off to the

dissolving tank has alsostopped prior toshutting down the

dissolver scrubber

The applicable emissionand parameter limits areexpected to be metduring shutdown

Verify s

stoppe

dissolveshutdo

SDT 188 1 SDT SCBR

NA ‐ 

Instantaneous

startup and

shutdown

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Smelt Dissolving Tank #1

starts after the controldevice is started up and

meets required

operating parameter

limits

NA ‐ control device start

up precedes the

emission unit startup.

NA ‐ 

Instantaneous

startup and

shutdown

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Operat

during 

SDT 188 1 SDT SCBR

NA ‐ 

Instantaneous

startup and

shutdown

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Smelt Dissolving Tank #2

starts after the controldevice is started up and

meets required

operating parameter

limits

NA ‐ control device start

up precedes the

emission unit startup.

NA ‐ 

Instantaneous

startup and

shutdown

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Operat

during 

SDT 189 2 SDT SCBR 4 4

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

The Recovery FurnaceSmelt Dissolving Tank

Scrubber should be fullyoperational with the

scrubber recirculatingflow(s) and venturidifferential pressurewithin normal startup

ranges prior to burning

black liquor in the

Recovery Furnace.

The startup period ends

and operation beginswhen full strength greenliquor is pumped to the

recausticizing operation. 4 4

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Per the 

scrubbeflow shmainta

scrubbe

high as 

the shuuntil gr

longer pumpedissolvi

SDT 190 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Meet liquid flow and dp

parameter limit 0.5 0.5

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup 

SDT 190 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Meet liquid flow and fan

amps 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup 

SDT 190 1 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Meet liquid flow and fan

amps 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup 

SDT 195 1 SDT SCBR 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

control device operates

during emission unitstartup Firing Black Liquor 18 18

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

All Cont

remain 

source 

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 196 1 SDT SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Ensure scrubber flow

and dp established

Minimum scrubber flowand dp levels achieved 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup

Wait un

has cea

SDT 196 2 SDT SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emission

and parameter limits are

expected to be met

during startup

Ensure scrubber flow

and dp established

Minimum scrubber flowand dp levels achieved 0.25 0.25

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

Wait un

has cea

SDT 197 1 SDT SCBR 0.08 0.08

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Required operating

parameters are metbefore emission unit isstarted up.

Water is circulatingthrough the system. 1.08 1.08

Control device is

shutdown after emissionunit shutdown.

Emissio

shutdo

SDT 198 1 SDT SCBR 3 3

Control device operating

and meets required

scrubbing liquid flow beforeemission unit begins normal

operation. gas stream pressure loss

control device operating

prior to processbeginning normaloperation

gas stream pressure loss

and liquid flow within

normal operating range,no alarms 3 3

Control device continues

to operate and meets

required scrubbingliquid flow while

emission unit is shutdown. gas stream pressure loss

control to oper

possible shuts d

SDT 199 1 SDT SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

scrubber liquid flow

parameter limit range isachieved 0.2 0.2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown.

SDT 200 2 SDT SCBR UK

Control device operating

and meets required

scrubbing liquid flow beforeemission unit begins normal

operation. pressure drop

control device operating

prior to processbeginning normaloperation

pressure drop and liquid

flow within normaloperating range, no

alarms UK

Control device continues

to operate and meets

required scrubbingliquid flow while

emission unit is shutdown. pressure drop

control to oper

possible shuts d

SDT 201 1 SDT SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure drop

parameter limit range isachieved 0.2 0.2

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during shutdown.

SDT 202 1 SDT SCBR 0.1 hour 0.1

Typically Recovery Furnace

and SDT are not to be

started until scrubber flow

and dp parameters have

been met

The applicable emissionand parameter limits are

expected to be met

during startup

meet liquid flow and dP

parameters before

starting Recovery

furnace on liquor

NOT DEFINED ‐ Flow and

dP parameters met for

more than 1 minute and

recovery furnace on

liquor and off gas 0.02 0.02

Scrubber is keptoperating until well after

boiler taken off liquor.

Scrubber typicallycontinues to run even if

Emission Unit off unless

scrubber maintenance

needed.

The applicable emissionand parameter limits are

expected to be metduring startup

Keep oas long 

SDT 203 2 SDT SCBR 0.1 0.1

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

emission unit shut down

until APCD running

Scrubber operating

parameters established 0.16 0.16

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be metduring startup

recoverdown b

shut do

SDT 205 1 SDT SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure dropparameter limit range isachieved 0.2 0.2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring shutdown.

SDT 207 2 SDT SCBR 1 1

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

all parameters at target

before EU is started all parameters at target 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

All para

target b

device 

SDT 226 3 SDT SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure drop minimumparameter value is

achieved 0.2 0.2

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be met

during shutdown.

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 240 2 SDT SCBR <0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup.

Control device is startedup before emission unitis started up.

Scrubber recirculation

rate, fan amps, and pH

meet parameter limits. <0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup.

Emissiodown b

device 

SDT 240 1 SDT SCBR <0.5 0.5

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup.

Control device is startedup before emission unitis started up.

Scrubber recirculation

rate, pressure drop and

pH meet parameterlimits. <0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be met

during startup.

Emissiodown b

device 

SDT 242 1 SDT SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up. NA

Control device is startedup and meets required

operating parameter

limits before emissionunit is started up.

Control device is started

up and meets required

operating parameter

limits before emission

unit is started up. 0.25 0.25

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down. NA

Controto oper

require

limits wunit is s

SDT 243 2 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Meet required permitparameter limits

Startup ends when all of

the permitted

parameter limits are

achieved 0.1 0.1

Control device continues

to operate and meets

required operating

limits while emission

unit is shut down.

Meet re

parame

SDT 340 1 SDT SCBR 0.25 0.25

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Pressure drop andcirculation rate

paramters are reached. 0.5 0.5

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits areexpected to be metduring startup

Liquor sboiler bshut do

SDT 525 2 SDT SCBR 2 2

Control device is started up

and meets required

operating parameter limits

before emission unit is

started up.

The applicable emission

and parameter limits are

expected to be met

during startup

scrubber water is on

during startup

startup ends when

pressure dropparameter limit is met. 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emissionand parameter limits are

expected to be met

during startup

scrubberun dur

SDT 531 1 SDT SCBR 1‐2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operati

black liq

from thfurnace

is burne

is no lo

SDT 600 2 SDT SCBR 1 ‐ 2 Hrs 2

Scrubber is operational and

scrubber parameter limits

(flow rate and fan amps) are

attained before black liquoris introduced to the

recovery furnace.

Scrubber fan amps andflow limits cannot be

met instantaneously at

startup of the scrubber

control device, but are

achieved before blackliquor is introduced to

the recovery furnace.

Scrubber fan amps and

flow rate limits are

attained before black

liquor is introduced to

the recovery furnace.

Startup ends when the

scrubber fan amps andflow limits are achieved. 1 Hr 1

Scrubber continues to

operate and meet fan

amp and flow limitswhile the RecoveryFurnace is shut down.Scrubber remains

operational until all

black liquor is pulled

from the recovery

furnace, the furnace bedis burned out and smelt

is no longer flowing.

Scrubber fan amps and

flow rate

Scrubbe

operate amp anwhile thFurnace 

Scrubbe

operati

black liq

from thfurnace

is burne

is no lo

App_C2_NSPS_SSM_Ctrls_Info 
Emission

Process

Group

RTI

CODE

Count of

RTI CODE

EU‐APCD

Group

APCD SU

Duration hrs

APCD SU

Duration hrs

num* APCD_SU_Integration

APCD_SU_

ParamDeviation

APCD_SU_

EmissRednMeas APCD_SU_MarkEnd

APCD SD

Duration hrs

APCD SD

Duration hrs

num* APCD_SD_ Integration

APCD_SD_

ParamDeviation

Em

SDT 606 3 SDT SCBR 1 1

Not integrated. Standard

procedure is for control

device to start up ahead of

emissions unit.

Inlet damper lockedopen, fan irunning,liquid flow is above

minimum flow

requirement listed in

Column AN.

All monitoringparameters being met,

smelt flowing to

dissolving tank. 1 1

Not integrated.

Standard procedure is

for control device to

shutdown afteremissions unit.

no fire 

smelt fdissolvi

SDT 610 2 SDT SCBR 0.5 0.5

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

Startup ends when

minimum scrubber flow

and fan amps are

achieved 0.08 0.08

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

SDT 613 4 SDT SCBR 2 2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up. na

Scrubber delta P andscrubber recirculatingflows must be

maintained to avoid

established limit

excursions during the

startup period.

Smelt tank vent fanmust be operating

properly and scrubber

delta P must be withing

minimum range

expected. 2 2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down. na

Ensure 

longer by the s

tank

SDT 615 1 SDT SCBR 0.25 0.25

scrubber parameters

established prior to black

liquor feed pressure drop

meet liquid flow

parameter limit

scrubber parametersaccomplished 0.25 0.25

control device continues

to operate after unit is

shutdown; liquid flow ismaintained; however

pressure drop cannot be

maintained due to

decrease of air flow pressure drop mainta

SDT 617 1 SDT SCBR 1 1

control device is fully

operational before processis started up

The applicable emissionand parameter limits are

expected to be met

during startup

process does not startup until control device isready

scrubber flow and fan

amps meet 3‐hour ave.

parametric limits 0.5 0.5

control device is not

shut down until process

is down

The applicable emissionand parameter limits areexpected to be metduring startup

continu

control process 

SDT 2.1E+08 2 SDT SCBR 0.2 0.2

Control device is started up

and meets required

operating parameter limitsbefore emission unit is

started up.

The applicable emissionand parameter limits are

expected to be met

during startup

Startup ends when the

pressure dropparameter limit range isachieved 0.2 0.2

Control device continues

to operate and meets

required operatinglimits while emission

unit is shut down.

The applicable emission

and parameter limits areexpected to be metduring shutdown.

*If a range was provided the maximum of the range was entered.

App_C2_NSPS_SSM_Ctrls_Info