### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 1 

# Pulp and Paper Sector Survey

Instructions for Part I: Mill Overview and Subpart S Data

2 / 4 /11

This survey overview document provides instructions for completing Part I of the p ulp and paper survey. This

overview is organized as follows:

A. Part I Introduction

................................ ................................ ................................ ................................ ........... 2

B. Confidential Business Information (CBI)

................................ ................................ ................................ ........ 4

C. How to Submit Your Part I Survey Response

................................ ................................ ................................ . 4

C1. Submitting Your Non

- CBI Response

................................ ................................ ................................ 4

C2. Submitting CBI

................................ ................................ ................................ ................................ . 4

D. How to Complete the Part I Survey

................................ ................................ ................................ ................. 5

D1. Flow diagrams

................................ ................................ ................................ ................................ ... 5

D2. Process dat a (P&P survey_PI.xls)

................................ ................................ ................................ ..... 6

a. Mill tab

................................ ................................ ................................ ................................ .... 9

b. PI Equip detail tab

................................ ................................ ................................ ................. 11

c. PI Permit limits tab

................................ ................................ ................................ ................ 15

d. PI Controls tab

................................ ................................ ................................ ....................... 17

e. Pulp prod tab

................................ ................................ ................................ ......................... 18

f. Byproducts tab

................................ ................................ ................................ ....................... 19

g. Kraft condensates tab

................................ ................................ ................................ ............ 19

h. CCA tab

................................ ................................ ................................ ................................ . 20

i. Bleaching tab

................................ ................................ ................................ ......................... 21 j. Paper prod tab

................................ ................................ ................................ ........................ 22

k. HAP additives tab

................................ ................................ ................................ .................. 22

l. WW tab

................................ ................................ ................................ ................................ .. 23

D3. Test data

................................ ................................ ................................ ................................ .......... 23

a. PI Emissions test data tab

................................ ................................ ................................ ...... 24

b. CEMS data spreadsheet (P&P CEMS_PI.xls)

................................ ................................ ....... 24

D4. Optional cost data

................................ ................................ ................................ ............................ 26

PART I

- ATTACHMENT 1 Emission Units to Include in the Part I Pulp and Paper Survey Response

.................. 28

PART I

- ATTACHMENT 2 Small Business Size Standards

................................ ................................ .................... 30

PART I

- ATTACHMENT 3 Part I Emissions Test Data Request

................................ ................................ ............. 31

### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 2 

## A. Part I Introduction

The pulp and paper sector information request applies for pulp and/or paper/paperboard mills that are a major source or synthetic area source of hazardous air pollutant (HAP) emissions that : (a) Perform chemical wood pulping (kraft, sulfite, soda, or semi

- chemical), or (b) Perform mechanical, groundwood (e.g., thermomechanical pulping (TMP)

, refiner mechanical pulping (RMP)) , secondary fiber, and non

- wood pulping, or (c) Perform bleaching, or (d) Manufacture paper or paperboard products.

As defined in 40 CFR Part 63, subpart A,

“ Major source ” means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant o r 25 tons per year or more of any combination of hazardous air pollutants, unless the Administrator establishes a lesser quantity, or in the case of radionuclides, different criteria from those specified in this sentence.

A “ synthetic area source ” is a st ationary source which is subject to federally

- enforceable conditions that limit its potential to emit to below major source thresholds.

Certain mills are not required to complete the pulp and paper sector survey. If your mill meets one of the following

c onditions, then you should complete the form in Attachment 1 of the Survey Overview document and email (or fax)

it to Bill Schrock at EPA (contact information is provided on the form). Conditions for exemption f rom all parts of the pulp and paper sector survey are as follows:

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

, or

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

• Your mill does not produce pulp, perform bleach ing, or serve as a primary manufacturer of paper or paperboard products. You are required to complete Part I of the pulp and paper sector survey unless you meet one of the three criteria listed above for exemption from the survey

.

This survey is to be com pleted in a Microsoft Excel spreadsheet file that is divided into several worksheets (“tabs” within the spreadsheet). You must complete certain tabs of the survey spreadsheet (depending on the type of mill you operate). T a ble 1 below denotes which survey spreadsheet tabs to complete depending on mill type . Additional spreadsheets are provided for submittal of continuous emissions monitoring system (CEMS) data or control measure

cost information.

Please complete the survey for the facility listed in the Section 114 letter you received in the mail. If you received more than one Section 114 letter for multiple facilities, you must create a separate survey response for each facility. If you have not already received or downloaded a copy of the survey spread sheets, they can be downloaded here: https://icr2010.rti.org/Industries/PulpPaper.aspx

Use t he 2009 calendar year as the base year for all survey responses (e.g., 2009 emissions inventory, 2009 capacity

, 2009 equipment configurations , etc

. ), unless another year is specified in the instructions (e.g., for emissions test data)

.

Part I of this survey asks questions about the emission units listed in Attachment 1 to this document . Part I c overs essentially all emission units except for chemical recovery combustion sources (which are covered in Part III)

. Section D, How to Complete the Part I Survey , explains how to treat various configurations of emission units (e.g., multiple emission uni ts venting to the same stack, etc.) for each survey tab. Attachment 2 contains a listing of small business size standards for North American Industry Classification System (NAICS) code Subsector 322, Paper Manufacturing. Finally, Attachment 3 of this su rvey contains a table of emission units and pollutants for which existing emission test data are requested under Part I.

### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 3 Use the following attachments to the Survey Overview document for reference: Attachment 2: Regulatory definitions from the kraft pul p mill new source performance standards (NSPS) (40 CFR Part 60, subpart BB), chemical recovery combustion source national emissions standards for hazardous air pollutants (NESHAP) (40 CFR Part 63, subpart MM), the pulp and paper processing NESHAP (40 CFR P art 63, subpart S), and selected definitions from

the NSPS and NESHAP General Provisions. Attachment 3: Acronyms and abbreviations used throughout the survey and associated spreadsheets.

Table 1. Part I Survey Spreadsheets and Tabs to Complete Spre adsheet and tab Types of mills that should complete this spreadsheet tab P&P survey_PI.xls

Mill All mills PI Equip detail All mills

PI Permit limits All mills

PI Controls Mills with add

- on air pollution controls on pulping emission units, bleaching emission units, or papermaking emission unit s

. Pulp prod Mills that produce any type of pulp (including chemical, mechanical/groundwood, secondary fiber, including non

- wood pulp) Byproducts Mills that produce turpentine or tall oil byproducts from pulpin g processes Kraft condensates 2 Mills that perform kraft pulping

CCA 2 Mills that perform kraft pulping and use the clean condensate compliance alternative (CCA) Bleaching Mills that perform bleaching Paper prod Mills that produce paper or paperboard pr oducts

HAP additives Mills that produce paper or paperboard products

WW Mills with onsite wastewater treatment plants

PI Emissions test data Mills operating emission units for which test data are requested in Attachment 3 to

this document.
P&P CEMS_ PI .xls

CEMS data 1 Mills operating CEMS on emission units listed in Attachment 1 to this document.

P&P costs OPTIONAL _PI .xls (Completion of this spreadsheet is optional)

APCD costs Mills that installed selected air po llution controls (see section D4 ) Equip change costs Mills implementing selected process or e quipment changes (see section D4 )

1 Separate tabs are included for different pollutants and for CEMS cost.

2 This tab does not apply for synthetic area sources.

Note that the information submit ted by a facility is not intended for a compliance assessment. If actual data is not available, the facility should provide the best engineering estimates where appropriate. In addition, it is not the

intent of the EPA to use this data to confirm data/in formation submitted in the facility’s Toxic Release Inventory (TRI) or other regulatory required reports. It is understood that data submitted in this survey could vary due to the nature of the questions.

### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 4 

## B. Confidential Business I nformation (CBI)

Th e U.S. Environmental Protection Agency’s ( EPA's ) procedures for handling confidential business information ( CBI ) are described in the letter (and attachments) accompanying the pulp and paper information collection request (ICR). If you believe that provid ing any specific information to us would reveal a trade secret, please identify this information clearly in your spreadsheet response by shading the spreadsheet cell containing the CBI with red highlight and indicat ing in the red block at the top of each s preadsheet tab that the tab contains CBI

. (You will find the red highlighting and red CBI block at the top of the spreadsheet helpful when you separate your CBI data from

non

- CBI for submittal as indicated in section C2 below). Also, please clearly label any flow diagrams or other attachments submitted with your survey that contain CBI. However, please do not label your entire response as CBI if only a portion includes trade secrets

. The EPA is likely to follow up with a request for validation of CBI cl aims for mills claiming large amounts of information as trade secret s , especially information that is readily reported by

other mills without such claims

.



## C. How to S ubmit Your Part I S urvey R esponse

If your response to this information collection requ est includes data with a claim of CBI , you should follow the instructions in this section to ensure the protection of your data. Please note that if you submit CBI, you will be separating your data into two portions and sending your data to EPA using two different mailing addresses

.



### C 1

. Submitting Your N on

- CBI Response

Follow these instructions for the non

- CBI portions of your survey response (or for responses that are entirely non

CBI.)

After you have completed and reviewed your survey response

, sig n and date the certificati on form in Attachment 4

of the S urvey O verview document. R emove the CBI components from your survey as instructed in section C2

, leaving only the red shading and replacing the CBI data with the letters “CBI” . Save the Excel spre adsheet (s) containing the non

- CBI portion s of your completed response, non

- CBI flow diagrams, emission test reports, and any

other electronic non

- CBI attachments on the flash drive you were provided with your section 114 letter (or on a CD or DVD). Assemb le any non

- CBI hard copy attachments to your survey (such as the signed certification form, hard copy flow diagrams, test data, wastewater emissions modeling reports, etc.). Please clearly label and m ail the non

CBI flash drive (or disk) and any non

- CBI h ard copy materials in one envelope to EPA at the address specified

below by the specified response deadline in the Section 114 letter. ( Note: If the spreadsheet/diagrams/attachments contain CBI, use the address for Mr. Morales provided in section C2 of t his document .)

U.S. Environmental Protection Agency Office of Air Quality Planning and Standards

U.S. EPA Mailroom (E143

- 03)

Attn: Mr. Bill Schrock

109 TW Alexander Drive Research Triangle Park, NC 27711

EPA recommends sending your non

- CBI files vi a Registered U.S. Mail using return receipt requested, Federal Express, or other method for which someone must provide a signature upon receipt.



### C 2

. Submitting CBI

Follow these instructions for any portion of your survey response that contains CBI.

P lease create and label a separate CD or DVD containing a version of your spreadsheet response with only the CBI portion of your data (i.e., only the red highlighted data in the survey spreadsheet ). Include on the disk any flow

### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 5 diagrams or pages of other a ttachments to your survey response containing CBI

, with the CBI portions of the diagrams/pages clearly marked (e.g., highlighted or circled). Clearly mark the disk with the words “Confidential Business Information.” Send only these CBI files under separa te cover to:

U.S. Environmental Protection Agency Office of Air Quality Planning and Standards

U.S. EPA Mailroom (C404

- 02) Attn: Mr. Roberto Morales, Document Control Officer

109 T.W. Alexander Drive Research Triangle Park, NC 27711

For the security of your data, EPA recommends sending your confidential files to Mr. Morales via Registered U.S. Mail using return receipt requested, Federal Express, or other method for which someone must provide a signature upon receipt.

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA. E

- mail

and facsimile are not secure forms of communication and should never be used to transmit CBI.



## D. How to Complete the Part I S urvey

Your survey response will consist of flow diagrams , test reports, and c ompleted Microsoft Excel spreadsheets. Separate Excel spreadsheet file s are provided for completion ( P&P survey_PI.xls ; P&P CEMS_PI .xls ; P&P costs

OPTIONAL _PI .xls ). You must complete certain tabs of the P&P survey_PI.xls spreadsheet file (depending on th e type of mill you operate) as shown in Table 1 above. The P&P CEMS_PI.xls spreadsheet file is to be completed if you have continuous emissions monitoring data to supply. The P&P costs OPTIONAL_PI.xls spreadsheet file is an optional spreadsheet file tha t can be completed to supply control measure cost information helpful for EPA’s regulatory analyses. One additional file, Boiler MACT Code Lookup.xls, is provided for your convenience and to reduce survey effort in case you wish to locate and supply your Boiler MACT survey ID codes when completing P&P survey_PI.xls.

You will enter data into the white (unshaded) cells of the spreadsheets. Please do not enter data into the blue shaded area of the spreadsheet, or in the orange

- colored column headings.



### D 1. Flow diagrams

Please provide a process flow diagram (or diagrams) showing the equipment listed in Attachment 1 (to both survey Parts I and III)

. No additional diagrams are requested in Part III, so please include chemical recovery combustion

sources in the diagrams submitted in response to Part I.

Readily available block flow diagrams (e.g., such as those use d for permit applications) will suffice. Electronic or hard copies are acceptable. You need not prepare any new flow diagrams. It is accept able to hand

- mark changes on an older diagram that may no l onger be completely reflective o f current operations. Examples of diagrams that would be helpful for EPA are as follows:

Chemical recovery area

. A diagram showing each chemical recovery furnace /combustion unit, black liquor oxidizer (if used), smelt or ash dissolving tank, causticizing equipment, lime kiln/calciner , and liquor storage tanks or ponds would be helpful

.

Pulping process

. A diagram showing the equipment in all pulping lines

, includi ng the digester area, pulp washing lines, evaporator lines, and o xygen delignification systems

, would be useful

. The diagram could

show any brown stock washers, hoods, filtrate tanks, vacuum pumps, screens, knotters, deckers, stock chests (including open stock chests, pulp storage tanks), thickeners, and weak black liquor storage tanks.

### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 6 D eckers, screens, knotters, stock chests, and pulp storage tanks following the last stage of pulp washing and/or those located prior to the paper machines are also o f int erest

.

Black liquor gasification . I f black liquor gasification is used, a diagram and description of the system

, including any combustion controls or add

- on controls used to reduce air pollutants

, would be helpful

.

Wastewater treatment plant (WWTP)

. A flow diagram of each WWTP showing each wastewater handling/treatment unit would be useful

.



### D 2

. Process data (P&P survey_PI.xls)

In this portion of the survey

, you are asked to add data to the various tabs in the P&P survey_PI.xls spreadsheet. Many of the instructions you need for completing the survey tabs are included in the “Instruction” row of each tab in

the P&P survey_PI.xls spreadsheet. However, more detailed instructions for selected tabs are provided below to account for common situations and to provide information on how the data will be used by EPA. Each survey tab includes fields with pull

- down menus for common entries. Use these pull

- down menus whenever possible, or write in information if your selecti on is not contained in the pull

- down menu.

Several IDs are requested throughout the pulp and paper survey response spreadsheet(s), including:

• NEI Site ID

• Emission Unit ID

• Boiler MACT survey IDs: FacilityID and UnitID [O ptional]

• Collection system ID

• Bleaching line ID (if needed)

• APCD_ID

The NEI Site ID and Emission Unit ID should correspond with the IDs used in the NEI update (Part II of this

survey ) where such IDs exist. If no NEI Site ID already exists (e.g., in cases where no previous NEI data exists for

you r mill) , the n you should use “NEW_____” for the NEI Site ID where the blank is your mill’s zip code, as this Why does EPA need process data ? Facility and equipment details ar e being request ed to inform the technolog y review of the pulp and paper NE SHAP and NSPS and to provide information on means of reducing residual risk . While the

NEI update (requested in Part II of this survey) provides EPA with data related to emissions r elease points (e.g., mass emission rate and stack exit parameters used for risk analysis and tracking nationwide trends), the technolog y review of the NESHAP and NSPS considers emission unit and control equipment details specific to the processes employed and matches these details to emissions levels that are achieved (e.g., emission concentrations). A pplicability of the NESHAP and NSPS compliance options depend s on the specific process equipment. How detailed must my diagram(s) be ?

The EPA will use the diagram(s) to aid in understanding the general mill flow and any unique characteristics in the mill layout. It is not necessary to show every single vent of every emission unit on the diagrams. However, the diagram should provide enough information so i t is clear how emissions are collected and controlled. For example, if all digester vents are routed to a low

- volume, high

- concentration (LVHC) collection system, then it is not necessary to show each individual digester vent when one line drawn from a di gester “block” to the LVHC collection system is

informative.

### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 7 will (in all likelihood) provide a unique identifier for your mill. If Emission Unit ID(s) for selected process units do not already exist in the NEI data set , then you may use any Emission Unit ID you choose (for example, the ID used in your permit), and this same ID should be used throughout all p arts of the survey. Note that Emission Units IDs

are limite d to 6 text characters in the NEI. You will specify the Collection system ID and APCD_ID in the PI Equip

detail and other spreadsheet tabs. The Bleaching line ID would be used in the Bleaching tab

, if needed

, for plants with multiple bleaching lines.

A “comments” column is included to the right of each spreadsheet should you wish to supply any comments on the information provided.

A Note About Identification Numbers ( IDs )

The different parts of the pulp and paper survey include the following IDs:

• NEI Site ID

• Emission Unit ID

• Collection system ID

• APCD_ID

It is impe rative that you use the same IDs to describe the same facility, equipment/emission unit, and emission release point throughout all parts of this survey. These ID codes will be used to link the various pulp and paper data base tables together into a functi ona l and informative data base to be used for regulatory analyses . You may choose your own IDs (e.g., based on Emission Unit IDs already included in the NEI, IDs from existing process flow diagrams, IDs in your air permit, etc.), but the IDs you choose mu st be consistent throughout your survey response. If you wish to avoid

follow

- up calls regarding your survey data, please make every effort to ensure that your IDs match throughout the spreadsheet (s) and in each part of your survey response. For exampl e, any Emission

Unit ID or APCD_ID you create/specify in Part I should also be used when referring to the same piece of equipment in Parts II and III for this survey response.

Also, please be sure that no extra spaces or characters are included in th e ID cells

. For example,

Emission Unit ID “DIG1” is not read the same as “DIG

- 1” or “DIG

- 1_” by data base software.

### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 8 What if I have difficult y pairing emission units with corresponding Emission Unit ID s in the NEI?

Having Emission Unit IDs in Part I/III and the NEI matching as closely as possible will help tremendously as EPA analyzes the survey data (for those instances where we need to link the NEI and Part I/III data). However, we realize that information may be presented in the NEI differently than we are requesting it in the Equip detail tabs of Parts I/III of the pulp and paper survey. The Equip detail tabs and the NEI serve two differ ent purposes, so this is to be expected. Instructions for handling difficult matches between the NEI and Part I/III are below:

1. When there is no corresponding Emission Unit ID in the NEI, then you should make one up (6 text characters or less) to use i n Part I and/or Part III. If you add the emission unit to the NEI in P art II, then use the Emission Unit ID you made up for Parts I/III.

2. In some cases there may not be a one

- to

- one correspondence between an existing NEI Emission Unit ID and the equip ment listing requested in the Part I /III Equip detail tab.

Example 1 : An existing Emission Unit ID in the NEI may represent a grouping of equipment (e.g., “PSC” for 4 pulp storage chests), but these equipment need to be listed separately in the Equip d etail tab. In this case, you should make up a similar Emission Unit ID for the Equip detail tabs of Parts I and III (e.g., PSC

- 1, PSC

- 2, PSC

- 3, PSC

- 4), and then add a note in the Equip detail tab “Process notes (optional)” column to indicate the correspon ding NEI Emission Unit ID of PSC as shown below:

Emission Unit ID Process notes (optional)

PSC

- 1 NEI Emission Unit ID (covering 4 tanks) = PSC

PSC

- 2 NEI Emission Unit ID (covering 4 tanks) = PSC

PSC

- 3 NEI Emission Unit ID (covering 4 tanks) = P SC

PSC

- 4 NEI Emission Unit ID (covering 4 tanks) = PSC

Example 2 : Suppose the NEI contains 2 or more Emission Unit IDs for a given piece of equipment (such as a single paper machine’s forming section {SN23} and burners {SN24}). In this case you nee d to pick a single representative Emission Unit ID (e.g., SN23) to use in the Part I/III response.

Example 3 : Suppose a single NEI Emission Unit ID is provided for many pieces of unrelated equipment at the mill, but the NEI Process ID varies for the equ ipment (e.g., NEI Emission Unit ID = 001 for all equipment at the mill, but each emission unit has a unique Process ID {01, 02, 03....}). This is not common, but is the case for at least one mill. In this situation, it is suggested that the Emission

Unit ID used for Part I/III be 001_01 for NEI Process ID 01; 001_02 for NEI Process ID 02, 001_03 for

NEI Process ID 03 etc.

3. If respondents unfamiliar with their pre

- populated NEI data are unable to match one or more NEI Emission

Unit IDs with emissions u nit ( s ) at their mill (using the SCCs as a guide) , then it is suggested that the respondent flag the unmatchable NEI data for deletion in Part II, and replace it with revised NEI data for identifiable

emission units. Include the identifiable Emission Unit IDs in Parts I/III.

Other tips:

• The NEI requires Emission Unit IDs to be limited to 6 characters.

• You may use the “Process notes (optional)” column in the Part I/III Equip detail tabs to clarify any matching discrepancies with the Part II NEI. These not es will assist EPA in analyzing the data and prevent confusion.

### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 9 Follow the instructions below and in the “Instruction” rows of the spreadsheet to complete the survey tabs. Refer to Table 1 of this document to determine which tabs you must complete depending on the type of mill you operate.

In several parts of the survey, the agency requests “nominal daily throughput capacity.” These values are typical

ope rating rates for the process or emission unit and can be used by the agency to compare the relative size of the unit. You may use the pulping line nominal capacity (throughput) for all equipment in the pulping line. You may specify the nominal liquor sol ids or lime kiln throughput for equipment in the chemical recovery loop. Likewise, for papermaking equipment you may use the nominal paper throughput capacity. The EPA is interested in capacity values that would be used for estimating emissions (for exam ple, values used in y our permit application )

. We are not interested in maximum capacity values for each piece of equipment outside of the constraints of the pulping/papermaking/chemical recovery process within which it is located.

a. Mill tab

Complete the columns following the instructions provided in the “ Instruction ” row . You r response in the Mill tab

will consist of one row of data. These data will be used by EPA to characterize your facility and identify applicab le regulations.

Size of entity

. Attachment 2 to this document contains a listing of North American Industry Classification System ( NAICS ) codes and small business size standards f or NAICS subsector 322

. For private businesses, small entity is defined f or each NAICS code of the owning entity based on number of employees and/or company revenue. The parent company number of employees is used for the pulp and paper subsector (322). Note that the “number of employees” is calculated according to the Small B usiness Size Regulations codified at 12 CFR 121.06

, where all individuals employed on a full

- time, part

- time, or other (e.g., t emporary) basis are counted equally.

Paper or paperboard processes/products . Enter the total number of operable paper machines located at the mill in 2009 (including any machines that were temporarily idle due to economic conditions in 2009) in the

“ Total number of paper machines ” column. Enter the total paper/paperboard machine nominal daily production capacity as of 2009 in th e " 2009 nominal daily production capacity total for paper/paperboard (air dried short tons/day) ” column. Note that nominal daily production capacity represents the paper/paperboard production capa bility of the operable machines and may be greater than 200 9 actual What if I do not know or have the information to answer a survey question?

There may be survey questions that you do not kn ow the answer to, or for which information is not readily available. The following codes may be used:

Unknown (UK): If you do not have the requested information, cannot obtain the information without extraordinary effort, and cannot provide a reasonab le estimate, then you may enter

“ UK ” for unknown.

Not Applicable (NA): If a question is not applicable to your operations, then you may enter

“ NA ” for not applicable.

Survey respondents are reminded that their certification of the accuracy of their re sponse includes a certification that any identification of information as "unknown" or "not applicable" is accurate. Further, survey respondents providing an excessive number of responses as “UK or “NA” are likely to receive scrutiny and follow

- up inquiri es from EPA related to their survey response.

### Part I Form Approved 02 / 17 / 2011

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### 10 production. Next

, indicate the types of paper grade s the facility is capable of producing across all paper machines ( again, including machines temporarily idle in 2009)

.

Paper/paperboard capacity utilization

. You are asked to provide the decima l percentage utilization for paper/paperboard nominal daily production capacity at your mill for the survey base year (2009). In addition, because 2009 was characterized by short

- term production curtailments at many mills due to the

U.S. economic situatio n, you are asked to provide a 5

- year average nominal daily production capacity

utilization. For example, suppose a mill has 3 paper machines but one of these machines was shut down

due to economic reasons for half of 2009. The capacity utilization c ould be figured as follows:

A B C D E F Paper

machine Nominal daily production capacity ( air dried st/day) Maximum production days/yr Actual production days/yr 2009 nominal production capacity, air

dried st/yr (= A x B) 2009 actual production, air

dried st/yr * (= A x C) 2009 decimal

percent
utilization * (= E / D)

#1 400 360 340 144,000 136,000

#2 500 360 355 180,000 177,500

#3 200 360 175 72,000 35,000

TOTAL 1,100 396,000 348,500 0.88 st = short tons (1 st = 2000 pounds) *The EPA recognizes the potential for actual production or actual utilization by machine to be considered as sensitive information (e.g., to be CBI). Therefore, EPA is asking that you report the overall decimal percent utilization aggregated across all machines instead of utili zation for each machine

.

It should be noted that the owner may not have production data back to 2005 if the facility was purchased after January 1, 2005. If this is the case, the facility should average the years that are available and note as

such in t he “comments” column.

### Part I Form Approved 02 / 17 / 2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 11 b

. PI Equip detail tab

All mills are asked to complete the PI Equip detail tab. This tab asks for information for each individual emission

unit. The purpose of this tab is to provide EPA with equipment

- specific details needed for the Agency to review the technology

- based standards (i.e., nationwide numbers of equipment, configuration o f controls, pertinent equipment details, and regulatory compliance options used).

The types of emission units listed in Attachment 1 that you o perate should be included in the PI Equip detail tab. Essentially, you are requested to provide information for most of the equipment at you r mill in Part I (except for

chemical recover y combustion sources such as recovery furnaces, semi

- chemical liquor c ombustors, sm elters, smelt dissolving tanks, lime kiln s , calciners, and black liquor oxidation systems which are covered in Part III ). However, if you operate chemical recovery combustion source s or power boilers that burn pulp mill non

- condensable gases (NCGs) or stripper off gases (SOG)

, then you will need to identify these combustion sources as the air pollution control device ( APCD ) in the PI Equip detail tab

. Boilers are a special case. Specific instructions pertaining to

boilers are included in “ Bo ilers, thermal oxi dizers, and direct

- fired dryers” below.

Columns A through A R of the PI Equip detail tab ask generic questions for all emission units listed in Attachment

1

. The c olumns to the right of column A R request design and operating details for specific types of emissio n units (e.g., digesters, strippers

, etc.). The table below summarizes the different types of equipment for which specific questions are included in the PI E quip detail tab.

PI Equip detail tab

columns Description of information requested

A

- A R Equipment, exhaust flow rate, controls, and Federal rule applicability for each emission unit and collection system.

A S

- A U Digesters

A V

- A Z Pulp washers

BA

- BB Knotters, screens, and deckers

BC

- B E Evaporators

B F

- B H Oxygen deligni fication

B I

- B R Strippers

B S

- B V Pulp storage and liquor storage

BW

- B Z Liquor storage ponds

CA

- C D Causticizing equipment

C E Fuel

- fired equipment (e.g., boilers * , thermal oxidizers, direct

- fired dryers, etc.)

CF

- C G Equipment incinerating NCG or SOG

CH

- D P Primary and supplemental fuels for fuel

- fired equipment (e.g., for boilers * , thermal oxidizers, direct

- fired dryers, etc.)
DQ

- D W Emission unit startup and shutdown.

DX Comments *Not required for boilers if Boiler MACT survey IDs are specified.

Da ta are requested for each emission unit (and need not be broken out by individual emission points for a given

emission unit unless different collection or control measures apply for the different emission points from an

emissions unit or the characteristic s of the emission points are different )

. Specify the Emission Unit ID and Collection system ID (if applicable), and APCD_ID(s) by following the directions in the “ Instruction ” row of the PI Equip detail tab. Some common configurations of emission units a re addressed below.

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### 12 Multiple emission units ducted to a single release point. Unless the emission units are numerous and share similar design/operation (see exception below), then you should l ist each emission unit separately in the PI Equip detail tab e ven if the exhaust from the emission unit is ducted to a common conveyance. For multiple emission units ducted through a common conveyance to the same release point, list each Emission

Unit ID separately and provide the same Collection s ystem ID for the d ifferent Emission Unit ID s. For example, an LVHC collection system ( Collection system ID LVHC01) may collect emissions from multiple emission points associated with digesters 1, 2, and 3 and an evaporator ( Emission

Unit ID s D1, D2, D3 and EVAP1) . You sho uld list digesters 1, 2, and 3 and the evaporator on four separate rows in the PI Equip detail tab (with 4 separate Emission Unit ID s , as shown above ) and provide the data requested for each emission unit, indicating for each entry that the emissions

are c ollected by the LVHC collection system ( Collection system ID LVHC01)

. You should also list the LVHC collection system in the Emission Unit ID column (using the Collection s ystem ID = LVHC01 as the Emission Unit ID = LVHC01 ) so you can provide control info rmation and equipment details for the LVHC collection system. Exception: If the multiple emission units ducted to a single release point are numerous and identical in design/operation (for example

– 20 batch digesters all ducted to LVHC control and process ing softwood), then you may lump the emission units together on one row and note their total capacity. Note how many emission units are lumped together in the “Emission unit description” column (e.g., digester (20 units))

Single emission unit with multi ple release points

. In the PI Equip detail tab, EPA is most interested in learning how (or if) your emission unit is controlled and what Federal regulation compliance options are in

use as indicated in columns A through AR

. If the different release point s (vents or stacks) have different controls or different NSPS/NESHAP applicability then you will need to list each vent (or group of vents with the same controls) on separate rows. Repeat the Emission Unit ID on separate rows and distinguish the release p oints using the “Emission unit description” column in as many rows as needed to reflect all of the release points associated with the emission unit in the PI Equip detail tab. For example , Emission Unit ID 001 (EU001) is vented to two stacks with differe nt controls

. Split EU001 to EU001a and EU001b on separate rows of the PI Equip detail tab, and then indicate in

the “Emission unit d escription” column that EU001a and EU001b vent through separate stacks. Enter details associated with emission release (ex haust flow, APCD information and NSPS/NESHAP compliance options) in each row. Enter equipment details (year installed, hours per year [hr/yr], combustion controls, fuel data, equipment design and other operating parameters) in only 1 row, leaving all othe r rows associated with the Emission Unit ID blank.

If the different release points (vents or stacks) are uncontrolled, have the same control, and have the same NSPS/NESHAP applicability then you should list the emission unit on only one row. For example

, consider Emission Unit ID (OXDLIG), an oxygen delignification system with 6

uncontrolled vents

. You would list this OXD LIG system in only one row. In the “Emission unit exhaust parameters (if emitted through a conveyance)” columns, you would enter the to tal flow

from all vents combined and note in column Q stating "multiple vents combined.” You would specify the emission release details (exhaust flow, APCD information and NSPS/NESHAP compliance options) and any requested equipment information (year insta lled, hr/yr, etc) in the single row.

If an emission unit has some groups of release points (vents or stacks) that are controlled and some that are uncontrolled (or if NSPS/NESHAP applicability varies for different groups of release points) then you

should list the emission unit on multiple rows for each group of release points with similar controls or rule applicability. For example , consider Emission Unit ID (OXDLIG), an oxygen delignification system with 3 uncontrolled vents (under the CCA compliance opt ion) and 3 thermal oxidizer

- controlled vents

. You would list this OXDLIG system in two separate rows and distinguish the groups of release points using the “Emission unit description” column. In the “Emission unit exhaust parameters (if emitted through a conveyance)” columns, you would enter the total flow from all vents combined

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### 13 for each group of vents and note in column Q "multiple vents combined” on each row. Enter details associated with emission release (exhaust flow, APCD information and NSPS/NESHA P compliance options) in each row. Enter equipment details (year installed, hours per year [hr/yr], combustion controls, fuel data, equipment design and other operating parameters) in only 1 row, leaving all other rows associated with the Emission Unit ID blank.

Emission units vented into the building. Include emissions units that vent into a building in the PI Equip

detail tab, and enter “BLDG” in the “ Configuration if not emitted through a conveyance ” column.

Emission units that are not vented . Inclu de emissions units that are not vented in the PI Equip detail tab,

and enter “NV” in the “ Configuration if not emitted through a conveyance ” column.

Emission units with fugitive emissions . Include emissions units with fugitive emissions in the PI Equip

d etail tab, and enter “FUGITIVE” in the “ Configuration if not emitted through a conveyance ” column.

If an e mission unit produces both fugitive emissions and emissions that are emitted though a conveyance

, then you need to either: (1) specify the fugitive em issions on a separate row in the PI Equip detail tab (e.g.,

as a “ Single emission unit with multiple release points ” as described in the instructions immediately above

for the PI Equip detail tab ) , or (2) if you know the volume percent of exhaust flow capt ured from the emission unit (e.g., 60%), you could use only one row to represent the emission unit and note 60% capture in the “Control capture efficiency” column without specifying vent

- by

- vent details.

Bypass stacks used only during certain times

. Do not include data for bypass stacks or control system bypasses in the PI Equip detail tab , except as specified for alternate ( backup ) controls below

.

Air pollution control devices (APCD s )

. In the APCD columns, enter primary APCDs (i.e., the pollution

con trol used most frequently) in the sequence in which they are used to control emissions from each emission unit (or collection system) identified in the Emission Unit ID column. Enter a description of the APCD in the APCD “type” column and an ID code in th e APCD_ID column. The ID you enter into the APCD_ID field will correspond with the APCD_ID you enter in the Controls tab. For example,

I f you use an electrostatic precipitator ( ESP ) ( ESP1) followed by a scrubber (WSa), you would enter APCD1 type = ESP an d APCD2 type = scrubber, and APCD1_ID = ESP1 and
APCD2_ID = WSa.

I f a white liquor scrubber (identified as WLIQSBR) is used to scrub SOG prior to burning of the SOG in a lime kiln ( Emission Unit ID = LK2), then APCD1_ID = WLIQSBR and APCD2_ID

= LK2.

Emis s ion units routed to a boiler, lime kiln , or recovery furnace for emissions control . Enter the Emission

Unit ID s for each emission unit (e.g., digester) in the Emission Unit ID column. Use the boiler, lime kiln

, or recovery furnace ’s Emission Unit ID as the APCD

_ ID in the APCD colu mns. The same Emission Unit

ID (e.g., for the lime kiln or recovery furnace) should be used in Part I II when equipment

- specific details are provided for these equipment

. (Note that process details for lime kilns and recovery f urnaces are not required in Part I, but would be entered in Part III. You would only identify the lime kiln or recovery

furnace in P art I if it serves as the APCD for a Part I emission unit.)

Alternate controls. Alternate (or b ackup ) controls include al ternative controls used when flow from an emission source (e.g., high

- volume, low

- concentration ( HVLC ) or LVHC collection system) is diverted from the primary control device to a less frequently used control device. For example, the primary LVHC

control m ay be lime kiln 1 and the backup control may be a boiler when lime kiln 1 is not operating. Enter

alternate controls in the “ Alternate method of control ” column of the PI Equip detail tab. Do not include

alternate controls in the columns for APCD1 throug h APCD4.

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### 14 C omplete the applicable equipment

- specific details requested in columns A S through D U for each type of emission

unit in the PI Equip detail tab by following the directions in the “ Instruction ” row of the tab. Additional specific

instructions ar e provided below for e quipment requiring instructions beyond what could be explained in the

“ Instruction ” row. Leave columns that do not apply for a given emission unit blank rather than entering

“ NA ”.

All emission units listed in Attachment 1 . Complete columns A through A R . These columns ask generic questions for all emission units related to how the emission units are vented and controlled, and related to Federal rule applicability . Additional questions in columns A S through D U may also apply for sel ected emission unit types.

Pulp processing equipment . Information pertaining to pulp processing equipment such as d igesters , p ulp washers

, knotters, screens, deckers , e vaporators , and o xygen delignification is requested so EPA can determine the population

and characteristics of these emission units following subpart S MACT compliance

. Capacities are requested so EPA

can estimate emissions and perform impacts analyses

.

Strippers . Information related to strippers is requested to provide an understanding of the number and characteristics of strippers in use at pulp and paper mills following subpart S compliance.

Pulp storage and l iquor storage

, and liquor ponds

. HAP emissions may be associated with pulp and cooking liquor

sto rage tanks, and liquor storage ponds. Questions pertaining to pulp and liquor storage are asked to provide an inventory of storage equipment and to characterize any storage processes that may require further analysis for subpart S residual risk purposes.

Causticizing equipment . Limited questions are asked for equipment in the causticizing loop of mills that perform

kraft or soda pulping. Information on causticizing operations provides inventory detail and process rates for purposes of emission calculat ions, and can inform EPA of practices that could be used to reduce emissions from the lime kiln or from other causticizing equipment.

Boilers , thermal oxidizers, and direct

- fired dryers

. The EPA is requesting limited information on boilers (and other

fu el

- fired equipment such as thermal oxidizers and dryers) in the PI Equip detail tab . M any pulp and paper mills use boilers for primary or backup control of organics from pulping process , and some mills use thermal oxidizers for this purpose . B oilers (and other fuel

- fired equipment) currently con tribute to the facility

- wide risk levels at pulp and paper mills

.

Boilers are a special case. Many pulp and paper mills completed EPA’s 2008 Boiler MACT survey that provides greater detail than are requested in th e pulp and paper sector survey

. You are asked to first list all boilers at your facility in the Emission Unit ID column of PI Equip detail

. First , you should either (1) enter the Boiler MACT survey IDs requested for each boiler , or (2) complete all of th e details requested in PI Equip detail for the boilers. If

you enter the Boiler MACT survey IDs (FacilityID and UnitID) in the initial columns of PI Equip detail :

• Y ou do not need to complete following portions of PI Equip detail for your boilers: year in stalled, operating hr/yr, emission unit exhaust parameters, combustion modifications/controls, process controls, air What averaging period should be used in responding to process detail questions?

Several questions in the PI Equip detail and other survey tabs ask for process parameters such as exhaust flow rate (acfm), tem perature, etc. Unless otherwise speci fied, typical values are requested, and are subject to the respondent’s discretion. For example, if you measure a particular parameter with an online meter and you have data available for most operating hours of the y ear, then you may choose to supply an annual average for the parameter. However, if the parameter is only measured periodically, then you may want to provide the most recent measurement.

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### 15 pollution controls, fuel

- fired equipment, primary fuels, supplemental fuels, or emission unit startup/shutdown.

• You are required to complet e the Subpart BB and Subpart S applicability columns and “e quipment incinerating NCG or SOG ” columns for boilers burning pulp mill NCG or SOG.

• Boiler s burning NCG/SOG (and the boiler’s APCDs) must be indicated as the air pollution control on the

rows for t he Emission Unit IDs controlled by the boiler

.

Thermal oxidizers may be used to control emissions from Part I or Part III emission units . For example, LVHC thermal oxidizers are covered under Part I, and semi

- chemical liquor combustor thermal oxidizers are covered under Part III). You will only enter the thermal oxidizers that control emissions from Part I emissions units (listed in Attachment 1 of this document) in Part I of the survey.

Wastewater handling/treatment units . Complete the generic quest ions in Columns A through A R of the PI Equip

detail tab for any wastewater handling/treatment units that are closed and/or vent through a conveyance.

Primary and s upplemental fuels

. Fuel types are requested for fuel

- fired equipment because fuel type can have an

effect on emissions . The EPA may consider fuel types and perform calculations based on fuel firi ng rates for various nationwide impact analyses. Because the types and amounts of fuels fired can vary throughout the year

, EPA is requesting the appr oximate percent of annual heat input capacity in million British thermal units per year (MMBtu/yr) supplied by each fuel.

Primary and supplemental fuel information is requested for fuel

- fi red equipment su ch as boilers, thermal oxidizers controlling Part I emission sources , and direct

- fired dryers (e.g., pulp dryers or paper machine dryers). NCG and SOG are not considered to be either primary o r supplemental fuel s for purposes of this survey. Information for

s econdary and additional fuels used routinely f or multifuel

- fired equipment may be indicated in the supplemental

and other fuel columns.

Emission unit s tartup and shutdown

. Complete the startup and shutdown questions for all emission units currently subject to Federal or State emission limits or mon itoring 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 wi de variety of equipment used at pulp and paper mills. The EPA is considering standards that c ould 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 e mission standards. You are asked to s upply 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

. ) T he st artup and shutdown data in the PI Equip

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

c. PI Permit limits tab

Permit limits for each emission unit/point listed in Attachment 1 of th is document are requested with one exception (boilers). You do not need to provide permit limits for boilers . You are only asked to include permit limits for the

emission units listed in P art I Attachment 1 at this time. However, you may also include pe rmit limits for the chemical recovery combustion source emission units listed in Part III Attachment 1 (and

, therefore, would not need to include these limits in Part III).

If available in the permit, provide limits in terms consistent with the suggested units shown in Table 2 below. These suggested units were taken from existing Federal limits codified in 40 CFR P art 60

, subpart BB or 40 C FR Part 6 3

, subparts S or MM. Specify permit limits as written in t he permit if the suggested units are not included in the permit. You do not need to convert limits to the suggested units. You may specify limits for a given pollutant in multiple units/formats (e.g., ppmdv and/or % reduction) if the permit is written to include multiple compliance

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### 16 options. However, yo u do not need to provide every unit/format for pollutants with multiple limits in different units of measure or formats (e.g. , only provide ppmdv and lb/MMBtu at specified % oxygen ( O 2 ) for a combustion unit sulfur dioxide ( SO 2 ) limit specified in the perm it in terms of ppmdv, lb/hr, lb/day, and tpy, lb/MMBtu at specified

% O 2 , etc.). The survey spreadsheet allows for up to five different permit limit formats for the same pollutant. Permit limits of most interest to EPA are concentration limits (ppmdv, gr /dscf, etc.), percent reduction, mass per unit production (lb/ton of material throughput, etc

. ) because these limits can be compared from facility to facility independent of emission unit or mill capacity. EPA will use the permit limit information you su pply in comparing permit limits across similar emission units nationwide. Please be as specific as possible when entering permit limit units. Include any oxygen correction factors (% O 2 ). Be sure to note if ppm values are on a dry (d) or volume (v) or

w eight (w) basis if specified this way in your perm it (ppmdv, ppmdw, ppmv, ppmw). Please note:

State Mass

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

- only required modeling, are not being requested unless this is the only way in which limits are specified in the permit. The EPA is most interested in state permit limits that are more stringent than those limits in federal rules (e.g., PSD Avoidance or BACT limit s ).

Permits restating NESHAP and NSPS limits

. Your pe rmit may simply restate the emission limits contained in Federal rules such as NESHAP subparts S and MM

. Some permits may list all of the compliance options contained in the Federal rules as permit limits. If this is the case, you do not need to enter pe rmit limits that are exactly the same as Fede ral NESHAP or NSPS. Instead, specify the applicable Federal rule (not the specific numeric Federal limits) in Column F and skip the remaining permit questions/columns in the table. If your permit contains addi tional State limits in terms other than the Federal limit, please indicate these limits in the appropriate column (e.g., Column G for permit limit 1, Column J for permit limit 2, etc.) Please do not enter State lb/hr or tpy emission limits in addition to the Federal limits.

Opacity

. The opacity limits of most interest to EPA are those for fuel

- fired equipment such as recovery furnaces, semi chemical combustion units, lime kilns, and thermal oxidizers. You do not need to include State opacity limits for e very emission unit (only the fuel

- fired units).

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

survey

. While we would prefer to receive data in the PI Permit limits tab, we will accept a copy of your operating permit (e.g., title V operating permit) instead of the completed PI Permit limits tab. Other complete and up

- to

- date summaries of permit limits

, such as a mill

- specific summary of permit limits or compliance matrix

, would be acceptable as w ell.

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### 17 Table 2. Suggested Units of Measure for Permit Limits

Pollutant Suggested units

PM 1 Recovery furnaces/chemical recovery combustion units: gr/dscf @ 8% O 2 SDT: lb/ton BLS LK: gr/dscf @10% O 2 PM 10 1 Other processes: lb/ton of throughput, lb/MMBtu , gr/dscf, g/dscm, or specify

PM 2.5 1

Opacity % (provide averaging time)

TRS RF/combustion units: ppmdv @ 8% O 2 SDT: lb/ton BLS (as H 2 S) LK: ppmdv @ 10% O 2 Other processes: lb/ADT pulp and/or ppmdv

SO 2 lb/MMBtu and/or ppmdv or limits on fuel S conte nt

NO X lb/MMBtu (as NO 2 ) or ppmdv

CO lb/MMBtu or ppmdv

Pb or other HAP metals Specify units

VOC lb/{production}, specify if as propane, etc. or ppmdv

THC Report as carbon.

RF/combustion units: l b/ton BLS

HCl ppmdv and/or % reduction

Methanol and g aseous organic

HAP chemical recovery combustion sources: lb/ton BLS process sources: ppmv @ 10% O 2 , lb/ton ODP, and/or percent reduction

Chlorine and chlorinated HAP ppmv, lb/ton ODP, and/or percent reduction Other speciated HAP (specify...) Specify units

1 Specify filterable and/or condensable if your permit limits distinguish between the filterable and condensable PM

fractions.

d. PI Controls tab

Complete the PI Controls tab by following the instructions in the “ Instruction ” row for add

- on APCD s us ed to control pulp and paper emission units

. The data requested in the PI Controls tab include pertinent control device design parameters that will be used by EPA to distinguish among control devices (e.g., pressure drop and L/G ratio

can b e used to ident ify high

- vs. low

- efficiency wet scrubbers) and to understand the non

- air environmental impacts associated with the control devices (e.g., amount of wastewater or solid waste generated and methods for handling).

Baghouses, cyclones, and other material ha ndling equipment. The EPA is most interested in details for control systems used to reduce HAP emissions (for equipment in the NESHAP source categories) and criteria air pollutant emissions from equipment in the NSPS subpart BB source category. You do no t need to include the specific detail s requested in the PI Controls tab for control devices used solely for wood/material handling operations (e.g., baghouses or cyclones on pneumatic wood handling systems; and particulate controls on lime, starch, or coal handling etc

. need not be included ).

Boilers . You do not need to include details for APCDs used to control boilers in the PI Controls tab

.

Actual c ontrol efficiency . Actual control efficiencies are requested for PM, TRS, HCl, SO 2 , and other HAP. Thi s information will be used in d etermining the capability of different control devices for reducing emissions. If you

have data from inlet/outlet emissions testing used to determine a percentage reduction in the requested pollutant

across the control devic e, th en you would enter this test result as the “actual” control efficiency. You may l eave the control efficiency columns blank (rather than marking as “NA”) if actual control efficiency is not known ( or not applicable for a given pollutant)

.

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### 18 Stripp ers . Specific information for strippers used to reduce air emissions from process liquid or wastewater streams is requested in the PI Equip detail tab rather than in the PI Controls tab

.

Thermal oxidizers . Questions pertaining to thermal oxidizers contr olling Part I emission sources are included in

both the PI Control s and PI Equip detail tabs. The PI Equip detail tab contains questions about heat input capacity,

e quipment incinerating NCG or SOG

, and primary or supplemental fuels

.

Control device s tart up 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 Fede ral 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 sta rtup 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 device parameter limits may remain in effect during startup and shutdown events, and which parameter

lim its may need to be replaced with another requirement during startup and shutdown. In all of the control device startup and shutdown questions, y ou are asked to s upply 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 PI Controls tab are being sought for regulatory development purposes, and will not be used for enforcement purposes.

e. Pulp prod tab

T he Pulp prod tab is to be completed by all mills t hat produce pulp onsite using chemical, semichemical, mechanical, non

- wood, and secondary fiber pulping processes. This tab is arranged in a way to accommodate multiple pulping processes or pulping lines (if applicable) and each pulping process/ line should occupy only one row (e.g.

, a mill that co

- produces kraft and mechanical pulps should use two rows). Some data fields apply for specific types of pulp (e.g

. , m echanical pulp, non

- wood pulp). If a data field does not apply to a particular type of pulping line, you may simply leave the field blank rather than marking it “NA”

. Provide data for the 2009 operating

year.

The pulp capacity data will be used by EPA to understand the general mill flow and in estimation of impacts and economic analyses. In the Pulp prod tab, t he 2009 pulp capacity (ADTP/d) and capacity util ization refer to unbleached pulps (i.e., pulp exiting the pulping line prior to any brig htening or bleaching). [Note: Capacity of bleached pulp (e.g., pulp exiting the bleaching/brightening l ine ) is requested in the Bleaching tab.] An example of

how to calculate the pulp capacity utilization percentage requested in the Pulp prod tab is as follows:

A B C D E F Pulping

process Pulp nominal daily production capacity

ADTP/d in

2009 Max

. d /yr Actual 2009 operating d /yr when pulp was produced 2009 nominal production capacity, ADTP/yr (= A x B) 2009 actual production, ADTP/yr* (= A x C) Pulp capacity

ut ilization d ecimal percentage in 2009 (= E / D)

kraft 950 365 340 346,750 323,000 0.93

mechanical 300 365 250 109,500 75,000 0.68 ADTP/d = air dried tons of pulp per day

. *The 2009 actual pulp production could be determined by multiplying

columns A x C or by other means. The EPA is not asking that you report the 2009 actual production.

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### 19 In the Pulp prod tab , EPA asks questions regarding how various pulps are used by the mill in order to understand the

mill flow for purposes of economic modeling . With t h ese questions, EPA seeks the amount of unbleached pulp from the pulping line that typically:

• goes to an onsite bleaching/brightening line (if applicable)

• is sold (or transferred to another mill within the same company) as unbleached market pulp

• is used on site to manufacture unbleached paper/paperboard

Complete the Pulp prod tab by following the instructions in the “ Instruction ” row.

f

. Byproducts tab

Mills that recover turpentine or tall oil from pulping processes should complete the Byproducts tab . B asic turpentine and tall oil production information are requested ( hr/yr, gal/ yr, and equipment supplying byproduct production )

. Turpentine recovery systems are covered under subpar t S. Tall oil production may be considered in the review of pulp and pape r regulations. The information requested may be used to estimate emissions and in economic

calculations.

Complete the Byproducts tab by following the instructions in the “ Instruction ” row.

g

. Kraft condensates tab

Complete the Kraft co ndensates tab by following the instructions in the “ Instruction ” row. The kraft condensate standards in subpart S apply to certain “named” condensate streams originating from the following equipment:

• Digester systems

• Turpentine recovery systems

• Evaporator systems

• HVLC collection systems

• LVHC collection systems

• Combined systems (i.e., a combination of any of the above named systems)

The kraft condensate streams are "named" in §63.446(b). In the kraft condens ates tab, you are asked to list (select from menu) each kraft condensate stream (or combination of streams) named in subpart S. Next you are asked to enter the Emission Unit IDs or Collection system IDs associated with each kraft condensate stream, and indicate whether the condensate stream is treated (or partially treated) according to subpart S.

You do not need to list every single condensate stream separately. If condensates from multiple systems are combined for treatment, then you may select menu choice “Combined systems” and then enter the Emission Unit

ID s or Collection system IDs for the combination of systems (grouped according to the treatment method).

In some cases mi lls may have complied with the subpart S kraft condensate standards through implementation of an equivalency

- by

- permit project involving other condensate systems not named above. If you are controlling condensate streams other than those named in subpart S for purposes of subpart S compliance, then you are asked to

list these “un

- named” condensate sources as menu choice “Other systems” an d then describe the streams being

controlled (e.g., Other systems

– foul water collection)

.

Uncontrolled/uncollected streams (table heading II)

. Mills may either collect/control all "named" kraft pulping

condensates (according to §63.446(c)(1)) , or empl oy one of the volume reduction options are specified in subpart S at §63.446(c)(2) or (3). Mills may also comply with subpart S through equivalency

- by

- permit. For “named” condensate streams that are uncollected/uncontrolled, you are asked to complete the question in table heading II to describe why the stream “named” in subpart S is not collected/controlled (e.g., because you meet one of the volume reduction options; or use equivalency

- by

- permit to control un

- named streams in lieu of the named streams).

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### 20 Recycled streams (table heading III) . Indicate if subpart S compliance is achieved by recycling the condensate to equipment meeting the kraft pulping system vent standards. S pecify the equipment Emission Unit ID receiving recycled condensates.

Conden sate treatment (table headings IV

- VII )

. Specify the treatment methods and provide compliance test results under table headings IV

- VII for each condensate stream treated/controlled for purposes of subpart S compliance. The kraft condensate control options are summarized as follows. This table corresponds with the pull down menu options for condensates treated by steam strip pers, biological treatment , or other means

.

Control option Applicability Rule refere n ce

92% total HAP reduction (by weight) §63.4 46(e)(3)

Remove 6.6 pounds/ton ODP Mills that do not bleach §63.446(e)(4)

210 ppmw at the outlet of the control

device Mills that do not bleach §63.446(e)(4)
Remove 10.2 pounds/ton ODP Mills that bleach §63.446(e)(5)

330 ppmw at the outlet of the contr ol

device Mills that bleach §63.446(e)(5) Remove prora ted mass of ___ pounds/ton ODP. { Respondent should specify limit in

blank } Mills producing a

mixture of bleached and unbleached pulp §63.446(i )

If your mill uses multiple treatment methods for a giv en kraft condensate stream, please answer the questions for

each treatm ent method (under table headings III, IV, V, and/or VI ) and the question in table heading VII . For example, if your mill normally treats condensates with a steam stripper but relies on biological treatment when the stripper is down, then you would respond to the questions under table headings IV (stripping), V (biological treatment), and VII (mu ltiple treatment methods).

Comments . Should you have comments regarding the kraft conden sate data you supply, please enter these

comments in column S.

h

. CCA tab

The CCA tab is divided into two portions: (1) Emission B alance to the left of the orange vertical lin e (column H )

, and (2) CCA Equipment List on the right of the orange vertical l ine. You will enter one row of data for the

Emissions Balance and multiple rows of data for the CCA Equipment List. This information is being requested to

inform EPA of the mill

- specific emission units involved in CCA compliance calculations.

The CCA tab must be completed once for each set of CCA compliance calculations used by your mill. Add another CCA tab if you need to provide more than one set of CCA calculations. As an alternative to completing the CCA tab, you may attach separate documentation of your CCA calculations used for purposes of showing compliance.

Sources eligible for inclusion in the CCA as credit generators include (but are not limited to) : pulping systems, bleaching systems, causticizing systems, wastewater systems, and papermakin g systems. Debit generating sources can include equipment from the kraft mill HVLC system, including: pulp washing systems, knotter systems, screen systems, decker systems, O 2 delignification systems, and weak liquor storage tanks. Refer to the system definitions in subpart S at §§63.441 and 63.447(a). If equipment other than that listed above is included in your CCA

calculations (e.g., equivalency

- by

- permit facilities) , please include that equipment in the CCA tab. EPA is interested in identifying wh ich mills are using the CCA option and the mill

- specific equipment used in CCA

calculations. EPA is not requesting detailed calculations used to show compliance with the CCA at this time. However, EPA reserves the right to request additional detail if ne eded as a follow

- up to this survey.

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### 21 Complete the CCA tab by following the instructions in the “ Instruction” row.

i

. Bleaching tab

All mills that perform bleaching or brightening of chemical, mechanical, secondary fiber, or non

- wood pulps should

comp lete the portion of the Bleaching tab to the left of the orange vertical line (column M ) to describe the bleaching (or brightening) systems used at your mill. Note that, for brevity, the terms “bleaching” and “bri ghtening” are used interchangeably in the Bleaching tab (e.g., the word “bleaching” can be read to me an “brightening” if that is the process your mill uses).

Your response in the Bleaching tab will consist of one row for each ble aching /brightening line located at your mill.

Most mills will hav e only one or two ble aching line rows

. For example, a mill that produces bleached chemical pulp, bleached secondary fiber pulp, and brightened mechanical pulp could include three rows (one for each type of pulp that is bleached/brightened using separate b leaching/brightening processes).

If your mill does not have a bleaching “ line ” (e.g., a TMP mill with only one emission unit for mixing brightening chemicals with pulp), the you need only to list the Emission Unit ID for the bleaching/brightening emission unit and

answer the questions to the left of the orange vertical line (entering “ NA ” for questions that are not applicable.

If your bleaching system includes any stages that use c hlorine or chlorinated compounds , then you must complete the portion of thi s tab to the right of the orange vertical line. E xtraction or other bleaching stages that do not use

c hlorine or chlorinated compounds are not covered by subpart S and shou ld be reported in the Bleaching tab with

“ N A (no chlorine or chlorinated compounds u sed in this stage) ” indicated.

When specifying controls used for the various bleaching stages, enter not applicable “N A ” for stages without
control. Enter the APCD_ID used in the PI Equip detail and PI Controls tabs when referring to any control device

. Each bleaching stage includes several vents: the tower vent, washer hood, seal tank vent, chemical and steam mixers, and vacuum pumps. If all vents from a particular bleaching stage are not routed to the control device indicated for that stage, then y ou should describe the control system configuration in the control methods column.

Responses to these bleaching questions will be used to characterize mills according to bleaching processes used, estimate nationwide emissions, and identify subpart S compl iance options commonly used (e.g., to determine if any remaining residual risk is associated only with bleaching at mills meeting certain compliance options)

. Information

on how the mill uses the pulp exiting the bleach plant may be used for economic mode ling and in characterization of potential emissions from paper machines (e.g., use of bleached/unbleached pulp produced onsite, use of purchased pulp, effects of bleaching process on paper machine emissions, etc

. )

.

Complete the Bleaching tab by following the instructions in the “ Instruction ” row.

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### 22 j

. Paper prod tab

All mills that produce paper should complete the Paper prod tab. Report information for all operable paper machines (including idle machines that are capable of operating in the future ). Do not include pulp dryers in the Paper prod tab. Complete the Paper prod tab by following the instructions in the “ Instruction ” row.

If multiple paper grades are produced on the same paper machine (e.g., coated free sheet produced some of the time,

and unc oated freesheet produced at other times), then you will need to include paper machine information on separate rows. Given the numerous specific grades of paper and paper characteristics, EPA reque sts that you distinguish among a relatively short list of g eneralized paper grades, including:

coated free sheet kraft packaging

uncoated free sheet linerboard coated groundwood corrugating medium uncoated groundwood solid bleached board tissue & sanitary recycled board specialty packaging & industrial cons truction paper and board

other * *Respondents are asked to specify a general paper grade in the event that one of the

general grades listed above is not representative.

Information on pulp type is requested because it is possible that pulp type ma y have an effect on emissions (particularly for bleached versus unbleached pulps). Should EPA consider paper machines for residual risk rulemaking, information such as pulp type, whether the pulp is bleached or unbleached, paper grade, stock consistency, and liquid HAP concentration may be useful for purposes of subcate gorizing paper machines.

You are asked to s pecify the approximate makeup of each paper machine furnish

- specifically the approximate percentage of each pulp type

. We recognize that the p ercentage can vary throughout the operating year and within paper grades (due to specific product variations) , and therefore, a specific percentage is not being requested. It will be sufficient to round to the nearest 5 or 10 percent.

k

. HAP additives t ab

Complete the HAP additives tab for any stock preparation and paper machine additives that contain “ measurable ”

concentrations of one or more of the following HAP : formaldehyde, acetaldehyde, napthalene, methylene chloride, acrylamide, or benzene

. Onl y include in this tab additives with measurable quantities of HAP as reported on the material safety data sheet (MSDS) for the additive. For purposes of this survey, “measurable” is defined consi sten t
with OSHA requirements that chemical suppliers provide specific constituent amounts in Material Safety Data Sheets for any carcinogens that are present in amounts greater than 0.1 percent and any non

- carcinogens that are present in amounts greater than 1 percent. Information on lesser quantities of HAP ingre dients is voluntary but not required. A lthough it is unclear whether paper machine additives contribute significantly to paper machine emissions (e.g., because additives may partition to the paper product or white water, and not necessarily to the air)

, E PA is requesting information for paper machine additives that contain HAP of significance for purposes of residual risk. EPA is not requesting information for other paper machine additives (many of which contain no HAP) , except in determining any non

- HAP substitutes for the additives

. Th e HAP additives information would be used (e.g., along with emissions data for paper machines) to identify HAP

- containing additives that may contribute significantly to paper machine HAP emissions or residual risk , and to evaluate work practices related to additives

.

Complete the HAP additives tab by following the instructions in the “ Instruction ” row.

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### 23 l

. WW tab

All m ills with onsite wastewater treatment plants (WWTP) should complete the WW tab columns to the left of the orange vertical line (column AA )

. The first questions in the WW tab ask if your mill outsources wastewater treatment to a publicly owned treatment works (POTW) or other separate entity such as a privately held entity that may be owned and operated by your same compan y or a different company. The purpose of the WW tab is to provide EPA with information regarding the status of permitting requirements and emissions measurement for pulp and paper mill wastewater treatment plants. This information will b e used by EPA for purposes of reviewing the pulp and paper regulations (e.g., NSPS and/or NESHAP subpart S). Use the WW tab to specify any Federal/State/local requiremen ts, permit limits, fence

- line monitoring, measurement methods (such as ambient

measure ments) , or modeling methods that apply for measurement or estimation of HAP and TRS (including H 2 S) air

emissions associated with the wastewater treatment system

.

In addition to questions about measurement and permitting status, mills are requested to sub mit a flow diagram of the WWTP (see section D1 of these instructions) and to complete some basic questions regarding WWTP capacity, the sequence of wastewater treatment units, and upstream controls/practices that reduce air emissions from the

WWTP. Mills are also asked to identify any wastewater treatment units that are closed to limit emissions to the atmosphere , or e quipped with a closed

- vent collection system and APCD

. If any wastewater treatment u nits are equipped with a closed

- vent collection system an d APCD , then you should also include the wastewater treatment

unit in the Emission Unit ID column of th e PI Equip detail and PI Control tabs and indicate the APCD information

in those tabs.

The series of questions seeking an approximate volume percent age of WWTP capacity from various mill areas will inform EPA of the overall nature of the wastewaters generated by pulp and paper mills for treatment. Mills are encouraged to complete this series of questions to the extent this information is known (or ca n reasonably be estimated). Otherwise, mills may enter “UK” for unknown. I f the WWTP is outsourced to a joint treatment facility

that treats process wastewater from several mills owned by the same company, then the volume percentage questions should be a nswered for each individual pulp and paper mill in their survey response considering the total volume of wastewater sent to the WWTP by that mill.

Mills with wastewater treatment plants that serve as the biological treatment system for the subpart S kraf t condensate standards must complete the questions to the right of the orange vertical line in the WW tab. These questions request the subpart S quarterly biological treatment system compliance testing results for the four quarters of calendar year 2009. This information will inform EPA of the performance of biological treatment systems in destroying HAP.

Complete the WW tab by following the instructions in the “ Instruction ” row.



### D 3

. Test data

Attachment 3 of this Part I survey contains a table of em ission units and pollutants for which existing emission s data are requested. Emissions data are being requested in the form of emissions test reports or continuous emissions monitoring data , whichever may be available. You are not required to conduct any new emissions testing or continuous emissions monitoring to respond to this survey

. Follow the instructions below for the “ PI Emissions test data tab” for emissions test reports. Follow the instructions for completing the “ CEMS data spreadsheet ( P&P

CEM S_PI.xls ) ” if you have continuous emissions monitoring system (CEMS) data instead of emission test reports for a given emission unit and pollutant combination. The emissions test data collected will provide valuable

information on current emissions levels and will allow EPA to consider variability in emissions from mill to mill (and over time for a given emission unit and pollutant) in reviewing and setting emission standards

. When submitting test data, EPA is requesting full test reports with field and l ab data sheets and example calculations, not just summary reports.

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### 24 Mills required to complete Part III may postpone until the deadline for Part III submittal of emissions test data and CEMS data required for the emission units listed in Part I Attachment 1 for the following pollutants: PM, PM 2.5 , TRS, NOx, SO2, and CO.

a. PI Emissions test data tab

Attachment 3 of this survey contains a table of emission units and pollutants for which existing emission test data are requested. You are not required to conduct any new emissions testing to respond to this survey. The EPA is only requesting existing emission test reports at this time as they may already be available

.

Emissions test data are not requested for power boilers unless the power boiler is u sed to control NCGs or SOGs (in which case the test data requested are for the pulping systems controlled by the power boiler, assuming these emissions points have been tested).

Review the test data request table in Attachment 3 of this survey. Locate an y existing emissions test reports in your

files that match the test method and other criteria for each emission unit and pollutant combination requested. Emissions test data representative of your current operations are requested. You are not required to supply emissions data that are no longer representative of the current emission unit and control system configuration. For example, if you have installed controls or made significant process changes expected to change emissions

, then you need no t supply emissions data for the prior configuration. However, you may voluntarily supply emission s da ta for prior configurations, as such information would be useful to EPA in characterizing emissions in general (for non

site

- specific uses) , but we request that yo u identify that such data are no longer representative in the PI Emissions

test data tab.

C utoff dates are provided in Attachment 3 for certain emission unit and pollutant combinations. More recent cutoff

dates (e.g., 2001 or date of MACT compliance) ar e specified for emission unit and pollutant combinations expected to be widely available. Longer cutoff dates (e.g., dating back to 1990) are included for emission unit and pollutant combinations for which data are likely to be sparse. Test d ata prior to the cutoff dates are requested only if necessary to obtain results of at least one representative test for a given process unit and pollutant.

Provide available test data for multiple years dating back to the cutoff date. Multiple years of test data wil l allow EPA to examine and account for variability in emissions in setting emissions standards

.

Supply both APCD inlet and outlet data if available.

As noted above, s ubmit full and complete copies of the emission test reports , to include field and la b data sheets and example calculations, meeting the criteria in Attachment 3 with your survey response. Electronic (pdf) or hard copies are acceptable. Include the summary portion of the report and any appendices showing run

- by

- run test parameters, metho d detection limits, laboratory data, production data, example calculations, etc. EPA will extract the test data from the emission test reports for use in nationwide regulatory analyses.

Complete the PI Emission s test dat a tab to identify the specific emi ssion units and control systems for which

emission te st reports are being submitted, the pollutant tested, and the test method. The PI Emission s test data tab will be used by EPA as the starting point for development of the emissions test data base that E PA intends to

construct based on the emission s test data received through this survey.

b. CEMS data spreadsheet ( P&P CEMS_PI.xls )

The EPA is requesting existin g CEMS data an d/or continuous opacity monitoring system (COMS) data for calendar year 2009 (CY 2009) operations from facilities that have installed continuous monitoring systems. You are not required to install or operate any new CEMS or COMS to respond to this survey.

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### 25 CEMS data that are representative of your current operations are requested. Y ou are not required to supply CEMS data that are no longer representative of the current emission unit and control system configuration.

You do not need to supply CEMS data for power boilers unless the boiler has a CEMS installed to show compliance

with a NESHAP subpart S or NSPS subpart BB emission limit

.

A separate Microsoft Excel spreadsheet file ( P&P CEMS_PI.xls ) i s provided for submittal of the re quested CEMS data. The spreadsheet file contains individual worksheets (tabs) designed specifically for TRS (12

- hour block average), TRS (hourly), Opacity, and other pollutants ( NOx, SO 2 , CO, Methanol, Chlorine, and PM ) . Each

worksheet is designed to accommodate data from one CEMS (including oxygen data) . If you have multiple CEMS (e.g., two TRS CEMS o n different emission units ), then you must copy the relevant worksheet in order to enter data

for the additional CEMS.

A brief introduction to each of the CEMS worksheets follows. Additional, field

- specific instructions are included on

each worksheet. A n “EXAMPLE” completed worksheet is also provided as a separate tab within the P&P CEMS_PI.xls spreadsheet file

.

TRS (12

- Hour Average) . This worksheet is designed for recovery furnaces, smelt dissolving tanks, lime kilns, digester systems, brown stock was her systems, multiple effect evaporator systems, and condensate stripper systems subject to the TRS monitoring requirements in NSPS subpart BB , but can be used for any

emission units with TRS CEMS (e.g., for compliance with State emissions standards which may be based on the TRS emissions guidelines) . Respondents are requested to specify the Emission Unit ID (or C ollection system ID) , the APCD_ID, and report the 12

- hour averages of CEM S concentration data for TRS for

CY2009 operations . In addition, respond ents are asked to provide the highest single 12

- hour average TRS

concentration recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or shutdown, and (c) under m alfunction conditions

. [Note: The reported concentrations of TRS should be

corrected to 8% O 2 for recovery furnaces and 10% O 2 for lime kilns and other equipment.]

TRS (1

- Hour Average) . Same as above, except that this worksheet is designed to accept the 1

- hour average

TRS data for the same time period as provi ded for the 12

- hour averages.

Opacity . This worksheet is designed for recovery furnaces or lime kilns equipped with COMS but may be

used for thermal oxidizers and other equipment . Respondents are re quested to specify the Emission Unit ID (or C ollection system ID) and the APCD_ID, and report the 6

- minute a verage opacity for CY 2009 operations

. An optional column is also included for hourly average opacity for mills that calculate an hourly

average. In addition, respondents are asked to provide the highe s t single 6

- minute average opacity recorded

in CY2009: (a) under normal operating conditions, (b) under conditions of startup or shutdown, and (c) under

m alfunction conditions

.

Other pollutants (such as NOx, SO 2 , CO, total HAP, methanol, total chlorina ted HAP

, chlorine, HCl, or PM)

. This worksheet is designed for any emissions unit equipped with a CEMS. Specify the continuously monitored pollutant at the top of the worksheet. Respondents are requested to specify the Emission Unit ID (or Collection sys tem ID) and the APCD_ID (or type of combustion controls used), and report the 1

- hour averages of the CEMS data for CY2009 operations. In addition, respondents are asked to provide the highest single 1

- hour average concentration recorded in CY2009: (a) und er normal operating conditions, (b) under conditions of startup or shutdown, and (c) under malfunction conditions.

OPTIONAL

- CEMS cost . Completion of this worksheet is OPTIONAL. This worksheet requests equipment

cost data for CEMS or COMS installed w ithin the past 10 years. EPA can use these data to estimate costs of CEMS or COMS when evaluating monitoring options.

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### 26 D4

. Optional cost dat a

The EPA requests information related to the capital and operating costs of selec ted air pollution controls or process/equipment changes. Providing this cost information to EPA is optional at this time

. The Agency wishes to receive enough cost information on a voluntary basis to perform regulatory analyses. However, should additiona l cost information be needed, EPA reserves the right to follow up with mills that have installed equipment or implemented process changes of interest to request cost information under CAA section 114 authority.

The spreadsheet entitled “P&P costs OPTION AL _PI .xls” can be completed to provide cost information. This spreadsheet contains two tabs ( APCD costs and Equip change costs ). The EPA recognizes that cost information can

be sensitive. The “P&P costs OPTIONAL _PI .xls” spreadsheet contains a red block a t the top of each tab where you

can indicate if the tab contains CBI, or if the entire tab should be treated as CBI

. Responses containing CBI should be submitted according to the instructions in section C 2 of this document.

Any cost information that you provide would be very useful to EPA for purposes of evaluating the costs of control measures that may be considered as regulatory options. These cost data will be used by EPA to estimate the

nationwide costs of any regulatory options based on the control measure indicated. Cost information from within

the last 10

- 12 years is requested (e .g., costs dating back to 1998). The c ost information could come from vendor quotes for APCD or equipment changes that either have been implemented or were explored but n ot implemented.

For Part I, t he EPA is particularly interested in costs of the following APCD s . Please supply this informati on using

the APCD costs tab:

- Paper machine HAP control devices

- Controls that reduce HAP emissions from wastewater handling and treatment systems

- Bleach plant CO control devices

The EPA is particularly interested in costs of the following process changes or equipment changes/upgrades. Please supply this information using the Equip change costs tab

.

- Pro cess changes that reduce HAP emissions from wastewater handling and treatment systems

- Process changes to improve lime mud washing or to control makeup water quality in the causticizing area

- Process changes that reduce paper machine HAP emissi ons

Complete the APCD costs and Equip change costs tabs by following the instructions in the “ Instruction ” rows of those tabs. You may also submit information in an alternative format (e.g., as a n attachment to your response) if What if my data are not in a form that can be inserted into P&P CEMS_PI.xls ? It is very helpful for EPA’s data analysis purposes if data are entered into the P&P CEMS_PI.xls template provided. However, we understand that some CEMS software may not be configured to provide output that can be easily converted to our preferred spreadsheet format. We also understand that, in some cases, the hourly production data requested in the CEMS spreadsheet may not be coupled with the CEMS data or may not be available in a manner to be easily linked to the CEMS data. If you face these or related issues, please note that EPA is not asking you to hand

enter hard copy CEMS data into the spreadsheet. You may pr ovide CEMS data in an alternative format if you are unable to convert it to our spreadsheet format within the timeframe for this survey. We request that you provide CEMS data in a form suitable for analysis if possible (e.g., spreadsheet or data base form at is preferred over read

- only pdf format). We’d accept more recent CEMS data (e.g., from the most recent 6 months) if 2009 CEMS data are no longer in electronic form due to company records retention policies. Further, you may omit the production data if they cannot reasonably be included in your CEMS spreadsheet. Estimates of production data are acceptable (e.g., if you have a daily production rates, you may divide by 24 operating hours in a day to estimate hourly production).

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### 27 needed. Because the cost data will be used by EPA to estimate the nationwide costs , please note if you believe that any portion of the cost information that you supply would be completely unrepresentative of costs that other mills may face for similar control projects (e.g., if y our project capital cost included installation of extra buildings, land purchases, etc. that may n ot be required for other mills)

.

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### 28 PART I

- ATTACHMENT 1

Emission Units to Includ e in the Part I Pulp and Paper Survey Response

Include the following typ es of equipment (emission units) in your Part I survey response. You may not operate all of the emission units listed below. Only include equipment operated at your mill. The purpose of the detailed list below is to ensure all emission points are repres ented. You may aggregate the equipment listed below into larger systems as appropriate in your survey response (e.g., you may list “bleaching stage 1” as an emission unit instead of every pump, tank, and hood vent within bleaching stage 1 as long as “blea ching stage 1” represents all of the emission points associated with that system)

. [Note: Chemical recovery combustion units are included in Part III.]

C austicizing E quipment Green liquor clarifier Green liquor storage tank Green liquor surge tank

Sl aker

Causticizers White liquor clarifier White liquor storage tank White liquor pressure filter tank White liquor/weak wash pressure filter Weak wash storage tank Dregs washer Dregs filter exhaust

Lime mud washer Lime mud filter system

Digester Area Equip ment Digester Chip bin Chip steaming vessel

Flash tank

Blow tank

Condenser Turpentine decanter

Pulp Washing, Thickening, a nd Storage Equipment

Brown stock washers

Hoods

Filtrate tanks Vacuum pumps

Screens

Kno tters
Decker

S tock chests (including open stock chests ) Pulp storage tanks

T hickeners Evaporators Black liquor storage tanks Evaporator h ot wells

Condensers

Boilout tanks Soap storage tanks Soap skimmer tanks Other emission points associated with evaporators.

Oxygen Delignification Equipment Oxyg en delignification reactor

Ox ygen delignification blow tank Oxygen de lignification washer

Po st

- oxygen washer filtrate tank Pulp storage tanks Other oxygen delignification system emission points.

Non

- c ondensable G as (NCG ) Collection LVHC system HVLC syste m

S tripper S ystem Equipment Stripper feed tanks

Condensers Heat exchangers

M ethanol Rectification Equipment

Rectifiers

Condensers

Decanters Storage tanks

Storage T anks Weak liquor storage tank s Strong liquor storage tank s Liquor storage ponds

Acid co ndensate storage tank s (at sulfite mills)

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### 29 T all Oil Production Equipment

Tall oil acidulation reactor Storage tank Dehydrator

Brine storage tank

Screen Centrifuge tan k Other tall oil production vents

Bleaching Equipment

T ower vent s W asher hood s S eal ta nk vent s C hemical and steam mixers

Vacuu m pumps

M echanical Pulping Equipment Stone grinder

Refiner Chip pre

- steaming vessel Chip cooker

Screen

Decker Brightening/bleaching tower

Non

- wood Pulping Equipment

Secondary Fiber Pulping Equipment

Paper Making Equipment Paper machines Pulp dryers

Machine chest Repulpers

Stock b lending and storage tanks

Broke tanks

Savealls White water storage tanks Wastewater T reatment S ystem U nits

Clarifiers Settling ponds

Aerated stabilization basins Activated sludge systems UNOX systems

Wastewater tanks Other wastewater handling and treatment units

Power B oilers

– PI Equip detail tab only

Thermal O xidizers/ I ncinerators controlling Part I

emission sources

Woodyard O perations

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### 30 PART I

- ATTACHMENT 2

Small Business S ize Standards

Small Business Size Standards for NAICS Subsector 322

– Paper Manufacturing

NAICS

Codes NAICS U.S. industry title Size

standards in

number of employees

322110 Pulp Mills 750

322121 Paper (except Newsprint) Mills 750

322122 Newsprint M ills 750

322130 Paperboard Mills 750

322211 Corrugated and Solid Fiber Box Manufacturing 500

322212 Folding Paperboard Box Manufacturing 750

322213 Setup Paperboard Box Manufacturing 500

322214 Fiber Can, Tube, Drum, and Similar Products Manufactur ing 500

322215 Non

- Folding Sanitary Food Container Manufacturing 750

322221 Coated and Laminated Packaging Paper Manufacturing 500

322222 Coated and Laminated Paper Manufacturing 500

322223 Coated Paper Bag and Pouch Manufacturing 500

322224 Uncoate d Paper and Multiwall Bag Manufacturing 500

322225 Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses 500

322226 Surface

- Coated Paperboard Manufacturing 500

322231 Die

- Cut Paper and Paperboard Office Supplies Manufacturing 500

322232 En velope Manufacturing 500

322233 Stationery, Tablet, and Related Product Manufacturing 500

322291 Sanitary Paper Product Manufacturing 500

322299 All Other Converted Paper Product Manufacturing 500

Source: U. S. Small Business Administration Table of Small Business Size Standards Matched to North American Industry Classification System Codes, Effective August 22, 2008. Accessed June 16, 2009 at: http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf

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### 31 PART I

- ATTACHMENT 3

Part I E missions Test Data Request

(Note: Test Reports submitted should be full and complete copies of the emission test reports, to include field and lab data sheets and example calculations

. )

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### 32 Part I

- Attachment 3 . Pulp and P aper E mission U nits and P o llutants for Which E xisting R epresentative E mission T est D ata A re R equested
Note: Emissions test data representative of your current operations are requested as described in the survey instructions. Mills required to complete Part III may postpone until t he deadline for Part III submittal of emissions test data and CEMS data required for the emission units listed in Part I Attachment 1 for the following pollutants: PM, PM 2.5 , TRS, NOx, SO2, and CO.

Emission Unit Particulate matter (PM) 1 Speciated HAP

meta ls 2 PM 2.5 (fil.) PM 2.5 (cond.) Chlorinated HAP (Cl) 1 Acetaldehyde, Formaldehyde,

and Methanol 1 Total hydrocarbon

(THC) as

carbon Total reduced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 1 Carbon

monoxide

(CO) 1

Test methods 4 M5, M29,

M1 7

PM CEMS,

COMS M29 EPA

OTM 27 EPA

OTM 28 Chlorine (Cl 2 ) via

M26A with

modifications

described in

subpart S

Cl 2 CEMS Methanol: Method 308 (part 63) or

Methanol CEMS

Other methods (e.g., for acetaldehyde & formaldehyde) M25 or M25A M16 (or variants

s uch as 16A, 16B, 16C) or TRS CEMS

Provide total

TRS data. Also provide speciated TRS data, if

available. M7 ( or variants

such as 7E)

CEMS M6 (or variants such as 6C)

CEMS M10

CEMS

Thermal oxidizers controlling Part I

emission sources Supply most

rec ent data Not requested Supply

most recent
data Digesters, Pulp washers, Evaporators, Turpentine recovery, Strippers, O 2 delignification,

Knotters and screens, Deckers

(high density storage), and Weak and strong liquor storage tanks (or

their associ ated

LVHC and/or HVLC

collection systems) Not requested Supply most recent data following MACT compliance Supply most

recent data following

MACT compliance Not requested

Sulfite pulping

sources Not requested Supply most recent data following

MA CT compliance Supply most

recent data Not requested

### Part I Form Approved 02/17/2011

OMB Control No. 2060

- 0656 Approval Expires 02 / 28 / 2014



### 33 Emission Unit Particulate matter (PM) 1 Speciated HAP

meta ls 2 PM 2.5 (fil.) PM 2.5 (cond.) Chlorinated HAP (Cl) 1 Acetaldehyde, Formaldehyde,

and Methanol 1 Total hydrocarbon

(THC) as

carbon Total reduced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 1 Carbon

monoxide

(CO) 1

Wastewater

t reatment s ystems Not requested Supply most recent modeling or

measurement data

(as requested in

WW tab) Supply most recent modeling

or measurement data (as requested in

WW tab) Not

r equested

Bleaching systems subject to subpart S Not requested Supply most

recent data following MACT compliance Supply most

recent data following

MACT compliance Paper machine emission points Not requested Supply most recent

data

Cau sticizing area

sources Not requested Supply most

recent data

Stand alone semichemical,

m echanical

, nonwood, and secondary fiber pulping Not requested Supply most

recent data

1 If your emission unit is equipped with a continuous emission s monitoring system (CEMS) or continuous opacity monitoring system (COMS), supply the CEMS and COMS data using the CEMS data spreadsheet ( P&P CEMS_PI.xls ) . Synthetic area sources should supply the most recent data (if data are available).

2 The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chr omium VI (Cr +6 ) and speciated mercury (Hg) test data if

available.

3 Speciated TRS would include: hydrogen sulfide (H 2 S), methyl mercaptan, dimethyl sulfide, and dimethyl disulfide.

4 M = method (e.g., M5 is EPA Method 5). EPA Methods 5, 6, 7, 10, 16, 17, 23, 25/25A, 26/26A appear in 40 CFR Part 60, Appendix A. EPA Method 308 appears in Part 63, Appendix A. The “ OTM ” test

methods can be found at http://www.epa.gov/ttn/emc/prelim.html