Date: May 8, 2012

Subject: Recommendations Concerning Residual Risk Remodeling for the Pulp and 

Paper Industry

EPA Contract No. EP-D-11-084; Work Assignment No. 0-03

From: Thomas Holloway

To: John Bradfield, Bill Schrock, Kelley Spence, and Nick Swanson

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

I. Background

Under section 112(f)(2) of the Clean Air Act (CAA), the U.S. Environmental Protection 

Agency (EPA) is directed to conduct risk assessments on each source category subject to 

maximum achievable control technology (MACT) standards and determine if additional or more 

stringent standards beyond those originally promulgated are needed to reduce any residual risk 

remaining after promulgation. The EPA is directed to conduct the section 112(f)(2) residual risk 

review 8 years after promulgation of the original standards. The national emissions standards for 

hazardous air pollutants (NESHAP) for the pulp and paper industry (40 CFR part 63, subpart S) 

were originally promulgated on April 15, 1998. Subpart S amendments that addressed the 

residual risk assessment required for the pulp and paper industry were proposed in the Federal 

Register on December 27, 2011. Final amendments to subpart S are required to be signed by the 

EPA Administrator by July 31, 2012.

Data from a CAA section 114 information collection request (ICR) sent to the pulp and 

paper industry were used for the residual risk assessment. The second part of the ICR (Part II), 

which concluded in June 2011, was targeted towards facilities that are major sources of 

hazardous air pollutant (HAP) emissions, and involved an update of pre-populated National 

Emissions Inventory (NEI) data spreadsheets (or creation of new NEI data sets). The response 

rate for Part II of EPA’s ICR was 100 percent, with respondents submitting NEI spreadsheets for 

171 major sources.

Substantial quality assurance (QA) efforts were conducted on the Part II data in order to 

create the modeling files needed for the residual risk assessment. Modeling files were needed for 

both the subpart S category (MACT code 1626-1) and the whole facility, so QA efforts focused 

on data for all emission sources at pulp and paper facilities. The QA of the inputs to the residual 

risk modeling file was documented in a November 11, 2011 memorandum entitled, Inputs to the 

Pulp and Paper Industry October 2011 Residual Risk Modeling.

1

Using these modeling files, EPA conducted risk assessments that provided estimates of 

the following:
2

 The maximum individual risk (MIR) posed by the HAP emissions from the 171 pulp and 

paper mills in the source category, where MIR is defined as the risk associated with a 

lifetime of exposure at the highest concentration;

 The distribution of cancer and noncancer risks within the exposed populations;

 The total cancer incidence;

 Estimates of the maximum target organ-specific hazard index (TOSHI) for chronic 

exposures to HAP with the potential to cause chronic noncancer health effects;

 Worst-case screening estimates of hazard quotient (HQ) for acute exposures to HAP with 

the potential to cause noncancer health effects; and

 An evaluation of the potential for adverse environmental effects.

The results of these risk assessments were presented in a December 2011 EPA document 

entitled, Draft Residual Risk Assessment for the Pulp & Paper Source Category.

2

II. Objective

In the preamble to the December 27, 2011 subpart S proposal, EPA proposed that the 

risks from the pulp and paper source category are acceptable and concluded that the current 

subpart S rule protects public health with an ample margin of safety.

3

The EPA also solicited 

comment on the proposal, asking for any additional data that may help to reduce the uncertainties 

inherent in the risk assessments and other analyses.

4

The EPA was specifically interested in 

receiving corrections to the mill-specific HAP emissions data used in the risk modeling, but also 

accepted revisions to mill-specific non-HAP emissions data, including revised data for criteria 

air pollutants (CAP) and total reduced sulfur (TRS).

The mill-specific NEI emissions data were available for download on EPA’s Risk and 

Technology Review (RTR) web page at: http://www.epa.gov/ttn/atw/rrisk/rtrpg.html; the NEI 

data files included detailed information for each HAP emissions release point for each facility 

included in the subpart S source category.

4

Commenters on the subpart S proposal (e.g., industry, states) were asked to determine 

whether any of the NEI data were unrepresentative or inaccurate and to submit their comments 

on the data downloaded from the RTR web page.

4

 Specifically, commenters were asked to enter 

suggested revisions to the NEI data fields appropriate for that information, gather documentation 

for any suggested emissions revisions (e.g., performance test reports, material balance 

calculations), and send the downloaded file with suggested revisions and all accompanying 

documentation to the docket for the subpart S amendments (Docket ID No. EPA–HQ–OAR–

2007–0544).4 The NEI data fields that could be revised included those listed in Table 1 at the 

end of this memorandum.

4

The objective of this memorandum is to document the review of the NEI data revisions 

received from the pulp and paper industry, evaluate which revisions could increase or decrease 

the risk associated with a particular facility, and recommend whether risk remodeling for the 

subpart S category should be conducted for any of the facilities based on these findings.

III. Review of NEI Data Revisions

An estimated 81 facilities provided NEI data revisions, out of 171 major source facilities

in the source category, for a response rate of nearly 50 percent, and 53 of 67 facilities with 
3

cancer risk greater than 1 in a million provided NEI revisions, for a response rate of nearly 80

percent. Most NEI data revisions were received after proposal, but there were some late NEI 

data revisions received prior to proposal that were not incorporated into the pre-proposal risk 

modeling file, which we have now included with the post-proposal revisions.

The facilities made a variety of revisions to their NEI data, including, but not limited to:

 Deleting emission units (e.g., shutdown units, units with emissions collected and emitted 

elsewhere, causticizing systems using fresh water/no pulping condensates, units

consolidated elsewhere in the inventory, fugitive sources changed to stack sources, paper 

machines reconfigured from a single emission point to wet/dry end emission points or 

multiple vents);

 Replacing emission units (e.g., consolidated units, stack sources changed from fugitive

sources, reconfigured paper machines);

 Adding emission units omitted from previous inventory (e.g., wastewater treatment 

plant);

 Deleting individual records (e.g., duplicates, zero emissions);

 Correcting source classification codes (SCCs);

 Changing release point IDs;

 Correcting release point type from fugitive to stack;

 Deleting pollutants (e.g., hexachloroethane [HCE] from washers/bleach plants, 

chlorinated compounds at unbleached mills, biphenyl from recycle paper machines, oxylene double-counted with total xylenes, o-cresol double-counted with total cresols);

 Adding pollutants omitted from previous inventory;

 Revising routine annual emissions data (e.g., based on updated emission factors/test data, 

corrected emissions calculations);

 Deleting/replacing routine annual emissions data with updated/corrected data;

 Revising maximum hourly emissions data;

 Revising MACT code;

 Providing stack parameters for newly designated stack sources;

 Correcting stack parameters;

 Replacing incorrect fugitive parameters; and

 Correcting latitudes/longitudes.

A. QA of NEI Data Revision Spreadsheets

The first step in our review was to QA the aforementioned changes in the individual NEI

data revision spreadsheets received from the pulp and paper industry. Table 2 at the end of this 

memorandum lists the NEI data fields we reviewed in each spreadsheet and provides some 

examples of the type of review we conducted. The risk inputs memo1 was used as a guide to 

ensure that the changes commenters made were consistent with prior modeling inputs.

We added an “RTI Notes” column at the end of each facility’s NEI data revisions 

spreadsheet that (1) noted our recommendations regarding the facility’s suggested NEI data 

revisions and rationale (e.g., OK to add/delete/revise record to correct error, update data, replace

data); and (2) noted our own revisions (e.g., adding default stack parameters, calculating flow 

rates, correcting errors, filling data gaps, adding data from facilities’ previous inventory updates). 
4

Where we made revisions, we highlighted those spreadsheet cells in yellow to distinguish them 

from the revisions made by the facilities.

B. Completion of Review Checklists

After we had completed our QA of each facility’s NEI data revisions spreadsheet, we 

filled out a review checklist for each facility that documented whether the NEI data revisions 

could be expected to increase or decrease the risk for that facility, to assist in developing our 

recommendations whether to remodel for risk for the subpart S category. See Appendix A for a 

blank copy of the NEI data revisions review checklist that was used. The review checklist 

includes the following items:

 Risk results from EPA’s December 2011 risk report for each facility for the subpart S 

category and facility-wide, including chronic cancer MIR, chronic non-cancer maximum 

hazard index (HI), and acute non-cancer HQ reference exposure level (REL);

2

for each 

facility, we included only those HQ(REL) values above 0.1, unless the highest HQ(REL) 

for the facility was below 0.1, in which case we included the highest HQ(REL) value for 

that facility;

 Facility information, including mill name, city, state, NEI ID, RTI facility ID;

 Format of the NEI data revision provided by the facility, including whether the revision 

was provided as a spreadsheet or written comment, whether the revision was submitted 

before proposal, and whether the revision was a resubmittal of a prior inventory;

 Table of changes that may increase risk for subpart S pulp and paper production sources 

(MACT code 1626-1), subpart MM chemical recovery sources (MACT code 1626-2), 

and facility-wide sources, including:

o Reductions in stack/fugitive release height, fugitive area (length x width), stack 

temperature, exit gas velocity, and/or exit gas flow rate;

o Additions or increases in emissions of key risk driver pollutants and other HAP;

o Addition of emission units; and

o Change in release point type from stack to fugitive or from vertical to 

horizontal/gooseneck/etc.;

 Table of changes likely to reduce risk for the same aforementioned sources, including 

(conversely):

o Increases in stack/fugitive release height, fugitive area (length x width), stack 

temperature, exit gas velocity, and/or exit gas flow rate;

o Deletions or reductions in emissions of key risk driver pollutants and other HAP;

o Deletion of emission units; and

o Change in release point type from fugitive to stack or from horizontal/gooseneck/

etc. to vertical;

 Table of changes with an unknown effect on risk on the aforementioned sources, 

including:

o Changes in latitude and longitude;

o Changes in fugitive angle; and
5

o Other changes listed on a site-specific basis (e.g., change in stack diameter, 

receptor location);

 List of other types of changes, including mill names, IDs, codes, descriptions; and

 Any other notes from RTI pertinent to the review.

We checked off each box in the review checklist that applied and also provided some 

additional information to assist in our later recommendations concerning risk remodeling for the 

subpart S category. Specifically, we listed on the checklist any of the key HAP risk driver 

pollutants whose emissions were increased, reduced, or deleted in the NEI data revision

spreadsheets. Based on our review of the risk results, we considered the key HAP risk driver 

pollutants to be acetaldehyde, formaldehyde, HCE, naphthalene, chloroform, methanol, and 

metals. We also listed on the checklist the emission units from which the relevant pollutants were 

emitted. In addition, we listed on the checklist any emission units that were added or deleted 

from the spreadsheets and their associated risk driver pollutants. We also calculated the HAP 

emissions reductions/increases associated with the aforementioned changes and then calculated 

the net change in facility HAP emissions for subpart S sources, subpart MM sources, and 

facility-wide, as applicable.

C. Risk Remodeling Recommendations

To facilitate our development of recommendations concerning residual risk remodeling 

for the subpart S processes at each facility, we consolidated the information from the review 

checklists for the 81 facilities that submitted NEI data revisions into a single summary

spreadsheet, provided as Appendix B at the end of this memorandum. We added the following 

additional columns to the spreadsheet to help us in our recommendations:

 Two columns including information summarized by the pulp and paper industry’s 

consultant AECOM, listing the risk drivers for facilities with chronic cancer risk over 2 

in a million, specifically the pollutants considered risk drivers (e.g., acetaldehyde, 

formaldehyde) and the sources from which the pollutants are emitted (e.g., wastewater, 

papermaking, pulping);5

 One column noting whether facilities submitted comments about incorrect receptor

locations at their facilities;

 One column providing our recommendations about whether to remodel risk for subpart S 

processes at each facility (Yes, No, Maybe) and one column listing the reasons why or 

why not;

 One column providing the baseline HAP emissions in tons per year (tpy) for subpart S

processes for each facility from the NEI data files on the RTR web page;

 One column providing the estimated net change in HAP emissions in tpy relative to 

baseline for subpart S processes for each facility that can be used to support our 

recommendations concerning remodeling of risk for subpart S processes; and

 One column providing the estimated percent change in HAP emissions relative to 

baseline for subpart S processes for each facility that can also be used to support our 

recommendations concerning remodeling of risk for subpart S processes.
6

Where facilities made the types of NEI data revisions that could reduce risk, we 

attempted to link those changes to the chronic cancer risk driver information from AECOM5and 

the acute non-cancer risk information from EPA’s December 2011 risk report2by highlighting 

the relevant cells in yellow, to directly show where the NEI data revisions are expected to reduce 

risk.

After populating the summary spreadsheet with the aforementioned information from the 

review checklists, AECOM, and EPA risk report, we sorted the spreadsheet by chronic cancer 

risk, from highest to lowest. Then, for each facility that submitted NEI data revisions, we made 

recommendations whether to remodel risk for subpart S processes based on (1) the level of 

chronic cancer and acute non-cancer risk from subpart S processes at the facility, reported in the 

EPA risk report2; (2) the NEI data revisions that were made; and (3) the net change in HAP 

emissions for subpart S processes. The development of our recommendations did not include

chronic non-cancer risk, since it was low—below a HI of 1—for all facilities. Table 3 at the end 

of this memorandum presents our facility-specific recommendations whether to remodel risk for 

subpart S processes. Our recommendations were premised on EPA’s finding in the December 

27, 2011 subpart S proposed amendments that the risks from the pulp and paper source category, 

as modeled prior to proposal, are acceptable.3Therefore, as long as the risk for subpart S 

processes at an individual facility is not expected to be substantially increased as a result of the 

facility’s NEI data revisions, we do not recommend remodeling risk for the subpart S processes 

at that facility.

Specifically, for facilities with chronic cancer MIR values above 1 in a million and acute 

non-cancer HQ(REL) values above 1, we recommend no risk remodeling of subpart S processes 

if the facilities provided NEI data revisions that would be expected to either reduce risk or result 

in no significant change to risk for subpart S processes. It follows that any facilities with lower 

MIR or HQ(REL) values is also not recommended for risk remodeling.

Only three facilities’ NEI data revisions increased the overall HAP emissions from their

subpart S processes. The net HAP emissions increase for subpart S processes at two of the 

facilities was minimal (approximately 3 tpy at each facility), so any increase in risk was expected 

to be minor. While the net HAP emissions increase for subpart S processes at the third facility

was substantial (a twofold increase of 308 tpy), 98 percent of the added HAP emissions can be 

attributed to methanol; less than 6 tons of HAP emissions can be attributed to the other risk 

driver pollutants (e.g., acetaldehyde, formaldehyde). The chronic cancer MIR values for subpart 

S processes at all three facilities were at or below 1 in a million, and the highest acute non-cancer 

HQ(REL) values for subpart S processes at all three facilities were below 1, so any increase in

risk for these three facilities is not expected to result in a high risk result. Therefore, we do not 

recommend risk remodeling for subpart S processes at these three facilities.

A fourth facility, which consists of three plants—a pulp mill, paper mill, and water 

quality center, each with its own NEI ID—had a minimal HAP emissions increase for its pulp 

mill, but the HAP emissions reductions at the water quality center at the facility far exceeded this 

small emissions increase; there were no NEI data revisions for the paper mill. Based on these 

findings, we do not recommend risk remodeling for the subpart S processes at this facility. Note: 

For facilities that did not provide NEI data revisions, we also do not recommend risk remodeling
7

for subpart S processes because there are no new data that would alter the risks modeled prior to 

proposal.

Nine facilities provided stack or fugitive parameter revisions that could potentially

increase risk for the subpart S category. However, these changes were (1) countered by other 

changes that could potentially reduce risk (e.g., additional stack/fugitive parameter changes, 

HAP emissions reductions, changes to release point type or equipment configuration) or (2) were 

not expected to have a significant effect because the risk estimates for the facilities were very

low (i.e., chronic cancer MIR below 1 in a million and highest acute non-cancer HQ(REL) 

below 1) and because there was no increase in HAP risk driver emissions for the subpart S

processes at these facilities. Therefore, we also do not recommend risk remodeling for the 

subpart S processes at these facilities.

In summary, based on EPA’s current cancer and non-cancer risk estimates for the pulp 

and paper industry and our review of the NEI data revisions received from the industry, we do 

not recommend risk remodeling for the subpart S category for any of the major source facilities 

in this industry.

IV. References

1. Memorandum from Thomas Holloway, Katie Hanks, Corey Gooden, and Matt Hakos, 

RTI, to J. Bradfield and B. Schrock, EPA. Inputs to the Pulp and Paper Industry 

October 2011 Residual Risk Modeling. November 11, 2011.

2. U.S. Environmental Protection Agency. Draft Residual Risk Assessment for the Pulp &

Paper Source Category. December 2011.

3. U.S. Environmental Protection Agency. National Emission Standards for Hazardous Air 

Pollutants from the Pulp and Paper Industry, Proposed Rule. 76 FR 81344. December 

27, 2011.

4. U.S. Environmental Protection Agency. National Emission Standards for Hazardous Air 

Pollutants from the Pulp and Paper Industry, Proposed Rule. 76 FR 81349-51. 

December 27, 2011.

5. Comment submitted by Paul Noe, Vice President for Public Policy, American Forest and 

Paper Association (AF&PA). RE: Docket ID No. EPA–HQ–OAR–2007-0544, National 

Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry (76 

Federal Register 81328, December 27, 2011). Attachment 1: Review of the HEM3 

Modeling Conducted by EPA for the Pulp & Paper Industry RTR by David Heinold, 

AECOM (February 2012), Table 2. February 27, 2012.
8

Table 1. NEI Data Fields for Revision

Data element Definition

Control Measure Are control measures in place? (yes or no).

Control Measure Comment Select control measure from list provided, and briefly describe the control 

measure.

Delete Indicate here if the facility or record should be deleted.

Delete Comment Describes the reason for deletion.

Emissions Calculation Method 

Code For Revised Emissions

Code description of the method used to derive emissions. For example, 

CEMS, material balance, stack test, etc.

Emissions Process Group Enter the general type of emissions process associated with the specified 

emissions point.

Fugitive Angle Enter release angle (clockwise from true North); orientation of the ydimension relative to true North, measured positive for clockwise starting at 0 

degrees (maximum 89 degrees).

Fugitive Length Enter dimension of the source in the east-west (x-) direction, commonly 

referred to as length (ft).

Fugitive Width Enter dimension of the source in the north-south (y-) direction, commonly 

referred to as width (ft).

Malfunction Emissions Enter total annual emissions due to malfunctions (tpy).

North American Datum Enter datum for latitude/longitude coordinates (NAD27 or NAD83); if left 

blank, NAD83 is assumed.

Process Comment Enter general comments about process sources of emissions.

REVISED Address Enter revised physical street address for MACT facility here.

REVISED City Enter revised city name here.

REVISED County Name Enter revised county name here.

REVISED Emissions Release Point 

Type

Enter revised Emissions Release Point Type here.

REVISED End Date Enter revised End Date here.

REVISED Exit Gas Flow Rate Enter revised Exit Gas Flowrate here (ft3/sec).

REVISED Exit Gas Temperature Enter revised Exit Gas Temperature here (°F).

REVISED Exit Gas Velocity Enter revised Exit Gas Velocity here (ft/sec).

REVISED Facility Category Code Enter revised Facility Category Code here, which indicates whether facility is 

a major or area source.

REVISED Facility Name Enter revised Facility Name here.

REVISED Facility Registry 

Identifier

Enter revised Facility Registry Identifier here, which is an ID assigned by the 

EPA Facility Registry System.

REVISED HAP Emissions 

Performance Level Code

Enter revised HAP Emissions Performance Level here.

REVISED Latitude Enter revised Latitude here (decimal degrees).

REVISED Longitude Enter revised Longitude here (decimal degrees).

REVISED MACT Code Enter revised MACT Code here.

REVISED Pollutant Code Enter revised Pollutant Code here.

REVISED Routine Emissions Enter revised routine emissions value here (tpy).

REVISED SCC Code Enter revised SCC Code here.

REVISED Stack Diameter Enter revised Stack Diameter here (ft).

REVISED Stack Height Enter revised Stack Height here (ft).

REVISED Start Date Enter revised Start Date here.

REVISED State Enter revised State here.

REVISED Tribal Code Enter revised Tribal Code here.

REVISED Zip Code Enter revised Zip Code here.

Shutdown Emissions Enter total annual emissions due to shutdown events (tpy).

Stack Comment Enter general comments about emissions release points.

Startup Emissions Enter total annual emissions due to startup events (tpy).

Year Closed Enter date facility stopped operations.
9

Table 2. NEI Data Fields Revieweda

Data field Example review

SCC Code Determined whether SCC code change was valid, based on type of pulping process 

and emission unit description in risk modeling file.

Emission Release Point ID Determined whether revisions of release point ID could result in duplicate records.

Emission Release Point 

Type

Determined whether revision of release point type was valid, based on stack 

parameters provided by facility (e.g., release point changed from fugitive to stack, but 

the stack diameter was greater than the stack height).

Pollutant Code Generally accepted facilities’ pollutant codes, pending review of a compilation of NEI 

data revisions for all 81 facilities reporting.b Checked for any data gaps. Determined 

whether the deletion of a pollutant was valid (e.g., facility wanted to delete pollutant 

that is not emitted, but the original pollutant code was incorrect, resulting in the 

incorrect pollutant being assigned; so, a change in pollutant code and pollutant fixed 

the problem).

Routine Emissions Generally accepted facilities’ rationale and revisions of emissions data, pending 

review of a compilation of NEI data revisions for all 81 facilities reporting.b When 

facilities assigned a value of zero to emissions but did not mark the record for 

deletion, we made a note in the spreadsheet that the record should be deleted. Also,

for one facility, we included emissions data from their pre-proposal inventory 

revisions that were not included in any post-proposal revisions.

Max Hourly Emissions Generally accepted the few facilities’ rationale and revisions of maximum hourly 

emissions data.

MACT Code Determined whether the revised MACT code corresponded to the type of emission 

unit identified by SCC code (e.g., lime kiln should be assigned to 1626-2).

Stack Height Reviewed revised stack height values provided by industry to ensure that stack height 

was always greater than stack diameter for stack emission points. Added 

SCC/MACT code default stack heights when facilities changed release point type 

from fugitive to stack but did not revise nationwide default stack height of 10 feet.

Exit Gas Temperature Added SCC/MACT code default exit gas temperature values when facilities changed 

release point type from fugitive to stack but did not revise nationwide default exit gas 

temperature of 72°F.

Stack Diameter Added SCC/MACT code default stack diameter values when facilities changed 

release point type from fugitive to stack but did not revise nationwide default stack 

diameter of 0.003 feet.

Exit Gas Velocity Added SCC/MACT code default stack diameter values when facilities changed 

release point type from fugitive to stack but did not revise nationwide default exit gas 

velocity of 0.0003 feet per second. Where there were revised values for stack 

diameter and flow rate (e.g., from facility and/or SCC/MACT code defaults), 

calculated velocity as “flow rate/(π × (diameter/2)2].”

Exit Gas Flow Rate Added SCC/MACT code default exit gas flow rate values when facilities changed 

release point type from fugitive to stack but did not revise nationwide default stack 

diameter, exit gas velocity, and exit gas flow rate from their respective national 

default values. Where there were revised values for stack diameter and exit gas 

velocity (e.g., from facility and/or SCC/MACT code defaults), calculated exit gas 

flow rate as “velocity × π × (diameter/2)2.”

Fugitive Length Reviewed fugitive length values to determine whether any revisions were made 

relative to the risk modeling file (e.g., to correct error). Deleted fugitive length values 

when facility changed release point type from fugitive to stack.

Fugitive Width Reviewed fugitive width values to determine whether any revisions were made 

relative to the risk modeling file (e.g., to correct error). Deleted fugitive width values 

when facility changed release point type from fugitive to stack.

Fugitive Angle Reviewed fugitive angle values to determine whether any revisions were made 

relative to the risk modeling file (e.g., to correct error). Deleted fugitive angle values 

when facility changed release point type from fugitive to stack.

Latitude Generally accepted facilities’ revision of latitude (e.g., to correct error), pending a 
10

Data field Example review

more in-depth review similar to the QA conducted pre-proposal.

Longitude Generally accepted facilities’ revision of longitude (e.g., to correct error), pending a 

more in-depth review similar to the QA conducted pre-proposal.

a

For new/replacement records added by facilities, we checked the accuracy of all fields in the table.

b

Pollutant codes and emission rates will be rechecked for consistency across all facilities upon compilation of the 

revised nationwide NEI file.
11

Table 3. Recommendations Concerning Risk Remodeling

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

NEI32869A Domtar Paper 

Company LLC

Hawesville KY 1.21E-05 0.17 <1 No Emissions reduction/removal of risk 

driver pollutants from multiple 

sources expected to reduce risk for 

subpart S category

NEI18334 GeorgiaPacific Corp.Pennington AL 1.04E-05 0.20 5.67 

(formaldehyde)

4.91 (methanol)

4.66 

(acetaldehyde)

2.91 (chloroform)

No Changes in release point type and 

stack parameters, removal of some 

emission units, and net emissions 

reduction/removal of risk driver/other 

pollutants expected to reduce risk for 

subpart S category

NEI40648 SP Newsprint 

Co.

Newberg OR 9.01E-06 0.44 3.17 (chloroform) No No NEI revisions received

NEI40282 Blue Ridge 

Paper Products 

Inc.

Canton NC 8.98E-06 0.29 <1 No Net emissions reduction/removal of 

risk driver/other pollutants expected 

to reduce risk for subpart S category

NEIWI7720116, 

NEI46739, & 

NEI42963

NewPage 

Corporation

Wisconsin 

Rapids

WI NEIWI7720116:

8.51E-06

NEI46739:

4.00E-07

NEI42963:

1.56E-07

NEIWI7720116:

0.41

NEI46739:

0.05

NEI42963:

0.00

NEIWI7720116:

4.29 

(acetaldehyde)

3.43 (methanol)

3.12 (chloroform)

1.38 

(formaldehyde)

No Net emissions reduction/removal of 

risk driver/other pollutants for entire 

facility expected to reduce risk for 

subpart S category; large emissions 

reduction for higher-risk 

NEIWI7720116; minimal net 

emissions increase in emissions for 

low-risk NEI46739

NEIME0250002 Madison Paper 

Co.

Madison ME 7.58E-06 0.31 1.57 

(acetaldehyde)

1.32 

(formaldehyde)

No Changes in release point type and 

stack parameters and net emissions 

reduction of risk driver/other 

pollutants expected to reduce risk for 

subpart S category

NEI42695 Domtar 

Corporation

Nekoosa WI 7.42E-06 0.29 <1 No Removal of some risk driver 

pollutants expected to reduce risk for 

subpart S category

NEI41552 Packaging 

Corp. of 

America

Counce TN 7.14E-06 0.36 2.12 

(acetaldehyde)

No Changes in release point type and 

stack parameters, removal of risk 

driver pollutant from one source, and 

net emissions reduction of risk driver 
12

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

pollutant expected to reduce risk for 

subpart S category

NEI6057 Graphic 

Packaging 

International, 

Inc.

West Monroe LA 5.27E-06 0.22 <1 No No NEI revisions received

NEI47091 Buckeye 

Technologies 

Inc.

Perry FL 5.22E-06 0.16 1.68 (chloroform) No Removal of risk driver pollutant from 

multiple sources expected to reduce 

risk for subpart S category

NEI40600 GeorgiaPacific Corp.Toledo OR 4.94E-06 0.15 <1 No Replacement of fugitive records with 

stack records and emissions reduction 

of risk driver/other pollutants 

expected to reduce risk for subpart S 

category

NEI46835 Woodland 

Pulp LLC

Baileyville ME 4.86E-06 0.20 15.2 

(acetaldehyde)

1.40 (chloroform)

No No NEI revisions received

NEI43207 Appleton 

Coated L.L.C.

Combined 

Locks

WI 4.32E-06 0.22 <1 No No NEI revisions received

NEI13363 Simpson 

Tacoma Kraft 

Co

Tacoma WA 4.30E-06 0.07 4.62 

(formaldehyde)

No Emissions reduction of risk driver 

pollutants expected to reduce risk for 

subpart S category

NEI41314 International 

Paper Co.

Georgetown SC 4.25E-06 0.16 <1 No Removal of some emission units and 

risk driver/other pollutants from 

multiple sources expected to reduce 

risk for subpart S category

NEI42211 GeorgiaPacific Corp.Big Island VA 4.25E-06 0.20 1.29 

(acetaldehyde)

No No revisions except minor changes to 

lat/longs and fugitive angles, so risk 

for subpart S category expected to be 

unchanged

NEI7104 Appleton Roaring 

Spring

PA 4.09E-06 0.07 <1 No Changes to stack heights expected to 

reduce risk for subpart S category

NEI40686 Domtar 

Corporation

Johnsonburg PA 3.85E-06 0.07 <1 No Removal of some risk driver/other 

pollutants from multiple sources 

expected to reduce risk for subpart S 
13

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

category

NEI33135 & 

NEI706

NewPage 

Corporation

Luke MD NEI33135:

3.77E-06

NEI706:

4.65E-07

NEI33135:

0.14

NEI706:

0.01

<1 No Changes in release point type and 

stack parameters, removal of 

emission unit, and emissions 

reduction of risk driver pollutant 

expected to reduce risk for subpart S 

category

NEI41599 Domtar Paper 

Company LLC

Kingsport TN 3.62E-06 0.14 1.09 

(acetaldehyde)

No Net emissions reduction/removal of 

risk driver/other pollutants from 

multiple sources expected to reduce 

risk for subpart S category

NEI8178 GeorgiaPacific Corp.Rincon GA 3.34E-06 0.06 <1 No Net emissions reduction/removal of 

risk driver/other pollutants from 

multiple sources expected to reduce 

risk for subpart S category

NEI8196 GeorgiaPacific Corp.Brunswick GA 3.27E-06 0.14 1.98 

(acetaldehyde)

No Change in release point type and 

stack parameters and emissions 

reduction of risk driver/other 

pollutants expected to reduce risk for 

subpart S category

NEI6450 MeadWestvacoEvadale TX 3.25E-06 0.09 1.20 

(acetaldehyde)

1.03 (chloroform)

No Change in fugitive parameters and 

net emissions reduction of risk driver 

pollutants expected to reduce risk for 

subpart S category

NEI26495 TIN Inc., dba 

Temple-Inland

Rome GA 3.18E-06 0.09 <1 No No revisions except suggested change 

in receptor location, so risk for 

subpart S category expected to be 

unchanged

NEI42357 Port Townsend 

Paper Corp.

Port 

Townsend

WA 3.10E-06 0.18 <1 No Change in release temperature and 

emissions reduction of risk driver 

pollutant expected to reduce risk for 

subpart S category

NEI18660 Domtar 

Industries

Ashdown AR 3.04E-06 0.08 <1 No Emissions reduction/removal of risk 

driver pollutants from multiple 

sources expected to reduce risk for 
14

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

subpart S category

NEIIL0215971 Ahlstrom 

Filtration LLC

Taylorville IL 3.00E-06 0.15 <1 No No NEI revisions received

NEI45182 International 

Paper Co.

Springfield OR 2.80E-06 0.05 <1 No Emissions reduction of risk 

driver/other pollutants expected to 

reduce risk for subpart S category

NEI47104 KapStone Roanoke 

Rapids

NC 2.73E-06 0.12 9.32 

(acetaldehyde)

1.48 

(formaldehyde)

No Changes in release point type and 

stack parameters expected to reduce 

risk for subpart S category

NEI12407 Verso Paper 

Corp.

Sartell MN 2.72E-06 0.09 <1 No Removal of emission unit expected to 

reduce risk for subpart S category

NEI40247 International 

Paper Co.

Riegelwood NC 2.69E-06 0.09 <1 No Removal of some emission units and 

emissions reduction/removal of risk 

driver/other pollutants expected to 

reduce risk for subpart S category

NEI759 MeadWestvaco Covington VA 2.62E-06 0.08 <1 No Removal of risk driver pollutant

expected to reduce risk for subpart S 

category

NEI8560 International 

Paper Co.

Prattville AL 2.58E-06 0.10 <1 No Removal of some emission units 

expected to reduce risk for subpart S 

category

NEI42482 GeorgiaPacific Corp.Green Bay WI 2.46E-06 0.03 <1 No Net emissions reduction of risk driver 

pollutant expected to reduce risk for 

subpart S category

NEIVA00022 Greif Inc. Amherst VA 2.32E-06 0.10 <1 No No NEI revisions received

NEI34030 UPM, Blandin 

Paper Co.

Grand Rapids MN 2.30E-06 0.04 <1 No Change in paper machine 

configuration (to include wet/dry 

end) and change in stack parameter 

expected to reduce risk for subpart S 

category

NEI8278 Rock-Tenn Co. Panama City FL 2.28E-06 0.07 <1 No Changes in release point type and 

stack parameters and removal of risk 

driver/other pollutants from multiple 
15

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

sources expected to reduce risk for 

subpart S category

NEI11610 Rock-Tenn Co. Cincinnati OH 2.27E-06 0.05 <1 No Changes to release point type and 

parameters expected to reduce risk 

for subpart S category

NEI6261 Verso Paper 

Corp.

Jay ME 2.22E-06 0.12 <1 No Emissions reduction of HAP 

driver/other pollutants expected to 

reduce risk for subpart S category

NEI43472 Sonoco 

Products Co.

Hartsville SC 2.19E-06 0.11 1.32 

(acetaldehyde)

No No NEI revisions received

NEI33883 NewPage 

Corporation

Escanaba MI 2.04E-06 0.12 <1 No Emissions reduction of HAP driver 

pollutants expected to reduce risk for 

subpart S category

NEI8186 International 

Paper Co.

Savannah GA 2.00E-06 0.03 1.57 

(formaldehyde))

No Removal of some emission units and 

dmissions reduction of HAP driver 

pollutants expected to reduce risk for 

subpart S category

NEI26476 Weyerhaeuser 

Co.

Port 

Wentworth

GA 1.91E-06 0.10 1.09 

(acetaldehyde)

No No NEI revisions received

NEI41565 AbitibiBowater 

Inc.

Calhoun TN 1.89E-06 0.13 1.27 (chloroform) No No NEI revisions received

NEI40738 Proctor & 

Gamble Paper 

Products Co.

Mehoopany PA 1.86E-06 0.06 <1 No Removal of some risk driver 

pollutants expected to reduce risk for 

subpart S category

NEI11251 International 

Paper Co.

Valliant OK 1.84E-06 0.06 <1 No Changes in stack/fugitive parameters 

and removal of some emission units 

expected to reduce risk for subpart S 

category

NEI11172 GeorgiaPacific Corp.Monticello MS 1.71E-06 0.06 <1 No Emissions reduction of risk driver 

pollutant expected to reduce risk for 

subpart S category

NEI54342 GeorgiaPacific Corp.Crossett AR 1.68E-06 0.06 <1 No Changes in release point type and 

stack parameters expected to reduce 

risk for subpart S category
16

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

NEI26581 Clearwater 

Paper Corp.

Lewiston ID 1.49E-06 0.03 <1 No Removal of risk driver pollutant 

expected to reduce risk for subpart S 

category

NEI34066 GeorgiaPacific Corp.New Augusta MS 1.44E-06 0.04 <1 No Change in fugitive parameters and 

removal of risk driver pollutant 

expected to reduce risk for subpart S 

category

NEI11367 Ahlstrom 

Filtration LLC

Madisonville KY 1.42E-06 0.16 2.07 

(formaldehyde)

1.18 (methanol)

No No NEI revisions received

NEI18658 Evergreen 

Packaging

Pine Bluff AR 1.39E-06 0.22 2.9 (chloroform) No Emissions reduction/removal of risk 

driver/other pollutants expected to 

reduce risk for subpart S category

NEI7181 Glatfelter Spring Grove PA 1.35E-06 0.05 <1 No Removal of risk driver pollutant from 

multiple sources expected to reduce 

risk for subpart S category

NEI34070 International 

Paper Co.

Redwood MS 1.32E-06 0.04 <1 No Change in paper machine 

configuration (to include wet/dry 

end) and stack parameters, removal 

of some emission units, and net 

emissions reduction expected to 

reduce risk for subpart S category

NEI13340 Pope & Talbot 

Inc.

Halsey OR 1.29E-06 0.14 4.67 

(formaldehyde)

2.57 

(acetaldehyde)

1.58 (methanol)

No No NEI revisions received

NEI26526 Rayonier Inc. Jesup GA 1.28E-06 0.13 <1 No No NEI revisions received

NEI54400 Domtar Paper 

Company LLC

Rothschild WI 1.18E-06 0.04 <1 No Emissions reduction of risk driver 

pollutants expected to reduce risk for 

subpart S category

NEI8265 GeorgiaPacific Corp.Palatka FL 1.16E-06 0.03 <1 No Removal of risk driver/other 

pollutants expected to reduce risk for 

subpart S category
17

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

NEI42341B North Pacific 

Paper Corp. 

(Norpac)

Longview WA 1.15E-06 0.03 <1 No No NEI revisions received

NEI33025 or 

NEW71411

International 

Paper Co.

Campti LA 1.10E-06 0.04 <1 No Removal of some emission units 

expected to reduce risk for subpart S 

category

NEI33023 Rock-Tenn Co. Hodge LA 1.10E-06 0.03 <1 No Change in release point type and 

stack parameters and net emissions 

reductions/removal of biphenyl, ocresol, chloroform, and other 

chlorinated HAPs expected to reduce 

risk for subpart S category

NEI46814 TIN Inc., dba 

Temple-Inland

Bogalusa LA 1.10E-06 0.03 <1 No No NEI revisions received

NEI6273 NewPage 

Corporation

Rumford ME 1.09E-06 0.04 <1 No Minimal net emissions increase for 

subpart S category, so any increase in 

risk for subpart S category expected 

to be minor; also, cancer MIR for 

subpart S category is ~1E-6, and noncancer HI and HQ(REL)<<1, so any 

increase in risk is not expected to 

result in a high risk result

NEI46599 GeorgiaPacific Corp.Camas WA 1.05E-06 0.03 <1 No Changes in release point type and 

stack parameters and emissions 

reductions of risk driver/other 

pollutants expected to reduce risk for 

subpart S category

NEI8619 International 

Paper Co.

Pine Hill AL 1.04E-06 0.04 <1 No Removal of some emission units 

expected to reduce risk for subpart S 

category

NEI42254 Rock-Tenn Co. West Point VA 1.02E-06 0.05 <1 No Changes in release point type and 

stack parameters and removal of 

biphenyl, o-cresol, and o-xylene from 

multiple sources expected to reduce 

risk for subpart S category
18

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

NEI47074 Domtar Paper 

Company LLC

Bennettsville SC 1.02E-06 0.03 <1 No Changes in release point type and 

stack parameters and replacement of 

fugitive records with lower-emitting 

stack records expected to reduce risk 

for subpart S category

NEI26491 GeorgiaPacific Corp.Cedar Springs GA 9.95E-07 0.04 <1 No No NEI revisions received

NEI8261 Rock-Tenn Co. Fernandina 

Beach

FL 9.31E-07 0.03 <1 No Removal of biphenyl, o-cresol, and 

chlorinated HAPs from multiple 

sources expected to reduce risk for 

subpart S category

NEI26309 International 

Paper Co.

Cantonment FL 9.23E-07 0.04 <1 No Change in fugitive parameters and 

removal of risk driver pollutant 

expected to reduce risk for subpart S 

category

NEI45206 Weyerhaeuser 

Co.

Vanceboro NC 8.85E-07 0.01 <1 No Removal of risk driver pollutant from 

multiple sources expected to reduce 

risk for subpart S category

NEI41252 KapStone North 

Charleston

SC 8.85E-07 0.02 <1 No No NEI revisions received

NEI7559 Boise Inc. DeRidder LA 8.80E-07 0.04 <1 No No NEI revisions received

NEI33013 International 

Paper Co.

Mansfield LA 8.44E-07 0.03 <1 No Removal of some emission units 

expected to reduce risk for subpart S 

category

NEI11461 Rock-Tenn Co. Coshocton OH 8.18E-07 0.04 <1 No Removal of biphenyl from multiple 

sources expected to reduce risk for 

subpart S category

NEI33945 Packaging 

Corp. of 

America

Filer City MI 8.16E-07 0.04 <1 No Emissions reductions of risk 

driver/other pollutants expected to 

reduce risk for subpart S category

NEI40554 GeorgiaPacific Corp.Clatskanie OR 8.00E-07 0.01 <1 No Changes to release point type and 

stack parameters expected to reduce 

risk for subpart S category

NEI26504 Packaging Clyattville GA 7.94E-07 0.03 <1 No No revisions to subpart S sources, so 
19

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

Corp. of 

America

risk for subpart S category expected 

to be unchanged

NEI18335 International 

Paper Co.

Selma AL 7.69E-07 0.05 <1 No Removal of some emission units and 

risk driver pollutant expected to 

reduce risk for subpart S category

NEI11338 NewPage 

Corporation

Wickliffe KY 7.44E-07 0.03 <1 No No revisions to subpart S sources, so 

risk for subpart S category expected 

to be unchanged

NEI46852 Green Bay 

Packaging Inc.

Morrilton AR 7.35E-07 0.04 <1 No No NEI revisions received

NEI18390 AbitibiBowater 

Inc.

Coosa Pines AL 6.85E-07 0.02 <1 No No NEI revisions received

NEI23 Halltown 

Paperboard Co.

Halltown WV 6.53E-07 0.03 <1 No No NEI revisions received

NEI42341A Weyerhaeuser 

Co.

Longview WA 6.47E-07 0.07 4.03 (chloroform) No Net emissions reduction of risk driver 

pollutant expected to reduce risk for 

subpart S category

NEI46817 GeorgiaPacific Corp.Zachary LA 6.43E-07 0.02 1.03 

(acetaldehyde)

No Removal of risk driver pollutant 

expected to reduce risk for subpart S 

category

NEI47077 AbitibiBowater 

Inc.

Catawba SC 6.42E-07 0.04 <1 No No NEI revisions received

NEI26471 Graphic 

Packaging 

International, 

Inc.

Macon GA 6.28E-07 0.01 <1 No No NEI revisions received

NEI33103 Red Shield 

Environmental

Old Town ME 5.54E-07 0.03 <1 No No NEI revisions received

NEI42689 Wausau Paper Mosinee WI 5.50E-07 0.10 <1 No No NEI revisions received

NEI46866 TIN Inc., dba 

Temple-Inland

Waverly TN 5.40E-07 0.03 <1 No No NEI revisions received

NEI42486 Green Bay 

Packaging Inc.

Green Bay WI 5.12E-07 0.01 <1 No No NEI revisions received
20

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

NEI6175 Hollingsworth 

& Vose Co.

West Groton MA 5.08E-07 0.00 <1 No No NEI revisions received

NEI26382 Rayonier Inc. Fernandina 

Beach

FL 5.05E-07 0.02 1.10 (chloroform) No No NEI revisions received

NEI42329 Nippon Paper 

Industries USA 

Co., Ltd.

Port Angeles WA 5.05E-07 0.01 <1 No No NEI revisions received

NEI42338 Longview 

Fibre Co.

Longview WA 5.02E-07 0.03 1.46 

(formaldehyde)

No Emissions reductions of risk 

driver/other pollutants expected to 

reduce risk for subpart S category

NEI46931 MeadWestvaco Cottonton AL 4.77E-07 0.02 <1 No No NEI revisions received

NEI9201 Domtar Paper 

Company LLC

Plymouth NC 4.73E-07 0.02 <1 No No NEI revisions received

NEI41628 International 

Paper Co.

Queen City TX 4.52E-07 0.03 <1 No Removal of some emission units and 

risk driver pollutant expected to 

reduce risk for subpart S category

NEI12411 Boise Inc. International 

Falls

MN 4.44E-07 0.02 <1 No No NEI revisions received

NEI18338 GeorgiaPacific Corp.Brewton AL 4.31E-07 0.01 <1 No Large net emissions increase for 

subpart S category; however, 98% of 

the added emissions is methanol 

(only 5.7 tons attributed to other risk 

driver pollutants); also cancer MIR 

for subpart S category is <<1E-6, and 

non-cancer HI and HQ(REL)<1, so 

any increase in risk is not expected to 

result in a high risk result

NEI18357 International 

Paper Co.

Courtland AL 4.29E-07 0.01 <1 No Removal of risk driver pollutant 

expected to reduce risk for subpart S 

category

NEI26514 International 

Paper Co.

Augusta GA 4.17E-07 0.02 <1 No Changes in fugitive parameters and 

removal of some emission units and 

risk driver pollutant expected to 

reduce risk for subpart S category
21

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

NEI34064 Weyerhaeuser 

Co.

Columbus MS 3.90E-07 0.04 <1 No No NEI revisions received

NEI12492 TIN Inc., dba 

Temple-Inland

Orange TX 3.83E-07 0.01 <1 No No NEI revisions received

NEI33118 Sappi Fine 

Paper North 

America

Skowhegan ME 3.83E-07 0.01 <1 No No NEI revisions received

NEI18657 Delta Natural 

Kraft

Pine Bluff AR 3.70E-07 0.01 8.54 (1,2-

dimethoxyethane)

2.75 

(formaldehyde)

No No NEI revisions received

NEIMA10626 Onyx Specialty 

Papers

South Lee MA 3.62E-07 0.00 <1 No No NEI revisions received

NEI18347 Rock-Tenn Co. Stevenson AL 3.57E-07 0.02 1.00 

(acetaldehyde)

No Changes in fugitive parameters and 

removal of biphenyl and chlorinated 

HAPs from multiple sources expected

to reduce risk for subpart S category

NEI208 Bear Island 

Paper Co., 

LLC

Ashland VA 3.54E-07 0.02 4.16 (chloroform) No No NEI revisions received

NEI46760 International 

Paper Co.

Eastover SC 3.49E-07 0.07 <1 No Removal of some emission units and 

risk driver pollutant expected to 

reduce risk for subpart S category

NEI43202 Wausau Paper Rhinelander WI 3.35E-07 0.01 <1 No No NEI revisions received

NEI8601 Boise Inc. Jackson AL 2.93E-07 0.01 <1 No No NEI revisions received

NEI18373 Alabama River 

Cellulose

Perdue Hill AL 2.92E-07 0.01 1.53 

(acetaldehyde)

No Emissions reduction of risk driver 

pollutant expected to reduce risk for 

subpart S category

NEI33887 Verso Paper 

Corp.

Quinnesec MI 2.88E-07 0.01 <1 No No NEI revisions received

NEI42317 Rock-Tenn Co. Hopewell VA 2.83E-07 0.01 <1 No Changes in release point type and 

stack parameters and removal of o-
22

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

xylene and chlorinated HAPs from 

multiple sources expected to reduce 

risk for subpart S category

NEI26487 Proctor & 

Gamble Paper 

Products Co.

Albany GA 2.79E-07 0.01 <1 No No NEI revisions received

NEI45474 Rock-Tenn Co. Demopolis AL 2.77E-07 0.11 1.93 (chlorine) No Removal of emission unit and risk 

driver/other pollutants from multiple 

sources expected to reduce risk for 

subpart S category

NEI42710 Thilmany

Papers, LLC

Kaukauna WI 2.73E-07 0.01 <1 No No NEI revisions received

NEI8122 Augusta 

Newsprint Co.

Augusta GA 2.62E-07 0.01 <1 No No NEI revisions received

NEI42730 Fraser Papers 

Inc.

Park Falls WI 2.40E-07 0.01 <1 No No NEI revisions received

NEIWI4050324 GeorgiaPacific Corp.Green Bay WI 2.18E-07 0.14 <1 No Small net emissions increase for 

subpart S category; however, the 

added pollutant (4.8 tons) is vinyl 

acetate (not risk driver), while the 

reduced pollutant (1.8 tons) is 

acetaldehyde (risk driver); also 

cancer MIR for subpart S category is 

<<1E-6, and non-cancer HI and 

HQ(REL)<<1, so any increase in risk 

is not expected to result in a high risk 

result

NEI33981 Domtar Paper 

Company LLC

Port Huron MI 2.13E-07 0.01 <1 No No revisions to subpart S sources, so 

risk for subpart S category expected 

to be unchanged

NEI42410 Boise Inc. Wallula WA 1.93E-07 0.01 <1 No No NEI revisions received

NEIMN14904 NewPage 

Corporation

Duluth MN 1.89E-07 0.01 <1 No No NEI revisions received

NEI39968 Finch Paper 

LLC

Glens Falls NY 1.86E-07 0.14 <1 No No NEI revisions received
23

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

NEI13216 Catalyst Paper Snowflake AZ 1.76E-07 0.00 <1 No No NEI revisions received

NEI12368 Sappi Fine 

Paper North 

America

Cloquet MN 1.73E-07 0.00 <1 No No NEI revisions received

NEI26506 Weyerhaeuser 

Co.

Oglethorpe GA 1.59E-07 0.01 <1 No No NEI revisions received

NEI11108 AbitibiBowater 

Inc.

Grenada MS 1.57E-07 0.01 <1 No No NEI revisions received

NEI42495 Thilmany 

Papers, LLC

De Pere WI 1.51E-07 0.01 <1 No No NEI revisions received

NEI12980 GeorgiaPacific Corp.Muskogee OK 1.49E-07 0.01 <1 No Minor changes in stack parameters 

for two release points expected to 

have minimal impact on risk for 

subpart S category

NEI33104 Lincoln Paper 

and Tissue

Lincoln ME 1.48E-07 0.00 <1 No No NEI revisions received

NEI42800 Shawano 

Specialty 

Papers

Shawano WI 1.47E-07 0.01 <1 No No NEI revisions received

NEI42690 Wausau Paper Brokaw WI 1.45E-07 0.01 <1 No No NEI revisions received

NEI18652 Clearwater 

Paper Corp.

McGehee AR 1.29E-07 0.05 <1 No No revisions to subpart S sources, so 

risk for subpart S category expected 

to be unchanged

NEI35908 International 

Paper Co.

Ticonderoga NY 1.17E-07 0.01 <1 No Removal of some emission units and 

risk driver pollutant expected to 

reduce risk for subpart S category

NEIWI7500086 

& NEIWIT$8597 

NewPage 

Corporation

Stevens Point WI NEIWI7500086:

1.13E-07

NEIWIT$8597:

0.00E+00

NEIWI7500086:

0.01

NEIWIT$8597:

0.00

<1 No No NEI revisions received

NEIWI0793640 Wisconsin 

Paperboard 

Corp.

Milwaukee WI 1.12E-07 0.00 <1 No No NEI revisions received
24

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

NEI7933 Rock-Tenn Co. Florence SC 1.08E-07 0.00 <1 No Changes in release point type and 

stack parameters and removal of ocresol, o-xylene, chloroform, and 

other chlorinated HAPs from multiple 

sources expected to reduce risk for 

subpart S category

NEI8177 Interstate 

Paper L.L.C.

Riceboro GA 1.07E-07 0.00 <1 No No NEI revisions received

NEI6284 Verso Paper 

Corp.

Bucksport ME 1.05E-07 0.00 <1 No No NEI revisions received

NEI46750 Packaging 

Corp. of 

America

Tomahawk WI 9.83E-08 0.00 <1 No No NEI revisions received

NEI34020 Wausau Paper Brainerd MN 9.79E-08 0.00 <1 No No NEI revisions received

NEI11602 Graphic 

Packaging 

International, 

Inc.

Middletown OH 7.40E-08 0.00 <1 No No NEI revisions received

NEIPA1013489 Newman & 

Co., Inc.

Philadelphia PA 7.36E-08 0.00 <1 No No NEI revisions received

NEI2INT16350 Temple-Inland Cayuga IN 6.75E-08 0.00 <1 No No NEI revisions received

NEITN1050093 KimberlyClark 

Worldwide, 

Inc.

Loudon TN 6.34E-08 0.01 5.24 (chloroform) No No NEI revisions received

NEI11645 Appleton West 

Carrollton

OH 6.13E-08 0.07 1.90 (chloroform) No No NEI revisions received

NEI11600 Smart Papers 

L.L.C.

Hamilton OH 5.51E-08 0.00 <1 No No NEI revisions received

NEI36019 Knowlton 

Technologies, 

LLC

Watertown NY 5.18E-08 0.00 <1 No No NEI revisions received

NEICT3102 Cascades Versailles CT 5.01E-08 0.00 <1 No No NEI revisions received
25

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

Boxboard

NEIWI4710355 SCA Tissue 

North 

America, 

L.L.C.

Menasha WI 4.43E-08 0.00 <1 No No NEI revisions received

NEI42961 NewPage 

Corporation

Wisconsin 

Rapids

WI 4.32E-08 0.00 <1 No No NEI revisions received

NEW73505 Republic 

Paperboard Co.

Lawton OK 4.22E-08 0.00 <1 No No NEI revisions received

NEI40488 Glatfelter Chillicothe OH 3.76E-08 0.00 <1 No No NEI revisions received

NEIGAT$3911 SP Newsprint 

Co.

East Dublin GA 3.39E-08 0.02 <1 No No NEI revisions received

NEI33866 Neenah Paper, 

Inc.

Munising MI 2.45E-08 0.00 <1 No No NEI revisions received

NEI7106 American 

Eagle Paper 

Mills Inc.

Tyrone PA 1.40E-08 0.00 <1 No No NEI revisions received

NEI33950 Menominee 

Paper Co. 

/Cellu Tissue

Menominee MI 8.45E-09 0.00 <1 No No NEI revisions received

NEI40720 PaperWorks 

Industries, Inc.

Philadelphia PA 7.58E-09 0.00 <1 No No NEI revisions received

NEI26304 Rock-Tenn Co. Jacksonville FL 4.13E-09 0.00 <1 No Removal of biphenyl, o-xylene, 

methylene chloride, and other 

chlorinated HAP from multiple 

sources expected to reduce risk for 

subpart S category

NEINY5532600 Hollingsworth 

& Vose Co.

Greenwich NY 1.44E-09 0.00 <1 No No NEI revisions received

NEI40553 Boise Inc. St Helens OR 4.20E-10 0.00 <1 No No NEI revisions received

NEINY5533400 Hollingsworth 

& Vose Co.

Easton NY 3.12E-10 0.00 <1 No No NEI revisions received
26

Survey NEI

Company 

name Mill city

Mill 

state Cancer MIR

Chronic noncancer max HIa

Acute noncancer max

HQ(REL)b

Remodel? Reasons

NEI2WAT18798 Ponderay 

Newsprint Co.

Usk WA 0.00E+00 0.00 <1 No No NEI revisions received

NEI42385 KimberlyClark 

Worldwide, 

Inc.

Everett WA 0.00E+00 0.00 <1 No No NEI revisions received

NEIGAT$3909 Hollingsworth 

& Vose Co.

Hawkinsville GA 0.00E+00 0.00 <1 No No NEI revisions received

NEI33072 Sappi Fine 

Paper North 

America

Westbrook ME -- -- -- No No HAP data for subpart S category

to model

NEI33986 Manistique 

Papers Inc.

Manistique MI -- -- -- No No HAP data for subpart S category

to model

NEIMA131179 Hollingsworth 

& Vose Co.

East Walpole MA -- -- -- No No HAP data for subpart S category

to model

NEIWA0270002 Grays Harbor 

Paper, LLC

Hoquiam WA -- -- -- No Not modeled

a Chronic non-cancer max HI results are low (<1) for all mills, so HI values were not considered in the risk remodeling evaluation. Note: HI values of 0.00 simply mean that HI is 

less than 0.005 (i.e., cannot be rounded to 0.01).

b Acute non-cancer HQ(REL) results are available for multiple pollutants. Note: Table only includes specific HQ(REL) values above 1.
Appendix A. NEI Data Revisions Review Sheet

A-1

 Source category Facility-Wide

Chronic cancer MIR _______ _______

Chronic non-cancer max HI _______ _______

Acute non-cancer max HQ REL _______ _______

NEI code: ____________ RTI code: ______

Mill name (city and state): ___________________________________________________

Format of NEI revision (check one):

__Spreadsheet __Resubmittal of prior inventory in its entirety

__Written comment __Other (specify) _______________

__Submitted before proposal

Changes That May Increase Risk (check all that apply)

Type of change in inventory revision

Subpart S 

(1626-1 Sources)

Subpart MM 

(1626-2 Sources)

Facilitywide 

sources

Reduced stack/fugitive release height

Reduced fugitive area (l x w)

Increased emissions of key risk driver pollutants 

(> 1 tpy increase)*

Increased emissions of other HAP less likely to 

be risk drivers (> 10 tpy increase)

Reduced stack gas temperature

Reduced stack gas velocity or flow

Added rows with add’l HAP emission unit(s)

Added rows with add’l HAPs (particularly risk 

drivers) for previously reported emission units*

Changed emission release point type from stack 

to fugitive, vertical to horizontal, gooseneck, etc 

*acetaldehyde, formaldehyde, hexachloroethane, naphthalene, chloroform, methanol, metals

Changes Likely to Reduce Risk (check all that apply)

Type of change in inventory revision

Subpart S 

(1626-1 Sources)

Subpart MM 

(1626-2 Sources)

Facilitywide 

sources

Increased stack/fugitive release height

Increased fugitive area (l x w)

Reduced emissions of key risk driver pollutants 

(> 1 tpy decrease)*

Reduced emissions of other HAP less likely to be 

risk drivers (> 10 tpy decrease)

Increased stack gas temperature

Increased stack gas velocity or flow

Deleted rows of HAP emission unit(s)

Deleted rows of HAPs (particularly risk drivers) 

for previously reported emission units*
Appendix A. NEI Data Revisions Review Sheet

A-2

Type of change in inventory revision

Subpart S 

(1626-1 Sources)

Subpart MM 

(1626-2 Sources)

Facilitywide 

sources

Changed emission release point type from 

fugitive to stack, horizontal/gooseneck/etc. to 

vertical

*acetaldehyde, formaldehyde, hexachloroethane, naphthalene, chloroform, methanol, metals

Changes with Unknown Affect on Risk

Type of change in inventory revision

Subpart S

(1626-1 Sources)

Subpart MM 

(1626-2 Sources)

Facilitywide 

sources

Changes in lat/long coordinates

Change in fugitive angle

Other types of changes (list):

__Mill name

__NEI ID

__SIC code

__SCCs

__Emission unit description

__Emission unit ID

__Process ID

__Emission release point ID

__MACT code

__Control measure code/description

Notes: