### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY SECTOR POLICIES AND PROGRAMS DIVISION OFFICE OF AIR QUALITY PLANNING AND STANDARDS OFFICE OF AIR AND RADIATION



### DATE: April 5 , 2013

SUBJECT: Review of the Conti nuous Emission Monitoring and Continuous Opa city Monitoring Data from the Pulp and Paper Information Collection Request Responses Pertaining to Subpart BB Sources

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

TO: EPA

- HQ

- OAR

- 2012

- 0640

The purpose of this memorandum is to present the results of a review of the Continuous Emission Monitoring System (CEM S ) and Continuous Opacity Monitoring System (COM S ) data provided by the pulp and paper industry in response to the 201 1 Information Collection Request (ICR). This analysis is part of the U.S. Environmental Protection Agency’s (EPA) effort to review the New Source Performance Standards (NSPS) for kraft pulp mills (40 CFR part 60, subpart BB) in accordance with section 1 11(b)(1)(B) of the Clean Air Act (CAA).

S ection 111 (b)(1)(B) of the CAA mandates that the EPA review and, if appropriate, revise the existing NSPS at least every 8 years. The kraft pulp mills NSPS was promulgated in 197 8 and reviewed in 1986. The NSPS regulates emissions of particulate matter (PM) from new, modified, and reconstructed recovery furnaces, smelt dissolving tanks, and lime kilns at kraft pulp mills. The NSPS also regulates emissions of total reduce sulfur (TRS) compounds from
new, modified, and reconstructed digesters, brown stock washers, multiple

- effect evaporators, condensate strippers, recovery furnaces, smelt dissolving tanks, and lime kilns at kraft pulp mills. On December 6, 2011, the Center for Biological Diversity, Greenpea ce, and the Port Townsend Airwatchers filed a complaint (Clean Air Act c itizen s uit) against the EPA to review the NSPS. This complaint resulted in a consent decree that requires EPA to review the NSPS by May 15, 2013 for proposal and March 14, 2014 for pr omulgation. See docket ID number EPA

- HQ

- OGC

2012

- 0730 for a copy of the consent decree.

Section I of this memorandum provides a summary of the t abulation and quality

assurance / quality control ( QA/ QC) analysis of the data provided by industry in response to the ICR survey. Section II of this memorandum discusses the analysis of the QA/QC ’d data

.

I. Data Assembly and QA/QC

The CEMS and COMS d ata w ere collected from the pulp and paper industry in 201 1 in response to a C A A § 114 ICR

. The three

- part survey was distributed by the EPA in February 201 1 and request ed information needed to perform various regulatory reviews, including the2 

### subpart BB NSPS review. This section of the memo discusses the QA/QC of the CEM S and COM S data that wer e provided in response to the ICR.

The general approach for proce ssing the CEMS and COMS data was to extract the data, as received, from individual ICR responses into a tabulation spreadsheet. Separate tabulation spreadsheets were developed for recovery furna ce opacity
, lime kiln opacity, recovery furnace TRS
, lime kiln TRS , and TRS from other pulping process emission units . Tabs within each tabulation spreadsheet were labeled in the format of RTI facility code followed by emission unit ID with a period as a separator for the two values. If data were provided for multiple stacks for a given unit, they were also extracted into separate worksheets with the same naming convention, followed by an indication of stack location in parentheses. For example, the u nit R401 at RTI f

acility 243 has two stacks and wa s represented by data in two separate worksheets with tabs labeled as follows: 243.R401 (N) and 243.R401 (S). A summary worksheet was included in each tabulation spreadsheet to link and tabulate the data pr ovided for each emission unit. Emission unit ID, RTI facility ID, and NEI site ID were provided to characterize the emission units; the “tab name ” of each worksheet from which the data are linked wa s provided ; and summary information such as annual average emissions, 99 th 

### percentiles , and maximum values were calculated. The data from each summary worksheet were used for the data analysis discussed in Section II in this document.

Spreadsheet templates for COMS and CEMS data were provided with part III of the ICR (P&P CEMS_PIII.xls). The ICR template requested 6

- minute average opacity values for a period of one year (87,600 opacity averages), as well as 1

- hour average and 12

- hour av erage TRS values for a period of one year. Alternative formats were also accepted. To some extent, the data extracted into the COMS and CEMS tabulation spreadsheets varied in format and type, depending on the facility and the unit, likely due to other stat e reporting and compliance requirements

. In some cases, respondents did not provide COMS or TRS CEMS data , or provided the data in an alternative format ( i.e

. , .pdf or .doc or .txt) that would have required extensive manipulation or re

- entry of data. Given the abundance of data sets provided in spreadsheet form that were “analysis

- ready
, ” it was elected not to tabulate data provided in an alternative form

. Mills that did not provide data in spreadsheet form were excluded from the quantitative analysis of the o pacity and TRS emission limit s , but the information these mills provided was reviewed qualitatively to confirm that it was comparable to the “analysis

- ready” information provided by other mills

. All data provided were reviewed for erroneous CO MS or CEMS readings. These readings included negative values and abnormally large values during periods of process downtime. All negative readings were deemed suspect and were removed from the data set to prevent artificial lowering of a unit’s annual aver age performance. The cells containing these values were highlighted in yellow to indicate removal. Abnormally large values that occurred during periods labeled as “process downtime” were removed if the production rate was reported as zero to indicate that the unit was non

- operational because emissions of opacity or TRS would not be expected when the process is down . These were removed to prevent the artificial increase in the annual average emissions associated with the unit . The cells corresponding to the removed values were also highlighted in yellow. Large values that were reported during other periods, in which the production rate was not zero, were not deleted from the data set. Facilities were asked3 

### to indicate in the ICR if any data were affected by p eriods of startup, shut down, and malfunction (SSM). Opacity and TRS emissions occurring during periods of SSM were retained in the continuous monitoring data averages analyzed in order to evaluate whether the updated NSPS should distinguish betw een periods of startup and shutdown and normal operation as revised emission limits were considered.

Based on the part III survey responses, there were 1 51 recovery furnaces and 13 1 lime kilns at 98 kraft pulp mills in 2009. Of these, two recovery furnace s were indicated as non

- operational during the year of the ICR, resulting in 149 operating recovery furnaces. These two units were the following: RF18 at Longview Fiber and Packaging (RTI 156, NEI42338) and EU445A at International Paper in Springfield (RTI 105, NEI45182).

A summary of the type of recovery furnace COMS and TRS CEMS data received and the comments from our QA/QC are listed in Appendix A. Similarly, a summary of the type of lime kiln COMS and TRS CEMS data and our QA/QC comments are listed in Appendix B.

A. Recovery Furnace Opacity Data

C ontinuous opacity monitoring system data were provided for 13 7 of the 149 operating recovery furnaces . Of the 13 7 units with data provided, 13 5 were extracted into a comp i led recovery furnace COM S spreadsheet containing individual worksheets for each unit

. Th ere were 2 5 units with multiple

- stack opacity data. The two units with data that were not extracted into the sp readsheet were not provided in E xcel format. The data for 117.B21 were provided as

. pdf and the data for 155.RECOVERY FURNACE were provided in W ord format (.doc). Recovery furnace design ( direct contact evaporator [ DCE ] or non

- direct contact evaporator [ NDCE ] ) and air pollution control device ( APCD ) type were added to the spreadsheet from the part III database. In all, adding in emission units with COMS on multiple stacks, 160 COMS data sets were available for analysis.

The order of preference for opacity averaging period extracted into the opacity tabulation spreadsheet was 6

- minute averages, 1

- hour average, and maximum 6

- minute average per hour. Of the data provided, 12 8 units were extracted in the 6

- minute format (23 units with multiple stacks)
, 5 units in the 1

- hour format (1 unit with multiple stacks) , and 2 units in the maximum hourly 6

- minute average format (1 unit with multiple stacks)

.

T he recovery furnace COMS summary worksheet summarizes the data type as “ 6

- minute averages, ” “ hourly averages, ” “ highest 6

- minute ave rage per hour, ” “ data not provided, ” or “ data provided in alternate format. ” For each COMS, the summary spreadsheet contains the maximum opacity, the average ( including and excluding exceedances )
, the standard deviation, the 99 th 

### percentile, the median, and the number (and percentage) of opacity 6

- minute average values over 20 percent and 35 percent

. The number of averaging periods in which opacity data were not provided ( e. g. , invalid data) is also indicated.4 

### B. Recovery Furnace Total Reduced Sulfur (TRS) CEMS Data

Total r educed s ulfur CEM S data were provided for 13 5 of the 149 operating recovery furnaces

. Of the 13 5 units with data provided, 1 31 were extracted into a comp i led recovery furnace TRS CEMs spreadsheet containing individual worksheets for each unit

. There were 1 0 recovery furnaces with multiple stack TRS data. The four units with data that were not extracted into the sp readsheet were not provided in E xcel format. The data for three of these units were provided in W ord format and one unit was provided as a PDF document

. In all, adding emission units with multiple stacks, 141 TRS CEMS data sets were available for analysis.

As noted previously, s eparate TRS CEMS spreadsheet templates requesting 12

- hour and 1

- hour average TRS data for a perio d of one year were provided with p art III of the ICR . The 1

- hour average data were requested in addition to the 12

- hour average data in order for EPA to explore shorter averaging times should there be a prevalence of shorter TRS averaging times required by s tate regulations . However, based on a review of permit limits and of the CEMS data provided
, it appears that a 12

- hour averaging time is most consistently used for compliance. Therefore, t he order of preference for TRS averagi ng time extracted into the tabulation spreadsheet used was 12

- hour averages, followed by 12

- hour averages manually calculated based

on 1

- hour averages, with 24

- hour averages being least desirable . Of the TRS data provided, 11 5 recovery furnaces were extracted in the 12

- hour average format (9 units with multiple stacks) , 1 0 units in the 12

- hour average calculated based on 1

- hour averages , and 6 units in the 24

- hour format (1 unit with multiple stacks)

.

The CEM S spreadsheet template that was sen t to industry with part III of the survey (P&P CEMS_PIII.xls) requested that a facility report the “ 12

- hour average emission value for TRS (ppmdv corrected for % O 2 

### ) ” in column I with the instructions “ p lease enter concentration (ppmdv) corrected for % O 2 

### as required by subpart BB (8% O 2 

### for recovery furnaces; 10% O 2 

### for other equipment for which data are requested).” The spreadsheet template also requested that a facility report the “ % O 2 

### correction (by volume, dry basis) ” in column J with the instruction s to enter “t he % O 2 

### correction by volume (dry basis) (e.g

. , 8% or 10%). ” For the recovery furnace TRS CEM S , it was expected that the oxygen (O 2 

### ) correction would be reported as 8 percent in column J

. The oxygen correction data for 9 units (109.RB3, 109.RB4, 127.REC1, 171.02, 171.03, 171.04, 183.002, 207.038, and 340.005) reported in column J appeared to be raw O 2 

### data instead of the requeste d corrected O 2 

### value of 8 percent

. It was assumed
, because raw O 2 

### data

were reported instead of the correction value
, that the TRS data provided in column I w ere also raw data. The raw TRS and O 2 

### values were used to determine the corrected TRS value using Eqn. 1 shown below from 40 CFR 60.284(c)(3) . The new TRS column was highlighted in yellow for the 9 units reported for which values were calculated. Unit 163.RF1901 had d ata reported as corrected to 10 percent O 2 

### and unit 242.AA

- 011 had data as corrected to 5 percent O 2 

### . These units were corrected to 8 percent O 2 

### . The data for two units (100.037A, 143.7000) were indicated as raw data. These values were also corrected using Eqn. 1 and the corrected TRS value column was highlighted in yellow.

Corrected TRS value = Raw TRS concentration value * ((21

- 8)/(21

- O 2 

### value)) ( Eqn. 1 )5 

### Data provided for six units (179.RF3, 240.RF04, 240.RF01, 163.RF1901, 163.RF2904, and 151.REC004) may slightly skew the performance values ( e.g. , annual average, median, 99 th 

### percentile) for those units because data w ere reported as “<1” instead of decimal values for 179.RF3 , 240.RF04, 240.RF01, 163.RF1901, 163.RF2904, and “0” for values less than 0.5 for 151.REC004. These values were not removed or edited ; therefore
, they did not contribute to the performance values
, but the reporting of the data was considered in the analys is

.

The summary worksheet in the recovery furnace TRS CEM S spreadsheet indicated the data type as “ 12

- hr average, ” “ 12

- hr calculated from 1

- hr averages ,” “ 24

- hr average, ” “ not provided, ”

or “ provided in alternative format. ” The annual average and standard deviation of the corrected TRS parts per million (ppm) 1 

### values were calculated for each unit (to determine 99 th 

### percentiles)
, as well as the maximum reported average and the n umber of exceeda nces over 5 ppm

. Because
most DCE recovery furnaces are not currently subject to the NSPS, the 20 ppm emission guideline for DCEs was also used for comparison. The emission guideline for NDCEs is 5 ppm (the same as the NSPS , though permitting approaches va ry by state ). Additional details such as APCD type, NSPS applicability, and whether or not the recovery furnace burns non

- condensable gases (NCG) were imported into the CEMS tabulation spreadsheet for analysis.

C. Lime Kiln TRS CEMS Data

Total r educe d s ulfur CEMS data were provided for 116 of the 131 operating lime kilns . Of the 11 6 units with data provided, 111 units were extracted into a comp i led lime kiln TRS CEMS spreadsheet containing individual worksheets for each unit

. There was only one lime kiln with multiple stack data provided. The four kilns with data that were not extracted into the sp readsheet were not provided in E xcel format. The data for two of these kilns were provided in text format (.txt), one kiln was provided in W ord format
, and one kiln was provided as a PDF document

. In all, adding emission units with multiple stacks, 112 TRS CEMS data sets were available for analysis.

Similar to recovery furnaces, the order of preference for TRS averaging period for lime kilns was 12

- hour averages, followed by 12

- hour averages calculated based on 1

- hour averages, with 24

- hour averages being least desirable . Of the data provided, 91 kiln s were extracted in the 12

- hour average format (1 unit with multiple stacks) , 1 4 kiln s were ex tracted in the 1

- hour average format, and 6 were extracted in the 24

- hour format. The 1

- hour average TRS data sets were converted to 12

- hour average format for comparison purposes.

T he O 2 

### correction data for 9 lime kilns (109.LK1, 112.AA

- 11, 127.LK1, 127.LK2, 164.P12, 171.009, 171.010, 183.004, and 340.008) reported in column J of the ICR template appeared to be raw O 2 

### data instead of the requested corrected O 2 

### value of 10 percent . The raw TRS and O 2 

### values were used to d etermine the corrected TRS value using Eqn. 1 above. Units 119.EQT006, 103.G

- 65, and 105.EU455 had data reported as corrected to 8 percent O 2 

### ; therefore
, a new

1 All parts

- per

- million values reported in this document represent ppm by volume on a dry basis (ppmdv)

.6 

### column was added (highlighted yellow) with the data c orrected to 10 percent . Raw data were repor ted for unit 143.6063, which w ere used to calculate the corrected TRS values.

Data provided for four units (163.LK1501, 163.LK2502, 179.LK3, 240.CA81) may skew the annual performance values (e.g., annual average, 99 th 

### percentile) for those units because data

were reported as “<1” instead of decimal values. These values were not removed or edited ; therefore
, they did not contribute to the performance values
, but t he reporting of the data was considered in the analysis.

A summary worksheet was added to th e lime kil n TRS CEMS spreadsheet to characterize the data provided. Emission unit ID , RTI facility ID, and NEI site ID were provided to characterize the emission units. The name of the worksheet for which the data were calculated for each row of data was p rovided as “tab name
, ” and data type was indicated as “ 12

- hr average, ” “ 24

- hr average, ” “ not provided, ” or “ provided in alternative format. ” The annual average and standard deviation of the corrected TRS ppm values were calculated for each unit (to determine 99 th 

### percentile) , as well as the maximum average and the number of exceedances over 8 ppm

. Because some lime kilns are not currently subject to NSPS, the 20 ppm emission guideline was also used for comparison. Additional lime kiln details su ch as APCD type, NSPS applicability, whether or not the lime kiln burns non

- condensable gases (NCG), or uses a white

- liquor NCG pre

- scrubber were imported into the CEMS tabulation spreadsheet for analysis.

D. Lime Kiln Opacity Data

Lime kiln opacity data we re compiled in order to establish a limit for lime kilns with electrostatic precipitators ( ESPs ) under the NSPS. Continuous opacity monitoring system data were provided for 27 lime kilns that utilize ESPs or ESP/scrubber combinations as pollution control d evices. These were extracted into a compiled lime kiln COMs spreadsheet containing individual worksheets for each unit. T here were 2 units with multiple stack opacity data. The order of preference for opacity averaging period extracted into the opacity tab ulation spreadsheet was 6

- minute averages and 1

- hour average. There were 25 units extracted in the 6

- minute average format and 2 extracted in the 1

- hour format. Including kilns with dual stacks, 29 data sets were available for analysis.

The lime kiln COMS summary worksheet summarizes the data type as “6

- minute averages” and “hourly averages.” The maximum opacity, the average, the standard deviation, the 99 th 

### percentile, the median, and the number (and percentage) of opacity average values over 20 percent w ere calculated

.

II. Data Analysis

Summary data from the recovery furnace and lime kiln COMS and TRS CEMS spreadsheets described in Section I were plotted and compared to the current NSPS limits in order to develop regulatory options for the NSPS review. T he annual average measurements, percent of averaging periods exceeding the current standard, and the 99 th 

### percentile of the averaging periods were7 

### plotted for each emission unit. The 99 th 

### percentile was used as an indicator of the emission limitation consistently met by each emission unit. Distinctions in furnace design and control systems , and current emissions allowances in the NSPS, were considered in the CEMS and COMS analyse s as descr ibed in more detail in the following sections.

A. Recovery Furnace COMS Analysis

Opacity limit evaluation

. The kraft pulping NSPS contain a 35 percent limit for opacity from recovery furnaces and does not distinguish between recovery furnace design (DCE or NDCE). The NSPS requires opacity to be recorded as 6

- minute averages, and allows 6 percent of the 6

- minute averages per quarter recorded to be in exceedance of the 35 percent limit. Ap pendix C contains graphs of the recovery furnace opacity data

. The horizontal axis represents each emission unit , but is not labeled with emission unit IDs because this would make the figures too difficult to read. A total of 160 COMS data sets were graphed (including multiple data sets for furnaces with separate COMS for dual stacks). The majority (151) o f the COMS data sets graphed were 6

- minute average data

. T hree data sets represented the highest 6

- minute average per hour, and six data sets were based on hourly average. The highest 6

- minute average per hour and hou rly data sets were generally within the range of the 6

- minute average data (unless otherwise noted on the plots).

Figure 1 in Appendix C presents the annual average of the opacity readings for each recovery furnace COMS data set (160 data sets)

. Based on this figure, it does not appear that r ecovery furnace design affect s opacity

. The highest annual average opacity was 16 percent, well below the 35 percent NSPS limit. Figures 2 and 3 show annual average opacity by control type (within DCE and NDCE groupings in Figure 2). From Figures 2 and 3
, it appears that there is no clear distinction between recovery furnace control system and opacity.

C ompliance is based on each individual averaging period and not the annual average

. T herefore, the 99 th 

### percentile and percent of averaging periods exceeding 35 percent were graphed in order to understand how opacity varies

. Figure 4 in Appendix C presents the 99 th 

### percentile values from e ach of the 160 COMS data sets. From Figure 4
, it is apparent that m os t mi lls are consistently meeting the NSPS limit of 35 percent opacity. The Subpart MM NESHAP contains a 20 percent opacity monitoring action level for new and existing recovery furnaces (40 CFR 63.864(k) (1) (i))

. For new recovery furnaces equipped with an ESP, subpart MM considers opacity greater than 20 percent for more than 6 percent of quarterly operating time to be a violation of the subpart MM standards (40 CFR 63.864(k)(2)(i))

. Figure 4 shows that most (129 of 160 data sets ) recovery furnac e COMS had 99 th 

### percentiles below the 20 percent level regardless of recovery furnace design

. Figures 5 and 6 break out 99 th 

### percentile opacity by control type (within design groupings in Figure 5). Figures 5 and 6 show that most control types are capable of meeting 20 percent opacity consistently , and that all control types are meeting 35 percent consistently. Two unique control systems (a parallel DBES P

- WPR/DBESP/DBESP system and a two

- sided dry and wet bottom ESP) had 99 th 

### percentiles around 25 and 27 percent, resp ectively

. The annual averages for these two unique systems were around 14 and 10 percent, respectively.

Based on Figures 1 through 6 in Appendix C
, 20 percent opacity emerges as a regulatory option for investigation under the NSPS review because: (1) 20 p ercent is already a benchmark8 

### under subpart MM, (2) all mills had annual average opacity o f 16 percent or less, and (3) the majority of recovery furnaces are consistently achieving 20 percent opacity

. The EPA could consider hi gher or lower options (e.g., 25 percent or 15 percent )
, but these do not have the benefit of relating to subpart MM. It appears that an opacity limit of 20 percent has been adequately demonstrated for recovery furnaces.
Monitoring allowance evaluation

. Figures 7 through 9 review the percentage of averaging periods exceeding the current 35 percent NSPS opacity limit, as compared to the current 6 percent monitoring exceedance allowance

. Similarly, Figures 10 through 12 show the percentage of averaging p eriods exceeding 20 percent opacity

. Figures 7 through 9 show that the overwhelming majority of mills are performing far better than the 6 percent monitoring allowance for opacity above 35 percent regardless of recovery furnace design or APCD type

. These figures show that a 2 percent monitoring allowance would more accurately represent the number of exceed a n ces mills are incurring under a 35 percent opacity limit

. Twenty

- three recovery furnace COMS had zero exceedances of the 35 percent limit.

Figures 10 through 12 show that a 2 percent monitor ing allowance coupled with a 20 percent limit is achieved by many recovery furnaces regardless of design or control system

. The two unique control systems mentioned above would be challenged to remain under a 2 percent monitoring allowance b ut because alternative control designs are both available and adequately demonstrated, it is not clear if the two unique control types would continue to be used if those furnaces were to be replaced, modified, or reconstructed. A 6 percent monitoring allo wance would c over nearly all exceedances of the 20 percent opacit y limit and is consistent with subpart MM (but a 6 percent allowance would not provide much incentive for improvement compared to

a 2 percent allowance)

. A 2 percent monitoring allowance more accurately represents the number of exceed a n ces the best performing recovery furnaces were incurring on opacity limits ranging from 20 to 35 percent

. Only 12 of 160 recovery furnaces COMS did not exceed the 20 percent opacity limit

. The proposed Subp art BBa NSPS will not be applicable to any existing unit (unless the unit is modified or reconstructed)

. However, we evaluated the recovery furnaces that, according to the data provided, might be challenged to meet a 20 percent limit with a 2 percent allow ance in order to see if they shared common attributes

. F urther analysis of the 16 COMS data sets above the 2 percent exc eedance threshold in Figures 10 through 12 revealed that 15 furnaces did not meet a 20 percent opacity with a 2 percent allowance (1 furnace had 2 stacks). After removal of data indicated as malfunctions and process down from the COMS data sets, three additional furnaces achieved 20 percent opacity with a 2 percent allowance. Seven of the 12 furnaces that did not achieve 2 0 percent opacity with a 2 percent allowance ar e NSPS units (NDCEs) and five furnaces (4 NDCE and 1 DCE) were not subject to the NSPS. The range of exceedances after removing the malfunction and process down data was 2.1 to 7.8 percent (excluding the 27.1 percent unit omitted from the graphs) and the average is 3.7 percent . Some COMS data sets were not annotated with process do wn or malfunction periods and it is thought that labeling and removing the affected 6

- minute averages would like ly result in some of these furnaces achieving

a 20 percent limit with a 2 percent monitor ing allowance. Overall
, 1 23 of 135 recovery furnace s with multiple types of control systems ( e.g., dry and wet bottom ESPs with and without dry PM return) adequately demonstrate d the ability to meet a 20 percent opacity limit with a 2 percent allowance option, each at numerous facilities in the industry.9 

### Recommendation

. The figures in Appendix C support a regulatory decision to reduce the subpart BB opacity limit from 35 percent to 20 percent and to reduce the monitoring allowance from 6 percent to 2 percent for new, modified, and reconstructed recovery furnaces

. Startup and shutdown periods were included in the data sets used to evaluate the revised opacity limit. Therefore, a revised limit of 20 percent opacity with a 2 percent monitoring allowance accounts for startup and shutdown periods (as well as normal operation) supporting the conclusion that separate opacity limits for startup and shutdown are unnecessary. Continuous compliance with the NSPS PM standards can be demonstrated through monitoring of control device operating parameters (e.g. ESP secondary voltage and current or power) during times when the 2 percent monitoring allowance is invoked.

B. Recovery Furnace TRS CEMS Analysis

TRS limit evaluation

. The kraft pulp mill NSPS limit TRS emissions from straight recovery furnaces to 5 ppm at 8 percent O 2 

### and from cross recovery furnaces to 25 ppm at 8 percent O 2 

### . Review of the part III ICR data indicate that no cross recover y furnaces are currently subject to the NSPS. Likewise, there is no TRS emissions data to analyze for th ese units. M aintain ing the current cross recovery furnace TRS limit is recommended for three technical reasons. First, the sulfur content of the semiche mical liquor is higher than traditional kraft liquor. Second, the heat content of the liquor is lower because it contains less organic material than kraft pulping liquor because of higher pulping yields. Lastly, the heavier sulfur loading and the lower ope rating temperature puts a restriction on the amount of excess oxygen available to oxidize sulfur compounds. Practically, we do not project any modified, reconstructed
, or new cross recovery furnaces being constructed in our analysis

. The remainder of this section will focus on TRS emissions from straight recovery furnaces.

The NSPS require TRS to be recorded as 12

- hour averages and allow one percent of the 12 hour averages recorded per quarter to be in exceedance of the 5 ppm limit without constituting a

v iolation. Appendix D contains graphs of the recovery furnace TRS data. A total of 1 31 recovery furnaces are represented by these graphs (including 1 0 recovery furnaces with multiple TRS CEMS for a total of 14 1 TRS data sets) , with the majority reported as 12

- hour averages. The TRS emission guidelines require a limit of 5 ppm for exiting NDCE and 20 ppm for existing DCE recovery furnaces. All of the recovery furnace TRS ppm values discussed in this section reflect conversion to 8 percent O 2 

### . The plots in Appendix D present t he recovery furnace TRS summary data from the summary spreadsheet described in Section I. Most of the TRS values shown on the plots are based on 12

- hour averaging periods ; h owever, seven of the TRS data sets (for non

- NSPS furnaces) are ba sed on 24

- hour average values. T he graphs distinguish between NSPS and non

- NSPS recovery furnaces because there are separate Federal TRS limits for existing and new sources under the emission guidelines and NSPS, respectively. Recovery furnace design and NSPS applicability appear to be more relevant than control device type in distinguishing between the best performing recovery furnaces for TRS. Process control factors (e.g., good combustion practices ) are expected to play a large role in recovery furnace TRS emissions.10 

### As shown in Figure 1 in Appendix D, m any DCE recovery furnaces that are not s ubject to the NSPS TRS limit exhibit emissions above 5 ppm but belo w the 20 ppm emission guideline on an average basis ( i.e., the average of the block averaging periods provided for the year)

. On average, all but one of the NDCE recovery furnaces met the 5 ppm limit, and most of the NDCEs averaged below 2 ppm.

Because compliance with the NSPS TRS limit is based on each 12

- hour block average (rather than the average of all 12

- hour blocks in a year), we considered the 99 th 

### percentile of the TRS averaging periods in Figure 2 as an indicator of how consistently the block average limit is achieved

. Two 99 th 

### percentile outliers were omitted from Figure 2 (a non

- NSPS DCE with 99 th 

### percentile at 126 ppm, and a NDCE subject to the NSPS with 99 th 

### percentile at 43 ppm). When considering the 99 th 

### percentile, nearly all of the DCE furnaces had TRS emissions above 5 ppm while the majority of NDCE furnaces achieved 5 ppm consistently

. Most of the DCE furnaces had 99 th 

### percentile values between 5 ppm and 20 ppm, with a few DCE furnaces exhibiting 99 th 

### percentile values between 20 and 30 ppm.

We also considered the number of averaging periods in excess of 5 ppm for each recovery furnace in Figure 3. Predictably, the DCEs exhibited a high percentage of averaging periods above 5 ppm because most DCEs are not required to consistently meet the 5 ppm limit. The majority of NDCEs achieved the 5 ppm limit consistently with one percent or fewer of the averaging periods in excess of 5 ppm. As noted previously, s ubpart BB contains a one percent monitoring allowance for recovery furnace TRS

. A few NDCE furnaces had a relatively high percentage of a veraging periods in excess of 5 ppm, but these were mostly non

- NSPS NDCEs.

Only the recovery furnaces subject to the NSPS were plotted in Figures 4 through 6 in order to better evaluate the one percent TRS monitoring allowance and the effect of different types of air pollution controls

. As shown in Figure 4, two of the three DCEs subject to the NSPS exceeded 5 ppm in less than one percent of the averaging period s. One of these DCEs had zero

exce edances. The third DCE (controlled by a WBESP and scrubber) exceeded the 5 ppm limit in 46 percent of the averaging periods, which again suggests that DCEs are challenged to meet a TRS limit of 5 ppm. Many of the NDCEs ( 44 of 72 ) subject to the NSPS achieved the 5 ppm limit with zero exceedances during the year reported

. An additional 14 NDCEs had some exceedances but remained below the one percent monitoring allowance
, and 8 units exceeded 5 ppm for 1 percent of the reporting periods. Six NDCEs excee ded 5 ppm in up to 7 percent averaging periods

. Based on this figure , it appears that a one percent monitoring allowance reflects the level of TRS compliance that has been adequately demonstrated and is achieved by the best performing recovery furnaces.

F igure 5 shows that there is little difference in the performance of various control systems used on NSPS recovery furnaces

. All systems achieved the 5 ppm limit on an annual basis , with the exception of the DCE controlled by a WBESP and scrubber. In Figure 6, we observe that control device type does not appear to significantly affect the 99 th 

### percentile TRS value for the NSPS recovery furnaces

. Few recovery furnaces had a 99 th 

### percentile TRS value in excess of 5 ppm, including a unique system with a two

- si ded dry

- and wet

- bottom ESP. The 99 th 

### percentile values shown on this figure indicate that most of the NSPS recovery furnaces are achieving 5 ppm 99 percent of the time , regardless of APCD type

. Although the annual average of the TRS11 

### averaging periods (sho wn in Figure 5) seems to suggest that a limit lower than 5 ppm ( e.g., 3 ppm) is achieved, the 99 th 

### percentile TRS value in Figure 6 reflects the variability exhibited in each block average and affirms that a limit of 5 ppm provides for the variability in T RS expected from the best performing sources

. Figure 7 in Appen dix D investigates the e ffect on DCE recovery furnace TRS emissions i f multiple

- stage black liquor oxidation (BLO) is used prior to the DCE. Of the three NSPS DCE recovery furnaces, two units ha d two

- stage BLO systems and one ha d a single

- stage BLO system. A total of 12 recovery furnaces with data were indicated as single stage BLO (3 units with multiple stacks) and 1 4 recovery furnaces with T RS data were indicated to have two

- stage BLO, and four ha d three

- stage BLO systems

. The TRS data in Figure 7 are inconclusive as to whether multiple

- stage BLO systems reduce TRS emissions better than single

- stage systems. Most of the BLO systems did not achieve the 5 ppm NSPS limit.

Figures 8 and 9 expl ore the impact of burning NCGs. Figure 8 shows the impact of burning NCGs on the annual TRS average and Figure 9 shows the impact on the 99 th 

### percentile. B urning NCGs did not appear to significantly increase recovery furnace TRS emission s , but it did indic ate an increase in the potential for TRS emissions variability as evidenced by the greater range in 99 th 

### percentiles for the NCG

- burning NDCE furnaces in Figure 9

. Monitoring allowance evaluation

. As shown in Figure 4, most recovery furnaces subject to the NSPS have achieved a 5 ppm TRS limit with one percent or less monitoring deviations during normal operations and startup and shutdown periods . The TRS CEMS data shown i n Figure 4 include periods of startup and shutdown , and show that many mills comply with the TRS limit in spite of startup and shutdown periods. The TRS CEMS data were reviewed closely to determine the impact of removal of the SSM exemption in 40 CFR 60.284(e)(1) and continuous application of the 5 ppm limit to startup and shutdown period s in addition to normal operations. Periods of malfunction and process downtime ( i.e., when BLS firing ceases) were excluded from consideration because these are not valid operating periods for rulemaking. The TRS CEMS data reveal that some exceedances of a 5 ppm limit falling within the one percent monitoring allowance are associated with periods of startup and shutdown. To ensure that the standard is continuous, an upper limit ( i.e.
, a cap) should be determined. Table D

- 1 in Appendix D shows the CEMS data for periods of startup and shutdown. After removing the extreme values for reasons noted in the table , 30 ppm appears to be a representative cap for the one percent monitoring allowance.

During periods of startup and shutdown, the EPA observed that corr ected TRS concentrations may be grossly inflated as a result of the oxygen correction equation. As the stack gas concentration approaches ambient conditions, the denominator of the oxygen correction equation becomes very small, leading to an oxygen correct ed concentration that is artificially high, such that an otherwise compliant TRS measurement can exceed the applicable concentration because it is corrected for oxygen. Table D

- 2 in Appendix D shows this inflation. One solution to this issue would be to allow uncorrected, actual TRS values to be used during periods of startup and shutdown for compliance for periods when the oxygen concentration is greater than 15 percent

.12 

### Recommendation

. Based on the TRS data presented in this section, it can be con cluded that DCE recovery furnaces would not be expected to reliably meet the current NSPS limit of 5 ppm

. It would also be expected that the current NSPS (at baseline) would require that new recovery furnaces be NDCE furnaces and modified or reconstructed DCE recovery furnaces to convert to NDCE technology. We did not project any new DCE recovery furnaces being constructed in our analysis

. The figures presented i n Appendix D support a regulatory decision to mainta in a TRS limit of 5 ppm with a one percent m onitoring allowance for recovery furnaces. To ensure the TRS standard is a continuous standard (consistent with the decision in of the D.C. Circuit Court of Appeals decision in Sierra Club v. EPA

, 551 F.3d 1019 (D.C. Cir. 2008) ), the monitoring allowance can be capped at 30 ppm which is representative of the upper limit achieved by most recovery furnaces. Because the TRS CEMS data analyzed include startup and shutdown periods (in addition to normal operational periods), there is no need for a separate sta ndard during periods of startup and shutdown.

C. Lime Kiln TRS CEMS Analysis

TRS limit evaluation

. Lime kiln TRS emiss ions are limited to 8 ppm at 10 percent O 2 

### by the kraft pulp mills NSPS. All of the lime kiln TRS ppm values discussed in this section reflect conditions at 10 percent O 2 

### . Figures 1 through 7 in Appendix E present TRS C E MS summary data for each lime kiln (1 unit with multiple stacks, for a total of 112 data sets)

. Most of the data points shown in these figures reflect 12

- hour average CEMS data sets

. However, 6 of the 112 lime kiln CEMS data sets were based on 24

- hour averages. The 24

- hour averages are annotated on the graphs where appropriate

. The figures in Appendix E distinguish between lime kilns subject to the NSPS and non

- NSPS kilns because there were several lime kilns that are not currently subject to the 8 ppm NSPS limit (but are more likely held to the 20 ppm emission guideline) , and therefore, exceeded 8 ppm

. Figure 1 shows all of the lime kiln CEMS data sets for NSPS and non

- NSPS kilns based on air pollution control device type: ESP, ESP followed by a scrubber (ESP/SCBR), and SCBR

. The 24

- hour average data sets were noted and fe ll within the scatter of the 12

- hour average data
sets

. We observe d that control device performance overlaps
, and that ESP/SCBR systems f e ll within the scatter of the ESP

- alone and SCBR

- alone systems

. With no clear distinction in TRS by control device
, it is expected that process fact ors ( e.g., mud washing, use of uncontaminated scrubber water , and NCG burning) have a greater effect on lime kiln TRS emissions tha n control device type

. Most of the lime kilns achieved the 8 ppm limit on an annual average basis

. However, compliance is bas ed on each 12

- hour block averaging period so the percentage of averaging periods in excess of 8 ppm was plotted in Figure 2. Several scrubbers and two non

NSPS ESPs exceeded 8 ppm for a relatively high percentage of averaging periods

.

The non

- NSPS kilns w ere removed from the remaining figures in Appendix E in order to more clearly examine lime kilns that are required to meet 8 ppm

. In F igure 3
, it can be observed that the NSPS kilns met the 8 ppm limit regardless of control device. Most of the kilns were operating with roughly a 4 ppm compliance margin below the 8 ppm limit based on annual average

. Figure 4 shows the percentage of averaging periods exceeding 8 ppm for the lime kilns subject to NSPS. There is no monitoring allowance for lime kiln TRS CEMS data in the NSPS ( e.g., any average that is an exceedance can be considered as a violation)

. Many of the NSPS13 

### kilns ( 32 of 60 ) achieved zero exceedances of the 8 ppm limit regardless of control device type

. Even some well

- controlled kilns had a few exceeda nces of the 8 ppm limit. We note that startup and shutdown periods were included in the percentages of averaging periods that exceeded 8 ppm. Startup and shutdown periods would be subject to the 8 ppm emission limit, while malfunctions can be handled with affirmative defense provisions. T he scrubber

- controlled kilns appear to be the most challenged to remain below 8 ppm

. Figure 5 considers the 99 th 

### percentile of the averaging periods for each kiln subject to the NSPS

. Most of the kilns consistently achieved 8 ppm 99 percent of the time regardless of control system

. Figure 5 shows that most of the kilns use the compliance margin afforded by the 8 ppm limit in order to remain in compliance and that a new source limit more stringent than 8 ppm would be difficult for well

- controlled kilns to meet consistently

. A lower limit would reduce the compliance margin and there is no clear technological basis for achieving a lower TRS limit. While ESP/ SCBR

- controlled kilns all remained below the 8 ppm limit, their 99 th 

### percentile performance was within the range of that achieved by the lime kilns with ESP or scrubber control only.

Figure 6 shows the 99 th 

### percentile for NSPS kiln s based on combustion of NCGs. While NCGs can contribute to TRS (if not properly combus ted), there does not appear to be any clear distinction in the TRS performance of NCG

- burning kilns versus non

- NCG burning kilns. NCG

burning kilns with white liquor pre

- scrubbers have similar TRS emissions to NCG

- burning kilns without pre

- scrubbers. Figur e 7 shows the percent of periods exceeding the TRS 8 ppm limit for lime kilns based on NCG burning. NCG burning appears to result in the potential for additional process v ariability.

Monitoring allowance evaluation

. As shown in Figure 4, most lime kilns s ubject to the NSPS have achieved the 8 ppm TRS limit with one percent or less monitoring deviations in spite of startup and shutdown periods. The TRS CEMS data were reviewed closely to determine the impact of removal of the SSM exemption in 40 CFR 60.284(e)(1) and continuous application of the 8 ppm limit to startup and shutdown periods in addition to normal operations. Periods of malfunction and process downtime ( i.e., when lime mud charging ceases) were excluded from consideration because these a re not valid operating periods for rulemaking. As shown in Appendix E , 12

- hour average CEMS data sets providing startup and shutdown detail were available for 31 lime kilns controlled by ESP and subject to the NSPS. Upon review of these data
sets , we obser ved that a 12

- hour block can either be partially or completely affected by startup or shutdown periods. Up to 113 of a possible 730 annual 12

- hour averaging periods were affected by startup and shutdown

. On average it takes a lime kiln 24 hours to startup and 12 hours to shu tdown

. 2 

### Of the 31 data sets with startup and shutdown indicated, 20 of the data sets contained no exceedances of the 12

- hour 8 ppm limit. Thus, compliance with the 8 ppm limit during startup and shutdown has been demonstrated at some mil ls

. However, for 11 other kiln s compliance with the 8 ppm TRS limit during startup and shutdown has not been adequately demonstrated because these kiln s experienced exceedances in up to eight 12

- hour blocks affected by startup and

2 Memorandum from K. Hanks, and C. Gooden, RTI International to K. Spence and B. Schrock, EPA. Review of Pulp and Paper Information Collection Request ( ICR) Responses Pertaining to Startup and Shutdown of Subpart BB Equipment

. March 22, 2013.14 

### shutdown. Eight of 730 po ssible 12

- hour blocks in a year corresponds to 1.1 percent of possible averaging periods (8/730 = 1.1%)

. This percentage of averaging periods affected by startup and shutdown is consistent with the information in Figure 4 which shows 51 of 60 NSPS kilns in compliance with the 8 ppm TRS limit in all but one percent of averaging periods.

Table E

- 1 in Appendix E shows the maximum TRS 12

- hour average ppm values occurring during startup and shutdown where there were exceedances of the 8 ppm standard. Where avai lable for the higher

- end values, 1

- hour TRS data sets corresponding with the 12

- hour averages were reviewed to determine the nature of the TRS emissions during the startup and shutdown events. Most of the high

- end values were determined not to be represent ative for rulemaking purposes. The two 12

- hour TRS concentrations corrected to 10 percent O 2 

### that appeared to be representative of startup and shutdown events were both 22 ppm. Similarly, for
most NSPS kilns, the 99 th 

### percentile 12

- hour average during all time periods (including startup and shutdown) was less than 20 ppm as shown in Figure 5. Therefore, an upper limit 12

- hour average of 22 ppm appears to be representative of the TRS concentration that has been achieved in practice during startup and shutdown events.

As discussed for recovery furnaces, d uring periods of startup and shutdown, the EPA observed that corrected TRS concentrations may be grossly inflated as a result of the oxygen correction equation. As the s tack gas concentration approaches ambient conditions, the denominator of the oxygen correction equation becomes very small, leading to an oxygen corrected concentration that is artificially high, such that an otherwise compliant TRS measurement can exceed the applicable concentration because it is corrected for oxygen. See T able D

- 2. It is recommended that EPA propose to allow uncorrected, actual TRS values to be used during periods of startup and shutdown for compliance for periods when the oxygen
concentr ation is greater than 15 percent

.

Recommendation

. To summarize, the current 8 ppm TRS limit based on a 12

- h ou r average with a one percent monitoring allowance during which time emissions must not exceed 22 ppm is recommended as the continuous lime kiln T RS standard

. T h is has been achieved in practice

. The one percent monitoring allowance (not to exceed 22 ppm) is recommended to adjust the current 8 ppm limit (with no allowance) for removal of the startup and shutdown exemption. This option balances the requirement for a continuous emission standard whil e providing for the operational variability expected from mills under normal, startup, and shutdown conditions. It is also recommended that periods of zero kiln throughput (zero lime production) be clarified as

non

- operational periods, and that a provision be added to the rule to state that the uncorrected TRS concentration can be considered when O 2 

### is near ambient conditions during startup or shutdown.

D. Lime Kiln COMS Analysis

Opacity limit evaluation

. The kraft pulp mills NSPS does not set an opacity limit for lime kilns because scrubbers were the dominant technology in 1978 and 1986 when the NSPS were originally promulgated and revised, respectively . However, the EPA received COMS data for lime kilns that ha d installed ESPs and were required to monitor opacity under subpart MM.15 

### Subpart MM requires continuous opacity monitoring for lime kilns and specifies 20 percent as the opacity limit for both new and existing kilns. Subpart MM contains an opacity monitoring allowance where 6 perce nt of the 6

- minute opacity averages per quarter may exceed the 20 percent limit without being considered an exceedance.

A total of 29 COMS data sets were graphed (including multiple data sets for two kilns with separate COMS for duel stacks) and are provi ded in Appendix F

. The majority (25) of the COMS data sets graphed were 6

- minute averages. Two data sets represented hourly averages.

Figure 1 in Appendix F presents the annual average of the opacity readings for each lime kiln. The highest annual average observed was 8 percent, well below the 20 percent MACT limit, however, compliance is based on each averaging period and not the annual average. The 99 th 

### percentile of opacity is shown in Figure 2 based on APCD type. Lime kilns controlled with ESP and ESP/ scrubber systems consistently achieved 20 percent opacity . The COMS for ESP/scrubber systems were usually placed between the ESP and scrubber . Two units exceeded the 20 percent opacity, but further investigation shows they did not exceed 20 percent for mor e than the 6 percent monitoring allowance.

Monitoring allowance evaluation

. Figure 3 in Appendix F shows the percent of averaging periods in excess of 20 percent opacity . A ll but three kilns consistently achieved 20 percent opacity with less than 1 percen t of averaging periods in exceedance of 20 percent . Further investigation into these three units show that removal of data labeled as process downtime and malfunction resulted in two of the units achieving 20 percent opacity with a 1 percent monitoring allowance. In summary, it is recommended that a 20 percent opacity limit with a 1 percent monitoring allowance is adequately demonstrated. Continuous compliance with the NSPS PM standards can be demonstrated through monitoring of control device operating parameters (e.g. ESP secondary voltage and current or power) during times when the 2 percent monitoring allowance is invoked. Because the data analyzed in arriving at the recommendation included startup and shutdown periods, there is no need for a separate standard for startup and shutdown periods.

E. Analysis of TRS CEMS Data for Other Emission Units

TRS limit evaluation

. As shown in Table 1, TRS CEMS data were submitted with the ICR for four kraft mill processes emitting non

- condensable gas es

. T he 12

- hour average TRS CEMS data sets were reviewed for these systems

. As for the lime kiln and recovery furnace TRS CEMS data sets, zero emissions values measured during process downtime and negative emissions were removed

. Emissions measured during startup and shutdown were retained.

The NCG source CEMS data sets were analyzed for maximum and 99 th 

### percentile TRS averages . These units included a pulp washer, a boiler, and two thermal ox idizers. The pulp washer data were prov ided as actual (uncorrected) TRS emissions because the oxygen correction is not required for non

- combustion sources. The boiler was characterized as backup control for low

- volume high

- concentration ( LVHC ) and high

- volume low

- concentration i ncineration that16 

### wa s used when the recovery fu rnace (primary control device) wa s not operational. The two thermal oxidizers were used to burn LVHC and stripper off gas streams. These units exhibited 99 th 

### percentile TRS values from 1.33 ppm to 3.88 ppm , but also exhibited maximum values of approximately 5 ppm (4.4, 4.8, and 4.9 ppm ) up to 16 ppm

.

Recommendation

. Based on this limited amount of data, it appears that the current NSPS limit of 5 ppm is the appropriate limit for each of these operations

.17 

### Table 1

. TRS CEMS Data for Kraft Pulping Processes Emitting NCGs

RTI Code NEI ID Emission Unit ID Process Type APCD Type APCD ID NCG sources controlled Notes Max TRS ppmdv @ 10% O 2 99 th Percentile TRS ppmdv @ 10% O 2 1

186 NEI18334 HWCHEM Pulp Washer Hardwood Chemiwasher Scrubber FL34 and HWCHME Washer Because this is a non

combustion control, the ppmdv is provided at the actual oxygen content of the untreated (undiluted) gas stream

. 4.4 3.29

198 NEI41565 016 Boiler unspecified 016_CD Backup control for digester and washer (NSPS units); also O 2 delig and decker According to Part I, Boiler 016 serves as the backup control device for HVLC control when the primary control device (recovery furnace) is not operational. 4.8 1.61

242 NEI34066 AA

- 016 TO Scrubber

- packed bed RC

- 22 condensate stripper, evaporator, turpentine, and digester LVHC 4.9 1.33

112 NEI34064 LVHC01, LVHC02, LVHC03 TO Scrubber

- packed bed AA

- 113 Digester, evaporator, turpentine, and condensate stripper 16 3.88 1. Calculated as the average of the 12

- hr aver a g e va lues provided including startup and shutdown

.

### A

- 1 

## APPENDIX A: Summary of Recovery Furnace Data Received

### A

- 2 S ummary of Recovery Furnace Data Received
RTI + Emission Unit ID Opacity Data Type TRS Data Type Comments on Data

100.037A 6

- min averages 1 2

- hr averages Provided raw TRS data

- corrected to 8% O 2 . Calculated 12

- hr average TRS from 1

- hour data. 102.RB10 6

- min averages 12

- hr averages

103.G

- 158 6

- min averages 1 2

- hr averages Calculated 12

- hr average TRS from 1

- hour data. 104.EUG D6 data not provided not provided
105.EU445C 6

- min averages 12

- hr averages
105.EU445A unit down unit down

107.08

- P1 6

- min averages 1 2

- hr averages Calculated 12

- hr average TRS from 1

- hour data. 108.RB3 6

- min averages 12

- hr averages

109.RB4 6

- min averages 12

- hr averages O 2 correction values were not 8%, assumed TRS values were raw data and corrected

109.RB3 6

- min averages 12

- hr averages O 2 correction values were not 8%, assumed TRS values were raw data and corrected

111.G

- 44 6

- min averages 1

- hr averages Calculated 12

- hr average TRS from 1

- hour data. 112.AA

- 100 6

- min averages 12

- hr averages

114.U500 6

- min averages 12

- hr averages 115.RE01 6

- min averages 12

- hr averages Unit has opacity data for 2 stacks

116.003 6

- min averages 12

- hr averages
117.B21 data in pdf form not provided Opacity data not tabulated 119.EQT010 6

- min averages 12

- hr averages 119.EQT008 data not provided not provided
120.F7 6

- min averages 12

- hr averages
121.000013 6

- min averages 12

- hr averages
121.000014 6

- min averages 12

- hr averages

124.001 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks
124.019 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks
126.RECOV 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks

127.REC1 6

- min averages 1 2

- hr averages Unit has opacity data for 2 stacks

. O 2 correction values were not 8%, assu med TRS values were raw data and corrected

. Calculated 12

- hr average TRS from 1

- hour data. 130.1 6

- min averages 12

- hr averages
130.2 6

- min averages 12

- hr averages
130.3 6

- min averages 12

- hr averages
131.5 6

- min averages 12

- hr averages

### A

- 3 RTI + Emission Unit ID Opacity Data Type TRS Data Type Comments on Data

131.6 6

- min averages 12

- hr averages
132.4RB hourly average 12

- hr averages
132.5RB hourly average 12

- hr averages Unit has opacity data for 2 stacks

133.10 6

- min averages 12

- hr averages
135.003

- 1 6

- min averages 12

- hr averages
136.EU 005 6

- min averages 12

- hr averages

137.189 data not provided provided as .doc TRS data not tabulated
137.721 data not provided provided as .doc TRS data not tabulated
138.002 6

- min averages 12

- hr averages
139.02 6

- min averages 12

- hr averages
140.55 6

- min averages 24

- hr averages 142.CU7216 6

- min averages 12

- hr averages
142.CU7214 6

- min averages 12

- hr averages
142.CU7215 6

- min averages 12

- hr averages

143.7000 hourly average 1 2

- hr averages TRS raw data reported

- corrected to 8%

. Calculated 12

- hr average TRS from 1

- hour data.

143.7010 hourly average 1 2

- hr averages Calculated 12

- hr average TRS from 1

- hour data.

143.7020 hourly average 1 2

- hr averages Calculated 12

- hr average TRS from 1

- hour data. 145.55 6

- min averages 12

- hr averages
145.54 6

- min averages not provided
146.16 6

- min averages 12

- hr averages
146.8 data not provided 12

- hr averages
147.14 6

- min averages 12

- hr averages Unit has opacity data for 2 stacks
147.5 6

- min averages 12

- hr averages

148.001 6

- min averages 1 2

- hr averages Calculated 12

- hr average TRS from 1

- hour data.

148.007 6

- min averages 1 2

- hr averages Calculated 12

- hr average TRS from 1

- hour data. 149.B011 6

- min averages 12

- hr averages
150.CREC

- 1 6

- min averages 12

- hr averages

151.REC004 6

- min averages 12

- hr averages TRS data contained "<1" instead of decimal values 151.REC007 6

- min averages 12

- hr averages
152.03 data not provided 12

- hr averages
153.EQT 0065 not surveyed not surveyed Mill was closed during the development of the survey (reopened in 2010) 154.P36 6

- min averages 12

- hr averages

### A

- 4 RTI + Emission Unit ID Opacity Data Type TRS Data Type Comments on Data

154.P37 6

- min averages 12

- hr averages P39 and P37 have own WBESP but vent to combined stack with single COMS (2 TRS CEMS)

154.P39 6

- min averages 12

- hr averages P39 and P37 have own WBESP but vent to combined stack with single COMS (2 TRS CEMS) 155.RECOVERY FURNACE provided as .doc provided as .doc Not tabulated.

156.RF18 unit down unit down
156.RF19 6

- min averages 12

- hr averages
156.RF22 6

- min averages 12

- hr averages
157.RB2 6

- min averages 12

- hr averages

159.F3 data not provided provided as .pdf Not tabulated.
162.381A 6

- min averages 12

- hr averages
162.382A 6

- min averages 12

- hr averages

163.RF2904 6

- min averages 12

- hr averages TRS data contained "<1" instead of decimal values

163.RF1901 6

- min averages 12

- hr averages TRS data contained "<1" instead of decimal values, O 2 correct was reported as 10%, corrected to 8%

164.B08 6

- min averages not provided Flue gases from B08 and B10 combine and then split into 2 ESPs

164.B10 6

- min averages not provided Flue gases from B08 and B10 combine and then split into 2 ESPs 165.000013 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks
165.000006 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks
166.RB01 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks
166.RB02 data not provided 12

- hr averages
167.005RB 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks
169.04 6

- min averages 12

- hr averages
169.05 6

- min averages 12

- hr averages

171.002 6

- min averages 12

- hr averages O 2 correction not reported as 8%, assumed raw TRS data and corrected

171.003 6

- min averages 12

- hr averages O 2 correction not reported as 8%, assumed raw TRS data and corrected

171.004 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks, O 2 correction not reported as 8%, assumed raw TRS data and corrected 172.RB01 6

- min averages 12

- hr averages
172.RB02 6

- min averages 12

- hr averages
173.RECOVB 6

- min averages not provided Unit has opacity data for 2 stacks
174.G

- 32 6

- min averages 12

- hr averages

### A

- 5 RTI + Emission Unit ID Opacity Data Type TRS Data Type Comments on Data

174.G

- 92 6

- min averages not provided Unit has opacity data for 2 stacks
175.RB3A 6

- min averages 12

- hr averages
175.RB2A 6

- min averages 24

- hr averages

176.RB7 6

- min averages 12

- hr averages
177.EU0804 6

- min averages 12

- hr averages
178.08P012 6

- min averages 12

- hr averages
178.08P013 6

- min averages 12

- hr averages

179.RF3 6

- min averages 12

- hr averages TRS data contained "<1" instead of decimal values

180.D001 6

- min averages 1 2

- hr averages Calculated 12

- hr average TRS from 1

- hour data. 181.50 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks
181.10 6

- min averages not provided Unit has opacity data for 2 stacks
182.037 6

- min averages 12

- hr averages

183.002 6

- min averages 12

- hr averages O 2 correction not reported as 8%, assumed TRS raw data and corrected
184.72 6

- min averages 12

- hr averages
184.73 6

- min averages 12

- hr averages
185.02 data not provided 12

- hr averages
186.RB15 6

- min averages 12

- hr averages
188.014RB1 6

- min averages 24

- hr averages
188.016RB2 6

- min averages 24

- hr averages

189.SN26 6

- min averages 12

- hr averages

190.R400 6

- min averages 12

- hr averages R400 and R401 appear to each have a DBESP that vent through a comment stack (opacity represents combined total)

190.R401 6

- min averages 12

- hr averages R400 and R401 appear to each have a DBESP that vent through a comment stack (opacity represents combined total) 190.R402 6

- min averages 12

- hr averages Unit has opacity and TRS data for 2 stacks
195.003 6

- min averages 12

- hr averages
196.SN

- 06 6

- min averages 12

- hr averages
196.SN

- 14 6

- min averages 12

- hr averages
197.2 data not provided not provided

198.019 highest 6

- min average per hour 1 2

- hr averages Calculated 12

- hr average TRS from 1

- hour data. 199.002 6

- min averages 12

- hr averages

200.007RF2 highest 6

- min average per hour 12

- hr averages Unit has opacity data for 2 stacks

200.007RF3 highest 6

- min average per hour 12

- hr averages Unit has opacity data for 2 stacks

### A

- 6 RTI + Emission Unit ID Opacity Data Type TRS Data Type Comments on Data

201.SR0001 6

- min averages not provided 202.Recovery Furnace EU320 6

- min averages 12

- hr averages

203.RF#2 6

- min averages 12

- hr averages
203.RF#3 6

- min averages 12

- hr averages
205.009 6

- min averages 12

- hr averages Unit has opacity data for 2 stacks
206.G

- 32 6

- min averages 12

- hr averages
206.G

- 31 6

- min averages 12

- hr averages

207.038 6

- min averages 12

- hr averages Uni t has opacity data for 2 stacks. O 2
co r rection was not reported as 8%, assumed to be raw TRS data and corrected 226.RECB2 6

- min averages 12

- hr averages
226.RECB1 6

- min averages not provided Unit has opacity data for 2 stacks

240.RF04 6

- min averages 12

- hr averages TRS data contained "<1" instead of decimal values

240.RF01 6

- min averages 24

- hr averages TRS data contained "<1" instead of decimal values

242.AA

- 011 6

- min averages 12

- hr averages O 2 correction reported as 5%

- corrected to 8% 243.R407 6

- min averages 12

- hr averages
243.R401 6

- min averages 24

- hr averages Unit has opacity and TRS data for 2 stacks

340.005 6

- min averages 12

- hr averages O 2 cor r ection was not reported as 8%, assumed to be raw TRS data and corrected
525.EU18 6

- min averages 12

- hr averages
531.RF15 6

- min averages 12

- hr averages
600.G0803 6

- min averages 12

- hr averages
600.G0806 6

- min averages 12

- hr averages

606.RB2 6

- min averages 12

- hr averages
606.RB3 6

- min averages 12

- hr averages
606.RB4 6

- min averages 12

- hr averages

610.4 6

- min averages 12

- hr averages Units 4 and 5 utilize a single stack with 1 COMS

610.5 6

- min averages 12

- hr averages Units 4 and 5 utilize a single stack with 1 COMS 613.001 6

- min averages not provided Unit has opacity data for 2 stacks
613.002 6

- min averages not provided Unit has opacity data for 2 stacks
615.24 6

- min averages 12

- hr averages Unit has opacity data for 2 stacks
617.B14 6

- min averages 12

- hr averages
208228535.001 6

- min averages 12

- hr averages
208228535.007 6

- min averages 12

- hr averages

### B

- 1 

## APPENDIX B: Summary of Lime Kiln Data Received

### B

- 2 Summary of Lime Kiln Data Received RTI + Emission Unit ID Opacity Data Type TRS Data Type Comments On Data

100.115 6

- min averages 12

- hr average
102.LK 6

- min averages 12

- hr average

103.G

- 165 NA 1 2

- hr average TRS values reported as corrected to 8%. Converted values to 10% correction. Calculated 12

- hr average TRS from 1

- hour data. 104.EUG E7 not provided not provided

105.EU455 6

- min averages 12

- hr average TRS values reported as corrected to 8%. Converted values to 10% correction. 107.11

- P14 6

- min averages 12

- hr average

108.LK1 NA not provided

109.LK1 6

- min averages 12

- hr average TRS O 2 correction not r eported as 10%. Assumed data were raw and corrected to 10%

. 111.G

- 35 not provided 1 2

- hr average Calculated 12

- hr average TRS from 1

- hour data.
112.AA

- 110 not provided 12

- hr average

114.U800 6

- min averages 12

- hr average
115.LK01 6

- min averages 12

- hr average

116.001 NA 12

- hr average
117.P36 NA not provided
119.EQT006 NA 12

- hr average TRS values reported as corrected to 8%. Converted values to 10% correction. 120.M18 NA 12

- hr average
120.M19 NA 1

- hr average Calculated 12

- hr average TRS from 1

- hour data.
121.000011 NA 12

- hr average
124.004

- 1 NA 12

- hr average

126.LK not provided 12

- hr average Unit has TRS data for 2 stacks

127.LK1 6

- min averages 1 2

- hr average TRS O 2 correction not r eported as 10%. Assumed data were raw and corrected to 10%. Calculated 12

- hr average TRS from 1

- hour data.

127.LK2 6

- min averages 1 2

- hr average TRS O 2 correction not r eported as 10%. Assumed data were raw and corrected to 10%

. Calculated 12

- hr average TRS from 1

- hour data. 130.4 NA 12

- hr average
130.5 NA 12

- hr average
131.18 NA 24

- hr average
131.16 NA 12

- hr average
132.21LK4 1

- hour average 12

- hr average
133.14 NA 12

- hr average
133.15 NA 12

- hr average
135.004

- 1 NA 12

- hr average

### B

- 3 RTI + Emission Unit ID Opacity Data Type TRS Data Type Comments On Data

136.EU 033 6

- min averages 12

- hr average

137.511 not provided provided as .txt Did not tabulate
137.512 not provided provided as .txt Did not tabulate
138.001 NA 12

- hr average
139.04 NA 12

- hr average
140.32 NA 24

- hr average
142.P6025 NA 12

- hr average
142.P6009 NA 12

- hr average

143.6063 hourly average 1 2

- hr average Raw TRS was provided, corrected data to 10%

. Calculated 12

- hr average TRS from 1

- hour data. 145.001 NA not provided

146.6 NA 12

- hr average
146.30 6

- min averages 12

- hr average
147.3 NA 12

- hr average
147.55 not provided 1 2

- hr average Calculated 12

- hr average TRS from 1

- hour data.
148.003 NA 1 2

- hr average Calculated 12

- hr average TRS from 1

- hour data.
148.009 6

- min averages 1 2

- hr average Calculated 12

- hr average TRS from 1

- hour data.
149.P001 NA 12

- hr average
150.CAU

- 12 NA 12

- hr average
151.CP002 NA 12

- hr average
151.CP001 NA 12

- hr average

152.08 NA not provided 153.EQT 0053 NA not surveyed Mill was not surveyed
154.P30 6

- min averages 12

- hr average 155.LIME

KILN NA provided as .doc Did not tabulate

156.143100 NA 12

- hr average
156.145000 NA 12

- hr average

156.LK5 6

- min averages 12

- hr average
157.KILN NA 12

- hr average

159.F4 NA provided as .pdf Did not tabulate

162.371A NA 12

- hr average
162.372A 6

- min averages 12

- hr average
163.LK1501 NA 12

- hr average Data contained "<1" instead of decimal values
163.LK2502 NA 12

- hr average Data contained "<1" instead of decimal values

164.P12 NA 12

- hr average TRS O 2 correction not r eported as 10%. Assumed data were raw and corrected to 10%

. 165.000019 NA 12

- hr average

### B

- 4 RTI + Emission Unit ID Opacity Data Type TRS Data Type Comments On Data

165.000002 NA 12

- hr average
166.LK01 NA 12

- hr average
166.LK02 NA 12

- hr average
167.004LK NA 12

- hr average
169.03 NA 12

- hr average

171.010 NA 12

- hr average TRS O 2 correction not r eported as 10%. Assumed data were raw and corrected to 10%

. 171.009 NA 12

- hr average TRS O 2 correction not r eported as 10%. Assumed data were raw and corrected to 10%

. 172.LK03 NA 12

- hr average
173.LK1 NA not provided
174.G

- 18 6

- min averages 12

- hr average
174.G

- 95 NA not provided
175.LK1A NA 24

- hr average
175.LK2A NA 12

- hr average

176.G

- 5 NA 24

- hr average
177.EU0905 NA 12

- hr average 178.09P037 6

- min averages 12

- hr average

179.LK3 6

- min averages 12

- hr average Data contained "<1" instead of decimal values
180.L001 NA 1

- hr average Calculated 12

- hr average TRS from 1

- hour data.
180.L002 NA 1

- hr average Calculated 12

- hr average TRS from 1

- hour data.

181.01 NA not provided
181.14 NA not provided

183.004 NA 12

- hr average TRS O 2 correction not r eported as 10%. Assumed data were raw and corrected to 10%. 184.LK1 NA 12

- hr average
184.LK2 not provided 12

- hr average

185.07 NA 12

- hr average
186.LK 6

- min averages 12

- hr average

188.001LK1 NA 24

- hr average CEMS reported to be from all 3 kilns, repeated values for the 3 units.

188.002LK2 NA 24

- hr average CEM S reported to be from all 3 kilns, repeated values for the 3 units.

188.003LK3 NA 24

- hr average CEM S reported to be from all 3 kilns, repeated values for the 3 units. 189.SN25 NA 12

- hr average
190.L600 NA 12

- hr average
190.L601 NA 12

- hr average
195.002 NA 12

- hr average

### B

- 5 RTI + Emission Unit ID Opacity Data Type TRS Data Type Comments On Data

196.SN

- 09 NA 12

- hr average
196.SN

- 02 6

- min averages 12

- hr average
197.1 NA not provided
198.004 NA 1 2

- hr average Calculated 12

- hr average TRS from 1

- hour data.
199.011 NA 12

- hr average 200.007_10 6

- min averages 12

- hr average 201.SR0003 NA not provided 202.Lime Kiln EU340 NA 12

- hr average

203.LKScr NA 12

- hr average

205.008 NA 12

- hr average
206.G

- 37 NA 12

- hr average
206.G

- 38 NA 12

- hr average
207.103A NA not provided
226.LK1 NA not provided
226.LK2 NA not provided

240.CA81 6

- min averages 12

- hr average TRS d ata contained "<1" instead of decimal values 242.AA

- 013 not provided 12

- hr average

243.LG07 not provided 12

- hr average

340.008 NA 12

- hr average TRS O 2 correction not r eported as 10%. Assumed data were raw and corrected to 10%

. 525.EU17 NA 12

- hr average
531.LK7 not provided 12

- hr average
600.G0903 NA 12

- hr average
600.G0905 NA 12

- hr average
600.G0908 NA 12

- hr average

606.LK4 6

- min averages 12

- hr average

610.7 NA 12

- hr average
610.8 NA 12

- hr average
613.009 NA 12

- hr average
615.21 NA 12

- hr average
617.P22 6

- min averages 12

- hr average
208228535.003 NA 12

- hr average
208228535.009 6

- min averages 12

- hr average

### C

- 1 

## APPENDIX C : Recovery Furnace Opacity Data

### C

- 2 0 2 4 6 8 10 12 14 16 18Annual Average Opacity (including exceedances) 

### Figure 1. Annual Average Opacity

- DCE vs. NDCE Calculated as the average of the 6

- min averaging periods.* Note that compliance is based on each 12

- hour average, not the annual average.

DCE NDCE *Three mills provided maximum 6

- min average for each hour, and 5 mills provided hourly averages. These averages are all within the range of the 6

- minute averages provided.

### C

- 3 0 2 4 6 8 10 12 14 16 18Annual Average Opacity (including exceedances) 

### Figure 2. Annual Average Opacity

- DCE vs. NDCE (Showing APCD) Note that compliance is based on each 12

- hour average, not the annual average.

DCE

- DBESP DCE

- DBESP

- WPR

DCE

- WBESP NDCE

- DBESP

NDCE

- DBESP

- WPR NDCE

- DBESP

- WPR/DBESP/DBESP

NDCE

- DB

- WBESP [2

- sided dry and wet] NDCE

- WBESP

### C

- 4 0 2 4 6 8 10 12 14 16 18Annual Average Opacity (including exceedances) 

### Figure 3. Annual Average Opacity

- APCD Note that compliance is based on each 12

- hour average, not the annual average.

DBESP DBESP

- WPR DBESP

- WPR/DBESP/DBESP DB

- WBESP [2

- sided dry and wet]
WBESP

### C

- 5 0 5 10 15 20 25 30 35 40 45 5099th Percentile of Opacity (%) 

### Figure 4. 99th Percentile of Opacity

- DCE vs. NDCE

DCE NDCE Current NSPS opacity limit = 35%

MM action level = 20%

### C

- 6 0 5 10 15 20 25 30 35 40 45 5099th Percentile of Opacity (%) 

### Figure 5. 99th Percentile of Opacity

- DCE vs. NDCE (Showing APCD)

DCE

- DBESP DCE

- DBESP

- WPR

DCE

- WBESP NDCE

- DBESP

NDCE

- DBESP

- WPR NDCE

- DBESP

- WPR/DBESP/DBESP

NDCE

- DB

- WBESP [2

- sided dry and wet] NDCE

- WBESP Current NSPS opacity limit = 35%

MM action level = 20% Highest 6

- min average provided for each

### C

- 7 0 5 10 15 20 25 30 35 40 45 5099th Percentile of Opacity (%) 

### Figure 6. 99th Percentile of Opacity

- APCD

DBESP DBESP

- WPR

DBESP

- WPR/DBESP/DBESP DB

- WBESP [2

- sided dry and wet]

WBESP Current NSPS opacity limit = 35%

MM action level = 20%

### C

- 8 0% 1% 2% 3% 4% 5% 6% 7%Percent of Averaging Periods Exceeding 35% 

### Figure 7. Percent of Averaging Periods Exceeding 35%

- DCE vs. NDCE

DCE NDCE Current NSPS Monitoring Allowance = 6% of averages exceeding 35% opacity

### C

- 9 0% 1% 2% 3% 4% 5% 6% 7%Percent of Averaging Periods Exceeding 35% 

### Figure 8. Percent of Averaging Periods Exceeding 35%

- DCE vs. NDCE (Showing APCD)

DCE

- DBESP DCE

- DBESP

- WPR

DCE

- WBESP NDCE

- DBESP

NDCE

- DBESP

- WPR NDCE

- DBESP

- WPR/DBESP/DBESP

NDCE

- DB

- WBESP [2

- sided dry and wet] NDCE

- WBESP Current NSPS Monitoring Allowance = 6% of averages exceeding 35% opacity

Highest 6

- min average provided for each hour

### C

- 10 0% 1% 2% 3% 4% 5% 6% 7%Percent of Averaging Periods Exceeding 35% 

### Figure 9. Percent of Averaging Periods Exceeding 35%

- APCD

DBESP DBESP

- WPR
DBESP

- WPR/DBESP/DBESP DB

- WBESP [2

- sided dry and wet]
WBESP Current NSPS Monitoring Allowance = 6% of averages exceeding 35% opacity

Highest 6

- min average provided for each hour

### C

- 11 0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10%Percent of Averaging Periods Exceeding 20% 

### Figure 10. Percent of Averaging Periods Exceeding 20%

- DCE vs. NDCE

DCE NDCE Note: One non

- NSPS NDCE with DBESP exceeding 20% opacity for 27.6% of time omitted from chart.

### C

- 12 0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10%Percent of Averaging Periods Exceeding 20% 

### Figure 11. Percent of Averaging Periods Exceeding 20%

- DCE vs. NDCE (Showing APCD)

DCE

- DBESP DCE

- DBESP

- WPR

DCE

- WBESP NDCE

- DBESP

NDCE

- DBESP

- WPR NDCE

- DBESP

- WPR/DBESP/DBESP

NDCE

- DB

- WBESP [2

- sided dry and wet] NDCE

- WBESP Note: One non

- NSPS NDCE with DBESP exceeding 20% opacity for 27.6% of time omitted from chart.

### C

- 13 0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10%Percent of Averaging Periods Exceeding 20% 

### Figure 12. Percent of Averaging Periods Exceeding 20%

- APCD

DBESP DBESP

- WPR DBESP

- WPR/DBESP/DBESP DB

- WBESP [2

- sided dry and wet] WBESP Note: One non

- NSPS NDCE with DBESP exceeding 20% opacity for 27.6% of time omitted from chart.

### D

- 1 

## APPENDIX D : Recovery Furnace TRS Data

### D

- 2 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18TRS, ppmdv @ 8% O2 

### Figure 1. Annual Average of the TRS Averaging Periods (NSPS and Non

- NSPS Furnaces) Values are mostly 12

- hr averages, with some 24

- hr averages for non

- NSPS units.

Note that compliance is based on each 12

- hr average, not the annual average.

DCE NDCE Current NSPS limit for straight RF (DCE and NDCE) = 5 ppm @ 8%O2 Emission guidelines (8% O2) = 5 ppm for NDCE and 20 ppm for DCE

### D

- 3 0 5 10 15 20 25 30TRS, ppmdv @ 8% O2 

### Figure 2. 99th Percentile of the TRS Averaging Periods (NSPS and Non

- NSPS Furnaces) Values are mostly 12

- hr averages, with some 24

- hr averages for non

- NSPS units.

DCE NDCE Current NSPS limit for straight RF (DCE and NDCE) = 5 ppm @ 8%O2 Emission guidelines (8% O2) = 5 ppm for NDCE and 20 ppm for DCE Two 99th percentile outliers omitted: non

- NSPS DCE (126 ppm), and NSPS NDCE (43 ppm)

1

### D

- 4 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Percent of Averaging Periods, % 

### Figure 3. Percent of TRS Averaging Periods in Excess of 5 ppmdv @ 8% O2 (NSPS and Non

- NSPS Furnaces) Values are mostly 12

- hr averages, with some 24

- hr averages for non

- NSPS units.

DCE NDCE Emission guidelines (8% O2) = 5 ppm for NDCE and 20 ppm for DCE

Current monitoring allowance forrecovery furnace TRS is 1%. Non

- NSPS Non

- NSPS

Non

- NSPS

Non

- NSPS

### D

- 50%0.3%0%0.3%0%0%0%1%1%0.3%1%1%0%0%7%0.1%0%0%3%0%2%0%0.3%2%0%0.1%0%0.1%0%0.3%0.3%0%0%0%0%0%0%0%0%0%0%0.1%0%0%0%0%0%0%0%1%0%0%0%0%0%0.3%2%0%0%0%0%0%1%3%0%1%0.3%0.5%0.4%0.1%1%0%0%0.3%0%0%0%0%
0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10%Percent of Averaging Periods, % Figure 4. Percent of TRS 12

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

DCE NDCE Current monitoring allowance forrecovery furnace TRS is 1%. One NSPS DCE with 46% of averaging periods exceeding 5 ppmdv is omitted from the graph.

### D

- 6 0 1 2 3 4 5 6 7TRS, ppmdv @ 8% O2 

### Figure 5. Annual Average of the 12

- hour TRS Averaging Periods by APCD (NSPS Furnaces) Note that compliance is based on each 12

- hr average , not the annual average.

DCE WBESP DCE WBESP/SCBR NDCE DBESP NDCE DBESP

- WPR NDCE DB

- WBESP NDCE WBESP Current NSPS limit for straight RF (DCE and NDCE) = 5 ppm @ 8%O2 Emission guidelines (8% O2) = 5 ppm for NDCE and 20 ppm for DCE

### D

- 7 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15TRS, ppmdv @ 8% O2 

### Figure 6. 99th Percentile of the 12

- hour TRS Averaging Periods by APCD (NSPS Furnaces)

DCE WBESP DCE WBESP/SCBR NDCE DBESP NDCE DBESP

- WPR NDCE DB

- WBESP NDCE WBESP Current NSPS limit for straight RF (DCE and NDCE) = 5 ppm @ 8%O2 One 99th percentile omitted: NSPS NDCE (43 ppm)

### D

- 8 0 5 10 15 20 25TRS, ppmdv @ 8% O2 

## Figure 7. Comparison of the 99th Percentile of the TRS Averaging Periods for DCE Recovery Furnaces with Multiple Stages of Black Liquor Oxidation

1 stage 2 stage 3 stage *NSPS units are indicated by the hollow data points.

### D

- 9 0 1 2 3 4 5 6 7TRS, ppmdv @ 8% O2 Figure 8. Annual Average of the 12

- hour TRS Averaging Periods for NSPS Furnaces With and Without NCG Burning Note that compliance is based on each 12

- hr average , not the annual average.

DCE (No NCG) NDCE (No NCG) NDCE Burning NCG Current NSPS limit for straight RF (DCE and NDCE) = 5 ppm @ 8%O2

### D

- 10 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15TRS, ppmdv @ 8% O2 Figure 9. 99th Percentile of the 12

- hour TRS Averaging Periods for NSPS Furnaces With and Without NCG Burning

DCE (No NCG) NDCE (No NCG) NDCE Burning NCG Current NSPS limit for straight RF (DCE and NDCE) = 5 ppm @ 8%O2

### D

- 11 Table D

- 1: TRS CEMS Data Sets for Recovery Furnaces with Exceedances of the 5 ppm Limit During Startup and Shutdown (based on a 12

- hour average) 1

RF type ID Highest TRS ppm during S/S N ote Control NSPS
NDCE 119.EQT010 45.22 * C ould not recreate with 1 hour data DBESP Yes

NDCE 127.REC1 102.84 * U ncorrected for O2; associated with 0 production at 19.15% O2

. No other valid values reported during startup/shutdown WBESP Yes
DCE 130.2 16.66 WBESP No
NDCE 132.5RB 25.57 DBESP

- WPR Yes
DCE 145.55 16.3 WBESP No
NDCE 148.001 18.92 DBESP No
NDCE 149.B011 29.62 Production was CBI; labeled as startup/shutdown DBESP Yes
DCE 151.REC007 39 DBESP No

NDCE 157.RB2 72.6 * 15.3 C orresponded to 0 production

. Highest not associated with 0 production was 15.3 WBESP No

NDCE 186.RB15 48.2 (malf) * 15.9 48.2 was “startup malfunction.” N ext highest startup was 15.9 DBESP Yes
NDCE 189.SN26 27.34 WBESP Yes
DCE 205.009 17.61 WBESP No
DCE 600.G0803 16 WBESP Yes *This value was disregarded for the reason provided in the “Note” column. The value was not considered as representative for rulemaking purposes.

### D

- 12 Table D

- 2 : TRS CEMS Data Corrected Based on Various Oxygen Levels for Lime Kilns and Recovery Furnaces

Recovery Furnace TRS Raw Data Lime Kiln TRS raw data O 2 reading Recovery Furnace TRS Corrected to 8% O 2 Lime Kiln TRS Corrected to 10% O 2 5 8 0 3.1 5.0 5 8 5 4.1 6.5 5 8 6 4.3 6.9 5 8 7 4.6 7.4 5 8 8 5.0 8.0 5 8 9 5.4 8.7 5 8 10 5.9 9.5 5 8 11 6.5 10.4 5 8 12 7.2 11.6 5 8 13 8.1 13.0 5 8 14 9.3 14.9 5 8 15 10.8 17.3 5 8 16 13.0 20.8 5 8 17 16.3 26.0 5 8 18 21.7 34.7 5 8 19 32.5 52.0 5 8 20 65.0 104.0 5 8 20.5 130.0 208.0 5 8 20.999 65000.0 104000.0

### E

- 1 

## APPENDIX E : Lime Kiln TRS Data

### E

- 2 0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0TRS, ppm at 10% O2 

## Figure 1. Annual Average TRS CEMS Data for Lime Kilns (Including non

- NSPS Kilns)

- Calculated as the average of the values for each 12

- or 24

- hr averaging period

- Note that compliance is based on each individual averaging period, not the annual average.

ESP ESP/SCBR SCBR Current NSPS Limit = 8 ppm at 10% O2

24

- hr average points have orange outline.

### E

- 3 0% 10% 20% 30% 40% 50% 60% 70% 80% 90%Percent of averageing periods exceeding 8 ppm 

### Figure 2. Percent of Periods Exceeding TRS 8 ppm Limit for Lime Kilns (Including non

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

ESP ESP/SCBR SCBR

### E

- 4 0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0TRS, ppm at 10% O2 

# Figure 3. Annual Average TRS CEMS Data for Lime Kilns (NSPS Kilns Only)

- Calculated as the average of the values for each 12

- or 24

- hr averaging period

- Note that compliance is based on each individual averaging period, not the annual average.

ESP ESP/SCBR SCBR Current NSPS Limit = 8 ppm at 10% O2

All are based on 12

- hr averaging period except for first scrubber.

### E

- 50%0%0%0.29%0%0%0.42%1.2%0%0%1.7%0%1.0%0%4.0%0.0%0.15%0%0%1.0%0.22%0%0%0%0%0%0.15%0.14%0.14%0.0%0.0%11.1%0.41%2.8%5.6%0.32%0%0.58%4.1%0%0%22.8%0%0.27%0%0.14%0%0%0%0%0%0.28%0%0%0.14%0%0.27%0.15%0%

0% 5% 10% 15% 20% 25%Percent of averageing periods exceeding 8 ppm 

## Figure 4. Percent of Periods Exceeding TRS 8 ppm Limit for Lime Kilns (NSPS Kilns Only) Note: The NSPS has no allowance for lime kiln TRS (e.g., any average that is an exceedance is a violation).

ESP ESP/SCBR SCBR All are based on 12

- hr averaging period except for first scrubber.

### E

- 6 0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0TRS, ppm at 10% O2 

### Figure 5. 99th Percentile of TRS CEMS Data Averaging Periods for Lime Kilns (NSPS Kilns Only)

ESP ESP/SCBR SCBR Current NSPS Limit = 8 ppm at 10% O2 2 NSPS kilns with 99th percentile exceeding 100 are omitted from this chart (1 ESP and 1 SCBR) .

All are based on 12

- hr averaging period except for first scrubber.

### E

- 7 0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0TRS, ppm at 10% O2 

### Figure 6. 99th Percentile of TRS CEMS Data Averaging Periods for Lime Kilns Burning NCGs (NSPS Kilns Only)

No NCG NCG Pre

- scrubbed NCG Current NSPS Limit = 8 ppm at 10% O2

All are based on 12

- hr averaging period except for first value. 2 NCG

- burning kilns with 99th percentile exceeding 100 are omitted from this chart.

### E

- 80.0%0.41%0%0%0%0.0%0%0.15%0%0%0%0%1.0%0.0%0%0%0%0%11.1%0.29%2.8%5.6%0%4.1%0%0.42%1.2%0%1.7%0%0%22.8%1.0%0%0%0.14%0%0%0%0%0.28%0.14%0.14%0%0.27%0.14%0.15%0%0%0%4.0%0.27%0%0.22%0%0%0.15%0.58%0.32%

0% 5% 10% 15% 20% 25%Percent of averageing periods exceeding 8 ppm 

## Figure 7. Percent of Periods Exceeding TRS 8 ppm Limit for Lime Kilns (NSPS Kilns Only) Note: The NSPS has no allowance for lime kiln TRS (e.g., any average that is an exceedance is a violation).

No NCG NCG Pre

- scrubbed NCG All are based on 12

- hr averaging period except for first value.

### E

- 9 Table E

- 1. TRS CEMS Data Sets for Lime Kilns Subject to NSPS Subpart BB with Exceedances of the 8 ppm Limit During Startup and Shutdown (based on a 12

- hour average) 1

Emission Unit ID APCD Type No. of S/S Periods No. of Periods Exceeding 8 ppm During S/S Max ppm TRS during S/S Events Comments

107.11

- P14 ESP 8 2 67.9* 10.8 • Likely invalid data. 12

- hour block contained one 899 ppm spike followed by negative 1

- hour readings. Actual O2 data unavailable; unclear if O2 correction inflated the ppm

.
• Next highest 12

- hr value was 10.8

ppm.

109.LK1 ESP 20 5 2,853* 397* 21.7 • Mill had two consecutive high TRS 12

- hr averages. The raw 12

- hr values were 167 and 49 ppm which inflated to 2,853 and 397 with the O2 correction. Uncorrected 12

- hr averages this high were not considered representative for rulemaking.

• Next highest 12

- hr value was 21.7

ppm. 146.6 SCBR 1 1 10.0 147.3 SCBR 9 2 17.8 148.009 ESP 1 3 7.4

151.CP002

SCBR (NCG scrubbers pre

- kiln

+ LK ESP] 7 2 37.0* 1

- hr data do not show 37 ppm

. It is unclear how the 37

- ppm 12

- hr average reported was derived because the highest 1

- hr value for that block was 10.9 ppm

. Data set not considered further.

151.CP001 14 8 57.0* 43.0*

22 • Data anomaly. Only one hourly value of 57 ppm was included in the 12

- hr average because process down time for the other 11 hours is excluded

.
• The 2 nd highest value of 43 ppm was

associated with 0 production.

• The 3 rd highest value was 22 ppm

• Actual O2 data unavailable; unclear if

O2 correction inflated th e ppm. 180.L002 SCBR 85 2 10.2

186.LK ESP/SCB R 68 1 8.1 203.LKScr SCBR 83 2 10.4 240.CA81 ESP 10 1 9.0

1. Not shown in the table are 20 additional lime kilns that had no exceedances of the 8 ppm TRS standard during startup or shutdown. *Not considered representative for rulemaking purposes.

### F

- 1 

## APPENDIX F : Lime Kiln Opacity Data

### F

- 2 0 1 2 3 4 5 6 7 8 9Annual Average Opacity, % 

## Figure 1. Lime Kiln Annual Average Opacity Calculated as the average of the 6

- min averaging periods for all COMS data sets (except one hourly average set).



### ESP ESP/SCBR

### F

- 3 0 5 10 15 20 25 3099th Percentile Opacity, % 

## Figure 2. 99th Percentile of Lime Kiln COMS Data Sets Calculated as the 99th percentile of the 6

- min averaging periods for all COMS data sets (except one hourly average set).



### ESP ESP/SCBR MACT violation level = 20% opacity for more than 6% of quarterly operating time

### F

- 4 0% 1% 2% 3% 4% 5% 6%Averaging Periods Exceeding Opacity Level, % 

## Figure 3. Percent of Lime Kiln COMS Averaging Periods Exceeding Various Levels Calculated as the 99th percentile of the 6

- min averaging periods

ESP ESP/SCBR MACT allowance = 6% of quarterly operating