Date: August 2, 2011 

Subject: Papermaking Technology Review Information Received from State Contacts 

EPA Contract No. EP-D-07-019; Work Assignment No. 4-09 

From: Veronica Hanzel 

To: John Bradfield 

Bill Schrock 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

The U.S. Environmental Protection Agency (EPA) is reviewing the national emission standards 

for hazardous air pollutants (NESHAP) for the Pulp and Paper Industry (40 CFR part 63, subpart 

S) as required by section 112(d)(6) of the Clean Air Act (CAA). The purpose of this 

memorandum is to present technology review information received through contacts to State 

agencies. 

Review of EPA’s RACT/BACT/LAER Clearinghouse (RBLC) indicated that several facilities 

have received Best Available Control Technology (BACT) determinations for papermaking 

operations (e.g., paper machines) under the new source review (NSR) permitting program. 

Many of these determinations involved some type of process change (e.g., use of additives with 

low volatile organic compound (VOC) content). Because the RBLC only lists the results of 

permitting determinations, States were contacted in order to obtain more-detailed documentation 

of the BACT determinations including data on emission reduction techniques considered, 

estimated emissions reductions, costs, and other environmental impacts. Of nine States 

contacted, information was received from seven States: 

 Arkansas Department of Environmental Quality provided excerpts from the PSD preliminary 

determinations for paper machines at the Georgia Pacific Corporation, Crossett Paper 

Operations facility under permit No. 597-AOP-R10. No information was available for 

Permit No. 597-AOP-R3. 

 Georgia Department of Natural Resources provided excerpts from the Prevention of 

Significant Air Quality Deterioration Review of Inland Paperboard and Packaging, Inc. – 

Rome Linerboard Mill Located in Floyd County, Georgia, Preliminary Determination, SIP 

Permit Application No. 14756. 
2

 Michigan Department of Environmental Quality provided excerpts from the PSD Preliminary 

Determination for paper machines at the Mead Corporation, Escanaba Paper Company, under 

Permit No 40022. 

 Oklahoma Department of Environmental Quality provided the following documents: 

o Memorandum, June 12, 2006 regarding Evaluation of Construction Permit Application No. 

99-113-C (M-4)(PSD), Fort James Operating Company, Muskogee Mill. 

o Memorandum, October 12, 2004 regarding Evaluation of Permit Application No. 97-057-C 

(M-4) PSD, Weyerhaeuser Company Valliant Paper Mill. 

 Tennessee Divisions of Air Pollution Control provided an excerpt from the PSD Preliminary 

Determination for the Packaging Corporation of America, Counce Mill, Permit No. 953059P. 

 Texas Commission on Environmental Quality provided an excerpt from the PSD review for 

Inland Paperboard and Packaging, Orange Mill, Permit No PSD-TX-684M1/9654A/833M1. 

 Wisconsin Department of Natural Resources provided the following documents: 

o Analysis and Preliminary Determination for the Construction and Operation Permits for 

the Proposed Modification of De-Inking, Bleaching, and Tissue/Towel Manufacturing for 

SCA Tissue North America, Permit #03-DCF-346. 

o Analysis and Preliminary Determination for the Construction and Operation Permits for 

the Proposed Modification of Paper Machines Nos. 26 and 24, Thermo-mechanical 

Pulping and a Dry Material Unloading Process for Stora Enso North America – Biron 

Mill Permit #02-DCF-124. 

o Analysis and Preliminary Determination for the Construction and Operation Permits for 

the Proposed Modification of Wood Yard, Wood Room, Pulping Processes Bleaching 

Processes, Stock Preparation, Papermaking Processes and Water Treatment Processes for 

Stora Enso North America – Whiting Mill Permit #02-DCF-039. 

o Analysis and Preliminary Determination for the Construction and Operation Permits for 

the Proposed Modification of the Paper Machine Complexes #16, #13, and #14 for 

Wisconsin Rapids Paper Mill, Permit #02-DCF-144. 

o Analysis and Preliminary Determination for the Construction and Operation Permits for 

the Proposed Modification of the Paper Machine #12 and Stock Preparation (Corenso 

Division) for Stora Enso – Wisconsin Rapids Paper Mill, Permit #05-DCF-312. 

o Analysis and Preliminary Determination for the Construction and Operation Permits for 

the Proposed Construction of Paper Machine No. 16 Complex (Furnish/Coating 

Emissions), a Steam Condenser and Modification of Four Paper Machines (Nos. 12, 13, 

14 and 16) for Consolidated Papers, Inc. Wisconsin Rapids Division, Permit #00-DCF058. 

o Analysis and Preliminary Determination for the Construction and Operation Permits for 

the Proposed Construction of Paper Manufacturing for Appleton Coated LLC – 

Combined Locks Mill, Permit #06-DCF-204. 
3

o Analysis and Preliminary Determination for the Construction and Operation Permits for 

the Proposed Modification of Paper Machine #6 for Paper and Allied Products 

Manufacture for Appleton Coated LLC – Combined Locks Mill, Permit #04-DCF-069. 

o Analysis and Preliminary Determination for the Construction and Operation Permits for 

the Proposed Modification of Paper Machine #7 (including trim handling), Off Machine 

Coating and Broke Handling for Appleton Coated LLC – Combined Locks Mill, Permit 

#02-DCF-170. 

The information obtained from the states is included in Attachment A. Table 1 summarizes the 

technologies considered and conclusions of the five-step BACT analysis. A number of control 

technologies were considered and rejected in these BACT analyses for paper machines, and in 

nearly all cases, BACT was determined to be some form of work practice involving low-emitting 

additives/materials. The following control systems were usually considered to be technically 

infeasible for paper machine vents in Step 2 of the BACT analyses: biofiltration, combustion in 

an onsite boiler, condensation, and carbon concentration. Carbon adsorption and water 

absorption (or wet scrubbing) were considered technically infeasible is some cases and 

technically feasible in other cases under Step 2. Where considered technically feasible, these 

technologies were deemed economically infeasible in Step 4. Thermal oxidation (e.g., in and 

RTO), catalytic oxidation, and flaring were considered technically (but not economically) 

feasible. Work practices involving new substance review programs, use of low-emitting 

additives/materials, and/or good combustion were determined to be technically and economically 

feasible and were selected as BACT. 

 
RBLC

Code FACILITY_NAME State PERMIT_NUM

Date of

Determination PROCESS_NAME

EMISSION

_LIMIT_1

EMISSION

_

LIMIT_1_U

NIT

EMISSION_LIMIT_

1_AVG_TIME_CON

DITION

CASE‐BY‐

CASE_BASIS

EMISSION_

LIMIT_2

EMISSION

_

LIMIT_2_U

NIT

EMISSION_LIMIT_

2_AVGERAGE_TIM

E_CONDITION PROCESS_

PAPER MACHINE #3 0.31 LB

FINE PAPER MACHINE #1

AND #2

0.89 LB

VOC/MDT,

NO. 1

0.54 LB

VOC/MDT,

NO. 2

MACHINE DRIED

TONS, 30‐DAY

AVERAGE

PAPER MACHINE #4 2.47

PAPER MACHINE #5 3.37

PAPER MACHINE #6 2.48

PAPER MACHINE #7 1.78

PAPER MACHINE #8 1.29

30.241,30.290

GEORGIA PACIFIC ‐ CROSSETT PAPER AR 597‐AOP‐R3 April, 2001 TISSUE MACHINE 6.8 LB/T lb/machine dried to BACT‐PSD 66.2 LB/H Existing plant, sources are ne

increase production by 250 t

Modification exceeds PSD sig

PM10, VOC, CO and NOx. Tis

Through Air Drying (TAD) tec

Source not installed yet. BAC

based on mass balance of ad

MDT=Machine dried tons.

Source not installed yet. BAC

based on mass balance of ad

DT=Machine dried tons.

30.211,30.290

INLAND PAPERBOARD ANDPACKAGING, INC. ‐ ROME LINERBOARD

MILL

GA 2631‐115‐0021‐

V‐01‐4

Oct., 2003 KRAFT PULP MILLS ‐ 

LINERBOARD MACHINES

0 SEE NOTE BACT‐PSD 2600 MACHINE DRIED TONS 

30.241 MEAD CORPORATION/ESCANABA

PAPER COMPANY

MI 40422 Nov., 2000 PAPER MACHINE, NO. 4,

VALMET

30.241 EMISSION BASED

ON 0.2 LB/T

VOC 0.2 LB/T VOC LIMIT INCLUDES ADDITI

WELL AS PULP. PRODUCT LIM

PER YEAR

LB

VOC/MDT

Table 1. Summary of Paper Machine BACT Analyses Received from State Contacts

30.210,30.211,30.219,30.240,30.241

GEORGIA‐PACIFIC CORPORATION ‐ 

CROSSETT PAPER OPERATIONS

AR 597‐AOP‐R10 Oct, 2006 MACHINE DRIED

TONS, 30‐DAY

Average

BACT‐PSD REVISED VOC ESTIMATES US

APPROACH. LIMIT IS BASED THROUGHPUT UNIT.

Table is two pages wide. Table 1 
PROCESS_NAME

PAPER MACHINE #3

FINE PAPER MACHINE #1

AND #2

PAPER MACHINE #4

PAPER MACHINE #5

PAPER MACHINE #6

PAPER MACHINE #7

PAPER MACHINE #8

TISSUE MACHINE

KRAFT PULP MILLS ‐ 

LINERBOARD MACHINES

PAPER MACHINE, NO. 4,

VALMET

e Contacts BACT Analysis

Step 1 ‐ Identify All Available Control

Technologies Step 2 ‐ Eliminate Technically Infeasible Options Step 3 ‐ Ranking Technically Feasible Control Alternatives Step 4 ‐ Evaluation 

Considered Good work practices, RTO All options technically feasible. Rank Control Technology CE

1 Good Work Practices Not available2 RTO 95 ‐ 98%

Good work practices includes p

sent to linerboard machine.No oxidation control listed in RB

set, varied greatly; costs for RTO 

which is large (2.3M acfm fro 64 

investment $60M, operating $1

estimated did not include costs 

RTO. Also very high fuel costs e

content. RTO not considered e

considered, increase in NOx em

gas.

Regenerative thermal oxidation

Recuperative thermal oxidation/afterburner

Catalytic incineration

Zeolite adsorption/Concentration

Carbon Adsorption

Wet Scrubber ‐ absorption

CondensationCombustion within mill boilers

Work Practice Standards

Thermal oxidation was determined to be technically feasible, however,

auxiliary fuel costs would be high.

Carbon adsorption was determined technically infeasible.

Absorption (wet scrubber) determined technically infeasible.

Combustion within mill boilers was determined not to be feasible due to

air flow volume.

Condensation determined to be technically infeasible.

Work practices such as reuse of whitewater, low VOC additives, and

recycle of off‐specification paper were determined to be technically

feasible.

Rank Control Technology CE

1 Good Work Practices Not available

2 RTO 95 ‐ 98%

Economic analysis only on recu

oxidation. Catalytic oxidation w

economic feasibility and becaus

undemonstrated on paper mac

Cost analysis based on 335,000 

VOC emissions and does not inc

technology itself.Total capital costs ‐ $850K to $4

$8.1M, and CE $179K to $320K/

Carbon adsorption

BiofiltrationRecuperative or regenerative thermal oxidizer

Low‐VOC or water‐borne materials

Carbon adsorption would be impeded by PM/PM10 content of gas

stream (would clog filter) and reduce VOC removal efficiency. However,

technically feasible if PM/PM10 were removed first.

Biofiltration not a tested technology for paper making industry; no

application of this technology for VOC control in paper making machines.

Typically used for much lower volume exhaust air flows than the # 6

paper machine (630,000 acfm). Biofiltration equipment requires a large

footprint of space. Estimated to need 400' X 50' for air flow for this

machine. Therefore, due to size /space requirement. Different

configurations considered. Still too large for practical applications. Also

dryer exhaust would be too hot for microorganisms. Determined not

technically feasible for use on paper machines.

Recuperative or regenerative thermal oxidizer is technically feasible.

Costs estimated for regenerative TO as it would be a better selection

(more cost effective)

Use of water‐borne chemicals or low‐VOC chemicals, reduction

dependent on ratio of current VOC materials and new VOC materials;

not all these can perform as effectively as the higher VOC chemicals;

process sensitive to changing chemicals due to customer specs for

product. Other than cleaners, highest VOC contributor is wet strength

resin or release agents. Important that the machines can use different

VOC content materials to make different products.

RTO ‐ 98+% CE

RCO ‐ 95+% CE

Carbon adsorption with PM removal ‐ 90+% CE

Low VOC or Water‐borne chemicals ‐ Varied

Annualized cost for RGTO 1.24 

At 99% reduction, CE would be 

Annualized cost for RCO 2.7M; 

Both considered too high to jus

assumed to be much higher bec

controlled is actually higher tha

Determined economically infea

Carbon adsorption cost estimat

mostly removed and assuming 

would not interfere with CA sys

115.7 tpy and CA system assum

sots for installation and operati

removal at 8.3K/ton. This estim

since assumption is based on tw

case. Considering much higher 

capturing all VOC emissions, co

costs did not include removal o

necessary. Not feasible for one 

machines. Determined to be ec

Many of chemicals used curren

VOC emissions come from use o

cleaners. Mill has a New Substa

VOC content, helps to assure us

available without compromising 

Table is two pages wide. Table 1 
RBLC

Code FACILITY_NAME State PERMIT_NUM

Date of

Determination PROCESS_NAME

EMISSION

_LIMIT_1

EMISSION

_

LIMIT_1_U

NIT

EMISSION_LIMIT_

1_AVG_TIME_CON

DITION

CASE‐BY‐

CASE_BASIS

EMISSION_

LIMIT_2

EMISSION

_

LIMIT_2_U

NIT

EMISSION_LIMIT_

2_AVGERAGE_TIM

E_CONDITION PROCESS_

Table 1. Summary of Paper Machine BACT Analyses Received from State Contacts

30.200 WEYERHAEUSER ‐‐ VALLIANT OK 97‐057‐C (M‐

4) PSD

May, 2004 PAPER MACHINE 0 SEE NOTE BACT‐PSD PERMIT FOR NEW CONSTRUC

OF EXISTING EQUIPMENT.

PAPER MACHINE

COMBUSTION #11‐14

1.7 T/YR EACH BACT‐PSD 

PAPER MACHINE 202 T/YR COMBINED BACT‐PSD 

3971 Paper Packaging of America, COUNCE

MILL

TN 953059P May, 2002 PAPER MACHINES 1258.8 T/YR 12‐month roll avg BACT‐PSD PSD PERMIT RESULTING FRO

NEEDED TO COMPLY WITH M

UNDER 40 CFR 63, SUBPART 

INCREASED CAPACITY. THE IRESULTED IN PSD SIGNIFICAN

SO2, CO, VOC, NOX, H2SO4, 

NO. 2 PAPER MACHINE 32.3 LB/H LAER 141.6 T/YR

NO. 1 PAPER MACHINE 26.7 LB/H BACT‐PSD 117 T/YR

30.211, TX Unknown212, 231,

239, 240,

241, 249,

290

INLAND PAPERBOARD AND PACKAGING

ORANGE MILL

PSD‐TX‐684M1/9654A/833M1

THE PURPOSE OF THE MILL I

TO INCREASE THE MILLS LINE

CAPACITY TO 2,340 MACHIN

DAY (MDTPD) BY INCREASING 

RATHER THAN AN INCREASE 

PRODUCTION.

30.290,490

MUSKOGEE MILL OK 99‐113‐C (M‐

3) PSD

Oct., 2005

Table is two pages wide. Table 1 
PROCESS_NAME

e Contacts

PAPER MACHINE

PAPER MACHINE

COMBUSTION #11‐14

PAPER MACHINE

PAPER MACHINES

NO. 2 PAPER MACHINE

NO. 1 PAPER MACHINE

BACT Analysis

Step 1 ‐ Identify All Available Control

Technologies Step 2 ‐ Eliminate Technically Infeasible Options Step 3 ‐ Ranking Technically Feasible Control Alternatives Step 4 ‐ Evaluation 

Thermal oxidation at 95+ % CE

Catalytic oxidation at 95+% Ce

Carbon Adsorption at 95 % CE

Biofiltration at 60‐90% CE

Wet Scrubber at varied CE

Good operating practices with case‐by‐case CE

‐No use of thermal oxidation for control of paper machines required. Is

technically feasible but flow rates are significantly large . USEPA

estimated annualized costs for regenerative thermal oxidizer at between

$8 and $33 per scfm; resulting in annualized cost greater than $20.5M

for control of 830 tpy at 95% CE, annualized cost effectiveness is more

than $26K per ton VOC. Also increased NOx from fuel burned; also costs

do not include large costs for capture equipment. Therefore

economically infeasible to use TO.

‐Same issues with catalytic oxidation (CO) except lower required energy

levels. No CO currently used or required. Is technically feasible. Costs

estimated to be higher capital costs; conservative estimate based on

thermal oxidizer costs; cost effectiveness for CO is at least $25K per ton;

also sensitivity to PM may be an issue for reliable operation; therefore

economically infeasible for CO.

‐Carbon adsorption (CA) is dependent on VOC being adsorbed, the

concentration of VOC and conditions of gas stream. Gas stream from

paper machines is water vapor saturated with low VOC concentration,

lower than optimum for CA range, therefore performance would be

poor. CA also poor choice for major VOC emitted, methanol. Without

chilling (which is very expensive and energy intensive), CA likely to have

very poor removal efficiency. Also not successfully demonstrated control

for paper machines. Conclusion is CA not technically feasible.

No technically or economically feasible control options available. No technically or economically 

Within company, control method is good

combustion practices

Within company ‐use of low‐VOC containing

chemicals or water‐borne chemical additives.

From RBLC ‐ limiting total VOC, or limiting the VOC

content of materials .

Use of water‐borne chemicals or low‐VOC chemicals, reduction

dependent on ratio of current VOC materials and new VOC materials;

determined to be technically feasible

Use of low or no VOC‐containing materials ‐ only technology

considered feasible

Company has in place a New Su

considered to be a pollution pre

performed.

No 5‐step analysis conducted Use of carbon adsorption or thermal oxidation was not considered to be

technically feasible because the exhaust of the VOC is at multiple

locations, each having a relatively low VOC concentration loading.

Review of RBLC database yielded no controls for 

paper machines. The 5‐step process was not

conducted.

Table is two pages wide. Table 1 
RBLC

Code FACILITY_NAME State PERMIT_NUM

Date of

Determination PROCESS_NAME

EMISSION

_LIMIT_1

EMISSION

_

LIMIT_1_U

NIT

EMISSION_LIMIT_

1_AVG_TIME_CON

DITION

CASE‐BY‐

CASE_BASIS

EMISSION_

LIMIT_2

EMISSION

_

LIMIT_2_U

NIT

EMISSION_LIMIT_

2_AVGERAGE_TIM

E_CONDITION PROCESS_

Table 1. Summary of Paper Machine BACT Analyses Received from State Contacts

#16 PAPER MACHINE

COMPLEX

0 BACT‐PSD PAPER MAKING MACHINE # 

UNDER THIS PERMIT. LIMITS 

PRIOR PERMIT. BACT IS USE 

UP AND COMPLIANCE DATES 

PAPERMAKING INGREDIENTS

THE PROCESS MAY NOT CON

#12 PAPER MACHINE 0 BACT‐PSD NO SUPPLEMENTAL NAT. GA

START UP AND COMPLIANCE 

THE PAPERMAKING INGREDIUSED IN THE PROCESS MAY N

PURCHASED, VO*

#13 PAPER MACHINE 0 BACT‐PSD DRYER NOT MODIFIED UNDE

LIMIT FOR ONLY PM10 & VO

START UP AND COMPLIANCE 

THE PAPERMAKING INGREDIUSED IN THE PROCESS MAY N

PURCHASED, VO*

#14 PAPER MACHINE 0 BACT‐PSD START UP AND COMPLIANCE 

THE PAPERMAKING INGREDI

USED IN THE PROCESS MAY N

PURCHASED, VO*

30.490 WHITING MILL WI 02‐DCF‐039 Mach 2003 PAPER MACHINE #64 W/

IN LINE COATER

0.0015 LB/LB LB VOC/LB ACS BACT‐PSD 0.9 LB/T LB VOC / TON

PAPER

P64, S64. ELECTRIC DRYER. 

PAPER MILL (TMP & STONE G

30.490 STORA ENSO NORTH AMERICA 00 WI ‐DCF‐058 May, 2000 

Table is two pages wide. Table 1 
PROCESS_NAME

e Contacts

#16 PAPER MACHINE

COMPLEX#12 PAPER MACHINE

#13 PAPER MACHINE

#14 PAPER MACHINE

PAPER MACHINE #64 W/

IN LINE COATER

BACT Analysis

Step 1 ‐ Identify All Available Control

Technologies Step 2 ‐ Eliminate Technically Infeasible Options Step 3 ‐ Ranking Technically Feasible Control Alternatives Step 4 ‐ Evaluation 

Considered RTO, CA, refrigerated condensers,

biofiltration, carbon collection (concentrator

system), water absorption/wet scrubber, TO,

catalytic and thermal incinerators, and flares.

CA technically feasible according to USEPA Air Compliance Advisor

(ACA).Refrigerated condensers not an applicable control technology according

to ACA, do not come in size necessary.

Biofiltration is not technically feasible due to large surplus land needed

that is not available.

Carbon collection systems ‐ not technically feasible due to specific

pollutants in the gas stream; methanol and acetaldehyde do not capture

well and would reduce overall efficiency.

Catalytic and thermal incinerators are technically feasible; needed to do

a cost estimate with low reliability due to high flow rates for air stream.

Water absorption is technically feasible and demonstrated technology.

Flares: self‐support and guy support flares determined to be technically

infeasible due to calculated height exceeds maximum for the control

technology; derrick support flares potentially applicable.

Catalytic incinerators at 95% CE

Carbon adsorbers at 95% CE

Thermal incinerators at 95% CE

Water absorption at 95% CE

RTO at 95% CE

Flares at 95% CE

Cost estimates:Catalytic incinerators; capital $

Carbon adsorbers; capital $1.6 

Thermal incinerators; capital $

Water absorption; capital $10.

RTO; capital $5.2 M, annual $2 

Flares; capital $3 M, annual $1

Table is two pages wide. Table 1 
RBLC

Code FACILITY_NAME State PERMIT_NUM

Date of

Determination PROCESS_NAME

EMISSION

_LIMIT_1

EMISSION

_

LIMIT_1_U

NIT

EMISSION_LIMIT_

1_AVG_TIME_CON

DITION

CASE‐BY‐

CASE_BASIS

EMISSION_

LIMIT_2

EMISSION

_

LIMIT_2_U

NIT

EMISSION_LIMIT_

2_AVGERAGE_TIM

E_CONDITION PROCESS_

Table 1. Summary of Paper Machine BACT Analyses Received from State Contacts

P40 ‐ PAPER MACHINE

#24 W/ COATER

0.22 LB/ADT OVERALL BACT‐PSD 0.0015 LB/LB LB/LB SOLIDS,

WATER BASED

COATING

Paper machine, coater, and 

P60 ‐ PAPER MACHINE

#26 W/ COATER

0.2 LB/ADT OVERALL BACT‐PSD 0.0015 LB/LB LB VOC/LB

SOLIDS, WATERBASED COATING

Coater: 40 mmbtu/h. Emissi

and coater are combined.

30.490 SENA BIRON MILL 02‐DCF‐124 Aug, 2002 

WI

Table is two pages wide. Table 1 
PROCESS_NAME

e Contacts

P40 ‐ PAPER MACHINE

#24 W/ COATER

P60 ‐ PAPER MACHINE

#26 W/ COATER

BACT Analysis

Step 1 ‐ Identify All Available Control

Technologies Step 2 ‐ Eliminate Technically Infeasible Options Step 3 ‐ Ranking Technically Feasible Control Alternatives Step 4 ‐ Evaluation 

Considered RTO, CA, refrigerated condensers,

Biofiltration, carbon collection/concentratorsystem, water absorption/wet scrubber, catalytic

and thermal incinerators, and flares.

RTO technically feasible and demonstrated technology, however, not

applied for paper machine processes.

Carbon canisters (gas adsorption) technically feasible and demonstrated

technology, however, not applied for paper machine processes.

Refrigerated condensers not an applicable control technology according

to ACA, do not come in size necessary

Biofiltration is not technically feasible due to large surplus land needed

that is not available

Carbon collection systems ‐ not technically feasible due to specific

pollutants in the gas stream; (methanol and acetaldehyde do not

capture well) and would reduce overall efficiency.

Catalytic and thermal incinerators were discussed as control technology

for destruction of VOCs but not as to the applicability to this process

water absorption/wet scrubber is not technically feasible due to low

VOC concentration in gas stream being below the 250 ppmv for

reasonable application and cost estimates.

Flares; were discussed control technology for destruction of VOCs but

not as to the applicability to this process

Catalytic incinerators at 95% CE

carbon adsorbers at 95% CE

Thermal incinerators at 95% CE

Water absorption at 95% CE

RTO at 95% CE

flares at 95% CE

Cost estimates:Catalytic incinerators; capital $

47K to 105KM/tonCarbon adsorbers; capital $4 to 

$20.9to 38K/tonThermal incinerators; capital $4

$62 to 137K/tonWater absorption; capital $429 

to 32.6M/tonRTO; capital $7.5 to 16M, annu

Flares; capital $4 to 5.5M, annu

Table is two pages wide. Table 1 
RBLC

Code FACILITY_NAME State PERMIT_NUM

Date of

Determination PROCESS_NAME

EMISSION

_LIMIT_1

EMISSION

_

LIMIT_1_U

NIT

EMISSION_LIMIT_

1_AVG_TIME_CON

DITION

CASE‐BY‐

CASE_BASIS

EMISSION_

LIMIT_2

EMISSION

_

LIMIT_2_U

NIT

EMISSION_LIMIT_

2_AVGERAGE_TIM

E_CONDITION PROCESS_

Table 1. Summary of Paper Machine BACT Analyses Received from State Contacts

WI P13/S13 ‐ PAPERBOARD

MACHINE

0 BACT‐PSD 8.4 MMBTU/H NAT. GAS; NO 

PRESS. APPLICATION COMPL

P14/S14 ‐ #14 PAPER

MACHINE W/ COATERS

0 BACT‐PSD NO NAT. GAS FIRED DRYERS 

ONLY). APPLICATION COMP

P82 / S82 ‐ PAPER

MACHINE #16 W/

COATERS

0 BACT‐PSD 25.9 MMBTU/H NAT. GAS DR

COMPLETE ON APRIL 30, 200

30.490 COMBINED LOCKS MILL WI 02‐DCF‐170 Dec., 2002 PAPER MACHINE #7,

COATINGS (P63 / S63)

0.61 LB/ADT lb VOC/ADT paper BACT‐PSD 0.0027 LB/GAL lb VOC/gal as

applied

THROUGHPUT IS T/D PAPER. 

7/23/03. MODIFICATION OF 

PAPER MACHINE #1

(S14/P40)

1.92 LB/ADT LB VOC / ADT 12

MO. AVG.

BACT‐PSD 3792 LB/MO. LB SOLVENT / MO.

12 MO. AVG.

TISSUE / TOWEL PAPER MAC

PULP); SOLVENT CLEANING (MMBTU/HR

PAPER MACHINE #2

(S15/P42)

3.37 LB/ADT LB VOC / ADT, 12

MO. AVG.

BACT‐PSD 8125 LB/MO 12 MO. AVG. THROUGHPUT IS T/D PAPER. 

P42); CLEANING SOLVENT AP

NEW AIR CAP DRYER (NAT. G

MMBTU/HR)TISSUE / TOWEL PAPER MAC

PULP)

PAPER MACHINE #3

(S16/P44)

1.88 LB/ADT LB VOC/ADT, 12

MO. AVG.

BACT‐PSD 56550 LB/MO LB SOLVENT/MO.,

12 MO. AVG.

THROUGHPUT IS T/D PAPER. 

(S16/P44); CLEAING SOLVEN

AND AIR CAP DRYER (NAT. G

MMBTU/HR)TISSUE / TOWEL PAPER MAC

PULP)

PAPER MACHINE #4

(S18/P46)

2.64 LB/ADT LB VOC/ADT BACT‐PSD 56550 LB/MO LB/MO SOLVENT,

12 MO. AVG

TISSUE / TOWEL PAPER MAC

PULP); SOLVENT CLEANING (DRYER: 54 MMBTU/HR

30.241 APPLETON COATED ‐ COMBINED LOCKS

MILL

WI 04‐DCF‐069 April, 2004 PAPER MACHINE #6

(S62A, P62A)

1.4 LB/ADT LB VOC/ADT, 12

MO. AVG.

BACT‐PSD 36 WT. % LIMIT ON

RETENTION AIDS

PAPER MACHINE #6, WITH N

PROJECT TO INCREASE (STEA

(PARTICULARLY FOR HEAVIER 

30.490 SCA TISSUE (MENASHA) 03‐DCF‐346 April, 2004 

WI

30.400, 490WISCONSIN RAPIDS PAPER MILL 02‐DCF‐144 April, 2002 

Table is two pages wide. Table 1 
PROCESS_NAME

e Contacts

P13/S13 ‐ PAPERBOARDMACHINEP14/S14 ‐ #14 PAPER

MACHINE W/ COATERS

P82 / S82 ‐ PAPER

MACHINE #16 W/

COATERSPAPER MACHINE #7,

COATINGS (P63 / S63)

PAPER MACHINE #1

(S14/P40)PAPER MACHINE #2

(S15/P42)PAPER MACHINE #3

(S16/P44)PAPER MACHINE #4

(S18/P46)PAPER MACHINE #6

(S62A, P62A)

BACT Analysis

Step 1 ‐ Identify All Available Control

Technologies Step 2 ‐ Eliminate Technically Infeasible Options Step 3 ‐ Ranking Technically Feasible Control Alternatives Step 4 ‐ Evaluation 

Considered oxidation (i.e. thermal or catalytic,

regenerative or recuperative), adsorption,

absorption , biofiltration and condensation systems

Due to low VOC concentration and variable VOC types, carbon

adsorption would not likely be an effective control and not considered to

be technically practical.

Carbon absorption systems (wet scrubber) was determined to be

technically impractical due to large surface area necessary to effect

absorption of the less soluble VOCs and the large volume of air flow.

Biofiltration is not a demonstrated technology and the technical

feasibility for this application is unknown, therefore the cost estimate,

was included, however additional testing and evaluation would be

necessary to confirm feasibility.

Condensation systems were determined technically infeasible due to

large air flow and low VOC concentration of gas stream.

Only oxidation (catalytic regenerative oxidation (CReO), catalytic

recuperative oxidation (CRuO), thermal regenerative oxidation

(TReO) and thermal recuperative oxidation(TRuO)) and biolfiltration

systems were considered to be technically feasible. Considered all

VOC emission points and groupings of VOC emission points (which

might be more feasible because it would increase VOC

concentrations) for cost evaluation. No ranking conducted on

control efficiency included.

Estimated costs:All sources;CReO capital $20.5M, annual $8

CReO capital $4.5M, annual $9.

TReO capital $14M, annual $10

TReO capital $1.3M, annual $14

BioFil capital $37.7M, annual $6

Costs were estimated for wet e

aftercoater dryer sources. Low

above, however lowest CE was 

which was still considered econ

Considered oxidation (i.e. thermal; regenerative or

recuperative or catalytic, fixed or fluid‐bed ),

adsorption, absorption , biofiltration and

condensation systems

Oxidation technologies are demonstrated and technically feasible

technologies.Due to low VOC concentration and variable VOC types, carbon

adsorption would not likely be an effective control and not considered to

be technically practical.

carbon absorption systems (wet scrubber) was determined to be

technically impractical due to large surface area necessary to effect

absorption of the less soluble VOCs and the large volume of air flow.

Bio‐scrubbing or biofiltration is not a demonstrated technology and the

technical feasibility for this application is unknown. In addition

biofiltration units typically require a large footprint to address air flow.

Therefore, bio‐scrubbing not considered to be technically feasible

technology.Condensation systems were determined technically infeasible due to

large air flow and low VOC concentration of gas stream.

Thermal oxidation, regenerative (TReO); at 99% RE

Thermal oxidation, recuperative (TRuo); at 98% RE

catalytic oxidation, fixed‐bed; at 95% RE

catalytic oxidation, fluid‐bed; at 94% RE

Biofiltration; at 65% RE

Venturi Scrubber ~35% RE

With the exception of good operating practice utilizing low‐VOC

chemicals, the effective technical applicability of the remaining

control options are questionable due to low VOC concentration

levels.

Estimated costs:TReO annualized capital and O&

TRuO annualized capital and O&

CReO annualized capital and O&

CRuO annualized capital and O&

BioFil annualized capital and O&

Venturi Scrubber annualized ca

All technologies evaluated were 

due to excessive costs and dele

Considered:RTO, carbon canisters (adsorption), refrigerated

condensers, biofiltration, carbon collection

(concentrator system), wet scrubber (water

absorption), thermal and catalytic incinerator, and

flares.

RTO technically feasible and demonstrated technology.

Carbon adsorption (gas adsorption) is a technically feasible and

demonstrated technology, would require a 2 or 3 bed system for

continuous duty cycle production.

Refrigerated condensers not an applicable control technology according

to ACA, do not come in size necessary.

Biofiltration is not technically feasible due to large surplus land needed

that is not available

Carbon collection systems ‐ not technically feasible due to specific

pollutants in the gas stream; (methanol and acetaldehyde do not

capture well) and would reduce overall efficiency.

Catalytic and thermal incinerators are technically feasible and

demonstrated technology, however flow rates for pollutant stream are

too high for cost equations and a scaled estimate of low reliability was

made.Water absorption/wet scrubber is technically feasible and demonstrated

th l

Water absorption at 95% CE

Fixed bed catalytic incinerators at 95% CE

Fluidized bed Catalytic incinerators at 95% CE

Recuperative thermal incinerators at 95% CE

RTO at 95% CE

Flares at 95% CE

2‐bed carbon adsorbers at 95% CE

3‐bed carbon adsorbers at 95% CE

Cost estimates (presented as ra

machines)Water absorption; capital $128 

$1.3 to 1.7M/tonFixed bed catalytic incineratorsto 8.3M, CE $ 29K to 37K/ton

Fluidized bed catalytic incinerat

to 10.4M, CE $ 37K to 46K/ton

Recuperative thermal incinerat

to 10.8M, CE $38 to 48K/ton

RTO; capital $1.6 to 6M, annua

1.6M/tonFlares; capital $2.9 to 3.7M, an

4.6M/ton2‐bed carbon absorbers; capita

CE $19 to 23K/ton3 b d b b b it 

Considered oxidation (i.e. thermal or catalytic,

regenerative or recuperative), adsorption,

absorption , biofiltration and condensation systems

Due to low VOC concentration and variable VOC types, carbon

adsorption would not likely be an effective control and not considered to

be technically practical.Carbon absorption systems (wet scrubber) was determined to be

technically impractical due to large surface area necessary to effect

absorption of the less soluble VOCs and the large volume of air flow.

Control efficiencies were estimated to be 50% or less, however, cost

estimates were included.

Biofiltration is not a demonstrated technology and the technical

feasibility for this application is unknown, therefore the cost estimate,

was included, however additional testing and evaluation would be

necessary to confirm feasibility.

Condensation systems were determined technically infeasible due to

large air flow and low VOC concentration of gas stream.

Only oxidation (catalytic regenerative oxidation (CReO), catalytic

recuperative oxidation (CRuO), thermal regenerative oxidation

(TReO) and thermal recuperative oxidation(TRuO)) and biolfiltration

systems were considered to be technically feasible. Considered allVOC emission points and groupings of VOC emission points (which

might be more feasible because it would increase VOC

concentrations) for cost evaluation. No ranking conducted on

control efficiency included.

Estimated costs:

All sources;CReO capital $4.2 to 13.1M, an

CRuO capital $1.9 to 3.5M, ann

TReO capital $3.2 to 9.1M, annu

TRuO capital $0.8 to 1.1M, ann

BioFil capital $6 to 19M, annua

Absorption CE $35K/ton

Costs were estimated for wet e

aftercoater dryer sources. Low

above, however lowest CE was 

which was still considered econ

Table is two pages wide. Table 1 
RBLC

Code FACILITY_NAME State PERMIT_NUM

Date of

Determination PROCESS_NAME

EMISSION

_LIMIT_1

EMISSION

_

LIMIT_1_U

NIT

EMISSION_LIMIT_

1_AVG_TIME_CON

DITION

CASE‐BY‐

CASE_BASIS

EMISSION_

LIMIT_2

EMISSION

_

LIMIT_2_U

NIT

EMISSION_LIMIT_

2_AVGERAGE_TIM

E_CONDITION PROCESS_

Table 1. Summary of Paper Machine BACT Analyses Received from State Contacts

30.490 STORA ENSO WISCONSIN RAPIDS PAPER

MILL

WI 05‐DCF‐312 Mar., 2007 P12 (PAPER / BOARD

MACHINE #12)

240 LB/MO 12 MO. AVG.

ADDITIVES /

INGREDIENTS

BACT‐PSD 3360 LB/MO 12 MO. AVG.

ADHESIVE / IN

LINE CLEANERS

PAPER MACHINE CONVERTE

MAX. PRODUCTION OF 500 T

BASED DRYING ONLY (NO ONBASED DRYERS). PRIMARILY 

CORRUGATED CONTAINERS)

CONSIDERED A PART OF THE 

IS IDENTIFIED AND PERMITTE

RAPIDS PULP MILL. THIS PRO

(BOARD) MACHINE AT THE W

MILL.

30.240 APPLETON COATED ‐ COMBINED LOCKS

MILL

WI 06‐DCF‐204 Aug, 2007 PROCESS P62, STACK S62 ‐ 

PAPER MACHINE #1

1.4 LB

VOC/ADTP

BACT‐PSD 36 % VOC RETENTION AID EXISTING PAPER MACHINE #

TPD PAPER PRODUCTION.

*Process notes and permit notes from RBLC may be combined in this column. Some notes in the RBLC were truncated.

Table is two pages wide. Table 1 
PROCESS_NAME

e Contacts

P12 (PAPER / BOARD

MACHINE #12)

PROCESS P62, STACK S62 ‐ 

PAPER MACHINE #1

he RBLC were truncated.

BACT Analysis

Step 1 ‐ Identify All Available Control

Technologies Step 2 ‐ Eliminate Technically Infeasible Options Step 3 ‐ Ranking Technically Feasible Control Alternatives Step 4 ‐ Evaluation 

Considered RTO, carbon adsorption, refrigerated

condensers, biolfiltration, catalytic and thermal

incinerators, flares, water absorption, and proper

operating procedures.

Oxidation technologies are demonstrated and technically feasible

technologies.Carbon adsorption is available, technically feasible and demonstrated

technology. A 2 or 3‐bed system would be required to handle

continuous duty‐cycle.

Refrigerated condensers were not considered an applicable technology

due to the system size needed for large air flow.

Biofiltration is not technically feasible due to large surplus land needed

that is not available.

Carbon adsorption was determined to be not technically feasible due to

the contaminants in the air stream (methanol) that would not be well

adsorbed making the system inefficient.

Catalytic and thermal incinerators are technically feasible and

demonstrated technology, however, due to high flow rates, a scaled

estimate with low reliability was done.

Water absorption was considered technically feasible and demonstrated

technology.Flares; derrick support flares are potentially feasible and applicable; guy

and self support flares are technically infeasible due to height required.

RTO; at 98% RE

Recuperative Thermal oxidation; at 98% RE

Catalytic oxidation, fixed‐bed; at 95% RE

Flare @ 95% RE

Carbon adsorption @ 95% RE

Catalytic oxidation, fluid‐bed; at 94% RE

Water absorption @ 90% RE

With the exception of good operating practice utilizing low‐VOC

chemicals, the effective technical applicability of the remaining

control options are questionable due to low VOC concentration

levels.

Estimated costs:TReO annualized capital and O&

TRuO annualized capital and O&

CTO annualized capital and O&

Flares annualized capital and O&

carbon adsorbers annualized ca

water absorption annualized ca

All technologies evaluated were 

due to excessive costs and dele

Considered oxidation systems (thermal or catalytic,

regenerative or recuperative), adsorption,

absorption, biofiltration, and condensation

systems

Oxidation systems were considered technically feasible and

demonstrated technology.Adsorption systems was considered to be technically feasible however

lower VOC loadings may render the technology not technically feasible.

Absorption was considered technically feasible, however, the voc

content of the stream could render the technology inefficient.

Biofiltration is tentatively feasible and was costed.

Condensation systems were determined to not be technically feasible.

Thermal and Catalytic incinerators at 99% RE

Biofiltration @ 99% REcarbon adsorbers at 95% RE

Water absorption at 50% RE

Costs estimated for wet end on

only, after coater dryer only an

Catalytic regenerative oxidation

and $35K to 1.7M/ton CECatalytic recuperative oxidation

and $49K to 2.2M/ton CEThermal regenerative oxidation

and $44K to 2M/ton CEThermal recuperative oxidation

and $72K to 3.3M/ton CE

Biofiltration; total annualized co

974K/ton CE

Carbon adsorption; total annua

447K/ton CE

Water absorption; total annuali

733K/ton CE

Table is two pages wide. Table 1