January 31, 2013

MEMORANDUM
SUBJECT: Meeting N otes for the December 1 3 , 2012 Meeting with AF&PA and NCASI
FROM: Kelley Spence (EPA/OAR/OAQPS/SPPD/NRG)
TO: Docket EPA

- HQ

- OAR

- 2012

- 0640

This memorandum summarizes the meeting between t he American Forest and Paper Association (AF&PA) , National Council for Air and Stream Improvement (NCASI) , member company representatives, and the U.S. Environmental Protection Agency ( EPA ) on December 1 3 , 2012. The purpose of the meeting was to discuss the status of the k raft pulping New Source Performance Standards (NSPS) review and the analysis o f emissions data and permit limits. The agenda for the meeting is provided in Attachment 1. The OAQPS k raft pulping NSPS review presentation is provi ded in Attachment 2. The AF&PA presentation covering technological issues and p relimin ary cost information is provided in Attachment 3. Meeting Attendees: Corey Brandt

- RockTenn Mike Curtis

- Georgia

- Pacific Jeff Shumaker

- International Paper Amy Marshall

- URS Corporation Jim Taylor

- MeadWestvaco Tim Hunt

- AF&PA
John Pinkerton

- NCASI Vipin Varma

- NCASI
John Bradfield

- EPA/SPPD Kelley Spence

- EPA/SPPD
Katie Hanks

- RTI Tom Holloway

- RTI Corey Gooden

- RTIDiscussion Points:

Discussions during the meeting followed the handout s in Attachment s 2 and 3 regarding affected source projections, stack test data, and continuous monitoring data for n on
- d irect c ontact e vaporators ( NDCE ) , d irect c ontact e vaporators (DCE) , l ime k ilns , and s melt d issolving t anks (SDT). There was insufficient time during the meeting to discuss the final three items on the agenda (i.e., excess emission allowances, volatile organic compound [VOC] measurement, and the Subpart MM risk and technology review ( RTR ) )

. Notes from the discussion th at are not apparent from the handouts are provided below.

• AF&PA members expressed concern about evaluating emission limits based on the average of multiple stack tests, and suggested that the range and maximum of the stack tests for each emission unit provides more information about emissions variability and the ability of an emission unit to meet a set limit over time.

• Regarding lime kilns, the AF&PA members noted:

o There is no value to monitoring opacity between the electrostatic pre cipitator (ESP) an d scrubber on lime kilns with combined ESP and scrubber controls because the measured stack gases are not discharged to the atmosphere. Control device parameters would be more meaningful.

o Mills currently operating scrubbers would likely add an ESP in fron t of the scrubber and retain the existing scrubber for SO 2 and limited TRS control if required to meet a low particulate limit. Only certain TRS compounds are controlled by scrubbers.

• In addition, AF&PA members noted concern s about technology distinctions between NDCE and DCE recovery furnaces and the physical limitations of older and new recovery furnaces. AF&PA members indicated that :

o It is not feasible to convert o lder (e.g., pre

- 1965 ) DCE furnaces to NDCE furnaces due to physical constraints of the boiler size (DCEs are smaller and do not have room for additional levels of air ). DCE to NDCE conversions would typically only be done for capacity expansion, but t his is general ly cost

- prohibitive ($20 to $60 million). It is more like ly that older DCEs would be replaced with an NDCE.

o The add ition or modification of ESP units are limited to a certain footprint within most chemical recovery areas (i.e., many ESPs are limited to the recovery furnace building roof or must be reinstalled on ground level if there is room )

.
o There are limitations on the size and type of recovery furnace that can accept SDT vent gases into the combustion chamber. In the few systems where this is practiced, the exhaust must be injected at high levels in the rec overy furnace (e.g. , with quaternary air in newer [post

- 2000] NDCE recovery furnaces). The SDT scrubber may be retained to cool and condense moisture from the SDT exhaust prior to injecting the SDT exha ust into the recovery furnace. Additional air ports
s pecific for the SDT exhaust must be added to the recovery furnace. Combusting the SDT exhaust results in the recovery of a portion of the SDT TRS as NaS 2 and the remainder oxidizing to SO 2 , similar to RF incineration of LVHC/HVLC gases. In some cases salt cake tanks or black liquor tanks may vent to the SDT scrubber. The recovery furnace ESP would need to be able to handle t he additional PM from the SDT and any equipment venting with the SDT exhaust. The members anticipated that incineration of the SDT exha ust would only be feasible for new recove ry furnaces designed specifically for SDT exhaust incineration , not modified units.

o Larger, newer furnaces could be upgraded to process spent liquor with a higher solids content with additional air levels in an atte mpt to further reduce TRS, but older smaller units (i.e., DCEs )do not have room for additional air levels. Processing higher

- solids spent liquor requires evaporator and concentrator upgrades that could cost $20 million.

• The AF&PA members explained that u pgrades to existing recovery furnaces or lime kilns would trigger modification criteria under the NSPS before trigg ering new source limits under MACT (s ubpart MM). PM limits set at the new source MACT level would be challenging for modified or reconstructed emission units to meet without changes in control technology

. Space at the mills may be a limiting factor for control system upgrades (e.g., addition of an ESP prior to a lime kiln scrubber, or roof

- top space for larger ESPs)

.

• It was the interpretation of AF&PA members that new emission units are unable to use the PM bubble option under subpart MM, while modified units may still participate in bubble calculations.

• The members noted that a new 1000 ton/day NDCE recovery furnace with auxiliaries would be in the ballpark of $200 to $250 million. The upper end of this range ($250 million) woul d include a new turbine generator needed to process the hig her

- pressure steam from the new NDCE furnace

.

• It was noted that p acked bed scrubbers on SDTs can quickly become plugged.

• The members noted that o pacity limits of 20 percent in permits for recovery furnaces may be based on periodic observations rather t han COMS. If based on COMS, then the averaging time associated with lower opacity limits is important.

• The AF&PA members suggested that the EPA’s CEMS cost model for SO 2 CEMS provides a reasonable cost for TRS CEMS. Appendix F requirements for TRS CEMS could cost an additional $13K per year. One member noted that there are some calibration gas issues with Appendix F for TRS and that Appendix F was not designed for TRS. It was suggested that the TRS CEMS under subpart BB are in place for monitoring excess emissions but not compliance (e.g., because stack testing is initially used for compliance), so Appendix F requirements may be unnecessary for TRS CEMS

.Attachment 1 Draft Agenda for AF&PA

- EPA Meeting on Kraft P ulping NSPSAgenda for AF&PA

- NCASI Mee ting with OAQPS December 13, 2012 (1:00 PM to 4:30 PM)

Introductions

Kraft NSPS

• Update of activities

• Assessment of ICR database of emissions

• Discussion/questions on methodology and preliminary assessment

• Review possible costs of alternative pollutant standards

• Discussion/questions on data

• Next Steps

– information needs

Excess Emission Allowances (as time allows)

• Follow

- up to information presented in October

• Start

- up and Shutdown language

• Next Steps Other issues (probably defer until next meeting)

• VOC Measurement

– follow

- ups from April meeting

• Subpart MM RTRAttachment 2
EPA Status of the Kraft NSPS

# Status of the Kraft Pulping NSPS Review (40 CFR Subpart BB) December 13, 2012

1

# Overview of Activities

• Current Activities

– Assembly and analysis of emissions data and permit limits



# – Identification of regulatory options



# • Next Steps

– Estimate impacts of options

– Draft rule for internal review



# • Propose by May 15, 2013



# • Promulgate by March 14, 2014

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 2

# Affected Source Projections

• Projections of new, modified, and reconstructed emission units.

• Estimate impacts for 5 years after applicability date of NSPS review (2013 proposal)

• Created inventory of DCE (and associated 

# BLO), NDCE, LK, and SDT systems from Part III ICR data

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 3

# Affected Source Projections

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 4 Equipment Type Recovery furnaces LK SDT DCE NDCE Historical Data Number of units in ICR data base 43 108 131 164 New installations triggering NSPS 2 48 46 56 Modifications/reconstructions triggering NSPS 1 1 27 16 14 Total number that triggered NSPS since 1976 3 75 62 70 Average number of new installations per year (over 33 yrs) 0.06 1.45 1.39 1.70 Average number of modified/reconstructed emission units per year (over 33 yrs) 0.03 0.82 0.48 0.42 Projection for Next 5 Years Projected number of new installations 2 0 7 7 8 Projected number of modified/reconstructed emission units 2 0 4 2 2 1. Any NSPS units not specifically labeled as “new” or “replacement” were considered to trigger NSPS through modification or rec onstruction, even if not specifically labeled as modified or reconstructed. 2. Calculated as the average number per year x 5 years, rounded to nearest whole number.

# Recovery Furnaces

• 151 recovery furnaces: 43 DCE, 108 NDCE

– DCEs controlled by DBESP (10), DBESP/SCBR (1), DBESP

- WPR (3), WBESP (27), and WBESP/SCBR (2)

– NDCE controlled by DBESP (78), DBESP/SCBR (1), DBESP

- WPR (13), 2

- sided DB

- WBESP (1), SCBR (2), 

# and WBESP (13)

– Counts subject to change (e.g., adjustments for recent DCE

- > NDCE conversions and/or non



# operational units)

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 5

# Recovery Furnace PM

• Current NSPS and existing source MACT limit is 0.044 gr/dscf @ 8% O2

• MACT new limit is 0.015 gr/dscf @ 8% O2

• Permit limits:

– About half of the RFs have PM permit limits below 0.044 gr/dscf @ 8% O2

– A few pre

- NSPS units have limits above 0.044 

# (e.g., MACT PM bubble mills)

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 6

# Recovery Furnace PM Stack Data

• 206 PM stack tests on 136 recovery furnaces

– Method 5 filterable PM (few ODEQ M5)

– 2002 to 2011 stack tests



# – Multiple tests for some furnaces

– 62 DCE tests:

• 18 DBESP, 4 DBESP

- WPR, 36 WBESP, 1 DBESP/SCBR and 3 WBESP/SCBR



# – 144 NDCE tests:

• 95 DBESP, 18 DBESP

- WPR, 22 WBESP, 7 DBESP/SCBR, 1 DB

- WBESP [2

- sided, dry and wet], and 1 SCBR

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 7PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 8PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 9PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 10

# RF PM Stack Data Observations

• NDCE and DCE similar results for PM

• Two

- thirds of the DCEs and NDCEs have 

# performance levels at or below 0.015 gr/dscf using typical recovery furnace 

# controls such as DBESP, WBESP, or DBESP

- WPR

.

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 11

# Recovery Furnace Opacity

• 160 RF COMS data sets analyzed

– Some RFs have two COMS in separate stacks

– Primarily 6

- min average analyzed

– Some highest 6

- min average per hour or hourly average



# • Current NSPS limit is 35% opacity

– 6% of averages per quarter excluding SSM can exceed without violating standard



# • MACT new limit is 20% opacity

– 6% of quarterly operating time allowance



# • Many permits with limits below 35% opacity; 20% 

# opacity common

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 12DRAFT

- SUBJECT TO CHANGE 13 PRELIMINARY ANALYSIS OF ICR DATA

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- SUBJECT TO CHANGE 14 PRELIMINARY ANALYSIS OF ICR DATA

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- SUBJECT TO CHANGE 15 PRELIMINARY ANALYSIS OF ICR DATA

DRAFT - SUBJECT TO CHANGE

# Recovery Furnace TRS

• 141 RF TRS CEMS data sets analyzed

– Primarily 12

- hour average; a few 24

- hour average for non

- NSPS furnaces



# • Current NSPS limits:

– 5 ppmdv @ 8% O 2 

# [ straight RF]; 25 ppmdv @ 8% O 2 

# [ cross RF]

– Allowance for 1% of quarterly averages to exceed limit



# • Only 1 “cross” recovery furnace exists, and it is subject to 

# the lower 5 ppm TRS limit for “straight” recovery furnaces (not 25 ppm )

• Straight RF NSPS limit based on use of process controls and NDCE or process controls and 2

- stage BLO for DCE



# • Most NDCEs have 5 ppm TRS permit limit and most DCEs have 20 ppm limit (emission guidelines)

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 16PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 17PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 18PRELIMINARY ANALYSIS OF ICR DATA DRAFT

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# Lime Kilns

• 131 lime kilns

– Controls include Scrubber (92), ESP (29) and ESP/scrubber (10)



# • Use of ESP and ESP/scrubber systems is a development since 1986 NSPS review

– Reviewing monitoring options to include in the NSPS for these systems

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 20

# Lime Kiln PM

• Current limits (all @ 10% O 2 

# ):

– NSPS: 0.066 gr/dscf (gas) and 0.13 gr/dscf (oil)

– MACT (Subpart MM):

• Existing: 0.064 gr/ dscf

• New: 0.010 gr/dscf



# • Gas/oil and gas/pet coke combinations are not addressed in the current NSPS

• Test data do not show a clear distinction in 

# fuel type vs. PM emissions

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 21

# Lime Kiln PM Stack Data

• 255 PM stack tests on 110 kilns reviewed

– Method 5 filterable PM

– 2001 to 2011 stack tests

– ESP (113), ESP/scrubber (26), and scrubber (116) controls



# – Gas (111), oil (55), gas/oil (9), gas/pet coke (13), and unspecified (67) fuels

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 22PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 23PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 24PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 25PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 26

# Kiln PM Stack Data Observations

• ESP and ESP/scrubber controls out

- perform scrubbers alone and are the only systems expected to achieve a new source limit of 0.01 (the MACT new limit ).

• The majority of kilns with ESP and 

# ESP/scrubber meet performance levels of 0.01, regardless of permitted limit.

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 27

# Lime Kiln Opacity (ESP Control)

• NSPS currently specifies no LK ESP monitoring requirements

• 20% opacity required in majority of permits

• MACT requires 20% opacity

– 6% of quarterly operating time allowance



# • 29 LK COMS data sets analyzed

– Primarily 6

- min average; two hourly average



# – Included COMS on 5 ESP/scrubber systems

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 28PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 29PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 30PRELIMINARY ANALYSIS OF ICR DATA DRAFT

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# Lime Kiln TRS

• 112 TRS CEMS data sets analyzed

– Primarily 12

- hour average

– S ome 24

- hour average (e.g., non

- NSPS kilns)



# • Current NSPS limit is 8 ppmdv @ 10% O2

– Based on process control, good mud washing, and caustic scrubbing



# – No allowance for exceedances



# • Approximately half of the units have a permit limit of 8 ppmdv and half have limits of 20 ppmdv (emission guidelines)

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 32PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 33PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 34PRELIMINARY ANALYSIS OF ICR DATA DRAFT

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# Smelt Dissolving Tanks (SDTs)

• 164 SDTs

– Controlled by mist eliminator (5), scrubber (156), or incineration in recovery furnace (3)

– Incineration control is a new development since the 1986 NSPS review, but no PM or TRS test data 

# are available to determine performance (co

mingled exhaust)



# • Scrubbers are predominant control

• Monitor scrubber parameters (not opacity)

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 37

# SDT PM and TRS Stack Data

• PM and TRS limits are in lb/ton BLS

– Needed tests with production data to compare to limits



# • 182 PM stack tests reviewed

– Method 5 filterable PM



# – 2001 to 2011 stack tests

– 4 mist eliminator, 20 packed bed scrubber, and 158 scrubber tests



# • 100 TRS stack tests reviewed

– Methods 16 or 16A/B/C

– 1987 to 2011 (all but 7 tests were 2004 or more recent)

– Emissions converted to “as H2S” basis consistent with NSPS limit



# – 91 scrubber, 6 packed bed scrubber, and 3 mist eliminator tests



# • No stack data for SDTs venting through recovery furnaces

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 38

# Smelt Dissolving Tank PM

• NSPS and MACT (existing) limit is 0.2 lb/ton BLS

• MACT (new) limit is 0.12 lb/ton BLS

• Permit limits:

– Most SDTs have limits of 0.2 lb/ton BLS

– About 20 percent of SDTs have limits below 0.2; most around 0.12 lb/ton BLS

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 39PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 40

# Smelt Dissolving Tank TRS

• Original NSPS limit was 0.0168 lb/ton BLS

• During the 1986 NSPS review the limit was 

# increased to 0.033 lb “as H2S”/ton BLS

• Emission guideline document developed prior to 1986 NSPS review had 0.0168 lb/ton BLS



# • Most SDTs have permit limits of 0.033

– Approximately 20% of the units are required to 

# meet 0.0168 lb/ton BLS

PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 41PRELIMINARY ANALYSIS OF ICR DATA DRAFT

- SUBJECT TO CHANGE 42Attachment 3 Kraft Pulp Mills NSPS Review

– A Preliminary Framework for Cost

# Kraft Pulp Mills NSPS Review

– A Preliminary Framework for Costs Industry Group Meeting with OAQPS RTP, NC
December 13, 2012

# Overview

AF&PA and NCASI are reviewing ICR data and preliminary additional data from member companies to evaluate feasibility and implications of a potential lowering of Kraft NSPS limits Primary impacts would be on existing recovery furnaces, smelt tanks, and lime kilns that are modified after NSPS revision and trigger NSPS and new smelt tanks (installing a new smelt tank triggers NSPS but not MACT if there is no new/reconstructed recovery furnace) Aside from incremental costs, there are technological limitations that could prevent some modified units from achieving any potential lower standard

2

# Recovery Furnaces DCE (BLOX and/or oxygen polishing) and NDCE (high solids) NDCE furnaces Larger, newer furnaces could be upgraded to higher solids with additional air levels to target achieving <5 ppm TRS while older, smaller furnaces cannot be modified No specific control technology designated to guarantee lower TRS limits ESP upgrades or replacements could meet lower PM 

# DCE Furnaces

– Mills typically avoid triggering NSPS 5 ppm TRS limit difficult to meet (operational/energy penalties ) Any further lowering of TRS limit impossible to achieve Furnace size may not allow for installation of additional levels of air Capital cost for NDCE conversion is prohibitive ($20M to $60M)

3

# NDCE F urnace Typical Upgrade Costs
$3M to $30M depending on scope
TRS/PM

– High solids and additional combustion air

- $5

- 10M (if furnace can accommodate this) PM

– Upgrade ESP @ $3

- 8M (if there is space) PM

– Replace ESP on top of recovery building with larger unit on ground level

- $20M 

# Additional auxiliary fuel firing in the upper furnace may also be needed

– unproven Combustion air and fuel modifications will affect performance relative to CO, NOx, and SO 2



## 4

# Lime Kilns
No control technology would guarantee further TRS reductions below current limit PM controls with wet scrubber, ESP, or both. Some mills bubbled under MACT II to meet PM requirements, oil

- fired units have NSPS limit higher than single source MACT Further lowering of PM limits would require ESPs (new ESP ~$5M) on scrubbed units

5

# Smelt Tanks PM and TRS controlled with wet devices ranging from mesh pads/water showers to full wet scrubbers. Some mills used MM “bubble” approach to comply with PM requirements High efficiency scrubbers could be employed in response to a lower PM standard ($500k + high operating costs ). Unproven for ultra low PM levels. 

# Mills may duct smelt tanks into recovery furnace to eliminate PM/TRS in response to a lower standard (~$5M plus additional maintenance costs)
infeasible for all but newest furnaces

6

# Impacts of Monitoring Changes
Potential changes involve additional QA requirements on TRS CEMS (Appendix F), COMS on lime kilns, and PM CEMS. EPA has developed a CEMS cost model that provides a reasonable cost estimate of installation and operations for various CEMS. TRS CEMS additional annual cost per system $13 K COMS $50K installed, $20K annual cost per system PM CEMS $100

- 150K installed, $40

- 55K annual cost per system (depending on technology installed)

7

# Economic Impacts of a Potential NSPS Revision

Other environmental regulations (Boiler MACT) will require extensive capital and operating expense Mills have high ROI hurdles for projects additional controls make modernization projects less attractive, reducing competitiveness

8