January 31, 2013

MEMORANDUM

SUBJECT: Meeting Notes for the December 13, 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 the 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 13, 2012. The 

purpose of the meeting was to discuss the status of the kraft pulping New Source Performance Standards 

(NSPS) review and the analysis of emissions data and permit limits. The agenda for the meeting is 

provided in Attachment 1. The OAQPS kraft pulping NSPS review presentation is provided in 

Attachment 2. The AF&PA presentation covering technological issues and preliminary 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 - RTI
Discussion Points:

Discussions during the meeting followed the handouts in Attachments 2 and 3 regarding affected source 

projections, stack test data, and continuous monitoring data for non-direct contact evaporators (NDCE),

direct contact evaporators (DCE), lime kilns, and smelt dissolving tanks (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 that 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 precipitator (ESP) and 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 front of the scrubber and retain

the existing scrubber for SO2 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 concerns 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 older (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 this is generally cost-prohibitive ($20 to $60 million). It is more likely that older DCEs 

would be replaced with an NDCE.

o The addition 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 recovery 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 exhaust into the recovery furnace. Additional air ports 

specific 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 NaS2 and the remainder oxidizing to SO2, 

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 

the additional PM from the SDT and any equipment venting with the SDT exhaust. The members 

anticipated that incineration of the SDT exhaust would only be feasible for new recovery 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 attempt 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 upgrades to existing recovery furnaces or lime kilns would 

trigger modification criteria under the NSPS before triggering new source limits under MACT 

(subpart 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) would include a new 

turbine generator needed to process the higher-pressure steam from the new NDCE furnace. 

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

• The members noted that opacity limits of 20 percent in permits for recovery furnaces may be based 

on periodic observations rather than 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 SO2 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 Pulping NSPS
Agenda for AF&PA-NCASI Meeting 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 RTR
Attachment 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 

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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 

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Affected Source Projections

PRELIMINARY ANALYSIS OF ICR DATA 

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Equipment Type

Recovery furnaces

DCE NDCE LK SDT

Historical Data

Number of units in ICR data base 43 108 131 164

New installations triggering NSPS 2 48 46 56

Modifications/reconstructions triggering NSPS1 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 installations2 0 7 7 8

Projected number of modified/reconstructed emission units2 0 4 2 2

1. Any NSPS units not specifically labeled as “new” or “replacement” were considered to trigger NSPS through modification or reconstruction, 

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 nonoperational units)

PRELIMINARY ANALYSIS OF ICR DATA 

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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 

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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 

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PRELIMINARY ANALYSIS OF ICR DATA 

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8
PRELIMINARY ANALYSIS OF ICR DATA 

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9
PRELIMINARY ANALYSIS OF ICR DATA 

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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 

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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 

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- SUBJECT TO CHANGE 13 02468

10

12

14

16

18 Annual Average Opacity (including exceedances)

Annual Average 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

PRELIMINARY ANALYSIS OF ICR DATA 

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10

15

20

25

30

35

40

45

50 99th Percentile

99th Percentile - 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 new = 

20%

Highest 6-min average 

provided for each hour

PRELIMINARY ANALYSIS OF ICR DATA 

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15PRELIMINARY ANALYSIS OF ICR DATA 

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0%

1%

2%

3%

4%

5%

6%

7%

8%

9%

10% Percent of Averaging Periods Exceeding 20%

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. (606.RB4)
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% O2[straight RF]; 25 ppmdv @ 8% O2[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 

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PRELIMINARY ANALYSIS OF ICR DATA 

DRAFT - SUBJECT TO CHANGE 17 0123456789

10

11

12

13

14

15

16

17

18 TRS, ppmdv @ 8% O2

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

Current NSPS limit for cross RF (DCE and NDCE) = 25 ppm @ 8%O2. Only 1 cross RF 

exists and it is permitted to meet the straight RF TRS limit.
PRELIMINARY ANALYSIS OF ICR DATA 

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10

15

20

25

30 TRS, ppmdv @ 8% O2

99th Percentile of the TRS Averaging Periods (NSPS and Non-NSPS Furnaces)

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

Current NSPS limit for cross RF (DCE and NDCE) = 25 ppm @ 8%O2. Only 1 cross RF 

exists and it is permitted to meet the straight RF TRS limit.

Two 99th percentile outliers omitted: non-NSPS DCE (126 ppm), and 

NSPS NDCE (43 ppm)
PRELIMINARY ANALYSIS OF ICR DATA 

DRAFT - SUBJECT TO CHANGE 19 0% 0.3% 0% 0% 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% Percent of Averaging Periods, %

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.
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 

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Lime Kiln PM

• Current limits (all @ 10% O2):

– 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 

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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 

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PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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PRELIMINARY ANALYSIS OF ICR DATA 

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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 

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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 

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PRELIMINARY ANALYSIS OF ICR DATA 

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10

12

14

16

18

20 Annual Average Opacity

Lime Kiln Annual Average Opacity

Calculated as the average of the averaging periods for all COMS data sets.

ESP ESP/SCBR

MACT violation level = 20% opacity for more than 6% of quarterly operating time
PRELIMINARY ANALYSIS OF ICR DATA 

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10

15

20

25

30 99th Percentile Opacity

99th Percentile of Lime Kiln COMS Data Sets

Calculated as the 99th percentile of the averaging periods for all COMS data sets.

ESP ESP/SCBR

MACT violation level = 20% opacity for more than 6% of quarterly operating time

These kilns exceeded 20% opacity for 

less than 6 percent of annual 

operating time.
PRELIMINARY ANALYSIS OF ICR DATA 

DRAFT - SUBJECT TO CHANGE 31 0.03% 0.11% 0.06% 0.01% 0.005% 0.06% 0.34% 1.2% 0% 0.04% 0.01% 0.01%0% 0.37%0.005% 0.002% 0.01% 0.003% 0.01% 2.2% 0.1% 0.4%0.11%0% 0.03% 0.54% 0.00% 0.28% 2.6%

0%

1%

2%

3%

4%

5%

6% Percent of Averaging Periods

Percent of Lime Kiln COMS Averaging Periods Exceeding 20%

MACT allowance = 6% of quarterly operating 

ESP ESP/SCBR
Lime Kiln TRS

• 112 TRS CEMS data sets analyzed

– Primarily 12-hour average

– Some 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 

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PRELIMINARY ANALYSIS OF ICR DATA 

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10

12

14

16 TRS, ppm at 10% O2

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.
PRELIMINARY ANALYSIS OF ICR DATA 

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0.0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

9.0 TRS, ppm at 10% O2

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.
PRELIMINARY ANALYSIS OF ICR DATA 

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0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

16.0 TRS, ppm at 10% O2

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.
PRELIMINARY ANALYSIS OF ICR DATA 

DRAFT - SUBJECT TO CHANGE 36 0%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

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.
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 (comingled exhaust)

• Scrubbers are predominant control

• Monitor scrubber parameters (not opacity)

PRELIMINARY ANALYSIS OF ICR DATA 

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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 

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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 

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PRELIMINARY ANALYSIS OF ICR DATA 

DRAFT - SUBJECT TO CHANGE 40 0

0.05

0.1

0.15

0.2

0.25

0.3

0.35 PM, lb/ton BLS

SDT PM Stack Test Performance Levels

(Performance levels are based on the max of multiple stacks; and average of multiple tests on the same SDT)

Mist Eliminator Scrubber Packed Bed Scrubber

NSPS limit =

MACT (existing) = 

0.2 lb/ton BLS

MACT (new) =

0.12 lb/ton BLS

All SDTs above 0.2 participate in the 

PM MACT bubble except these two.
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 

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PRELIMINARY ANALYSIS OF ICR DATA 

DRAFT - SUBJECT TO CHANGE 42 0

0.005

0.01

0.015

0.02

0.025

0.03

0.035 TRS as H2S, lb/ton BLS

SDT TRS Stack Test Performance Levels

(Performance levels are based on the max of multiple stacks; and average of multiple tests on the same SDT)

Mist Eliminator Scrubber Packed Bed Scrubber

NSPS limit =

0.033 lb as H2S/ton BLS
Attachment 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)

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NDCE Furnace 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 SO2

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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

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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

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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)

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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

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