Date: November 16 , 2011

Subject: Section 112(d)(6) Technology Review for Pulping and Papermaking Processes EPA Contract No. EP - D - 11 - 084 ; Work Assignment No. 0 - 03 From: Katie Hanks

Thomas Holloway To: John Bradfield

Bill Schrock U.S. Environmental Protection Agency Research Triangle Park, NC 27711 The purpose of this memorandum is to present the results of a review of available information on developments in practices, processes, and control technologies that apply to pulping and papermaking pro cesses. This anal ys is is part of the U.S. Environmental Protection Agency ’s (EPA’s) effort to review the national emission standards for hazardous air pollutants (NESHAP) for the Pulp and Paper Industry (40 CFR part 63, subpart S) in accordance with sectio n 112(d)(6) of the Clean Air Act (CAA). Section Iof this memorandum provides background information on the requirements of section 112(d)(6) of the CAA, the pulp and paper production source category , and the requirements of the Pulp and Paper NESHAP. Se ction II discusses the review of information on developments in practices, processes, and control technologies that have occurred since the original development of this NESHAP. The specific processes mentioned in this memorandum include:  K raft pulping pro cesses  S oda pulping processes  S emichemical pulping processes  S ulfite pulping processes  N on - wood pulping processes  Mechanical pulping  S econdary

fiber pulping processes  Papermaking processes Separate memoranda present detailed technology reviews for kraft pu lping proc ess condensates and ble aching s ys tems. (EPA 2011a, EPA 2011b)2

**I. B**  **ackground A.**  **Requirements of Section 112(d)(6) of the CAA** Section 112 of the CAA requires EPA to establish technology
- based standards for sources of hazardous air pollutants (HAP). Thes e technology
- based standards are often referred to as maximum achievable control technology ( MACT ) standards. Section 112 also contains provisions requiring EPA to revisit these standards. Specificall y, paragraph 112(d)(6) section states: (6) REVIEW AND REVI SI ON.

– The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emission standards promulgated under this section no less often than every

8 years. For the purpose of this technology review, a “development” was considered to be any of the following:  Add
- on control technology or other equipment that was not identified and considered during the development of the NESHAP;  Improvements in add
- on control technology or other equipment that were not identified and considered during NESHAP development that could result in significant additional HAP emissions reductions;  Work practice or operational procedure that was not identified and considered during NESHAP development; and  P rocess change or pollution prevention alternative that could be broadl y applied that was not identified and considered during the development of the NESHAP.  Improvements in work practices, operational procedures, process changes or pollution prevention alt ernatives **B. Description of Source Category and NESHAP Requirements**  The pulp and paper production source category includes any

facility engaged in the production of pulp and/or paper. This category includes, but is not limited to, integrated mills (where pulp alone, or pulp and paper, or paperboard are manufactured on
- site), non
- integrated mills (where either pulp or paper / paperboard are manufactured on - site , but no t both), and secondary fiber mills (where waste paper is used as the primary raw material). Th e processes used to convert wood into paper products include: wood preparation (debarking, chipping, and sizing of the wood material); pulping (chemical, mechanical, semichemical, or recycled paper pulping); chemical recovery ( recovery

of pulping chemicals in che mical and semichemical pulping); bleaching (chemicall y whitening/brightening the pulp) ; and papermaking (stock preparation, dewatering, pressing, drying, and finishing). A fully
integrated chemical pulp and paper mill would include all of these proc ess areas .3

The MACT standards for the pulp and paper production source category were developed in three parts:  MACT I - regulates HAP emissions from the pulp production areas and bleaching operations at chemical pulp mills (kraft, sulfite, semichemical, a nd soda wood pulping processes) and the bleaching operations at pulp mills using mechanical, secondary fiber, and non
- wood pulping ;  MACT II - regulates HAP emissions from the chemical recovery combustion areas of chemical pulp mills (kraft, sulfite, semich emical, and soda wood pulping processes); and  MACT III - regulates HAP emissions from pulp and paper production areas of pulp mills using mechanical, secondary fiber, and non
- wood pulping, and papermaking s ys tems at all mills. The MACT I and MACT III standards are contained in 40 CFR part 63, subpart S (NESHAP for the Pulp and Paper Industry), which was promulgated on April 15, 1998. As noted previously , the purpose of this memorandum is to present the results of a technology review for many sources s ubje ct to NESHAP subpart S . The pulping and bleaching operations at kraft, soda, sulfite, and stand
- alone semichemical pulp mills that are regulated b y the MACT Irule include digesters, pulp washers, evaporators, turpentine recovery , steam stripper sy stems, liquor storage tanks, lime slaker vents, oxygen delignification s ystems, bleaching systems, wastewater treatment systems, and related equipment and processes
. B leaching operations at mechanical, secondary fiber, and non
- wood pulp mills that are regulated b y the MACT I rule include bleaching tower vents, storage tanks, washer vents, filtrate tank vents, scrubber outlets, and wastewater . Mills that mechanically pulp wood, pulp secondary

fiber or non
- wood fibers, and any mills that make paper, paperboard, or related products from pulp are entities covered b y th e MACT III rule. The processes evaluated under this standard include chip pre
- steaming vessels, pulpers/repulpers, deinking operations at secondary fiber mills, and papermaking operations (e.g., forming, drying, vacuum pumps , storage tanks) at all mills. As promulgated, the MACT Iand III (subpart S) standards include emission s standards for pulping s ys tem vents, kraft pulping process condensates, and bleaching sy stem vents. These standards also include s everal alternative emission s limits f or each covered process that is designed to provide flexibility and promote and encourage the use of new technology , particularl y combined air/water controls and pollution prevention technologies. Table 1 at the end of this memorandum presents an abbreviated summary of the subpart S standards. The control sy stems used b y most mills to meet the subpart S emissions standards are as follows:  Pulping sy stem vents

— thermal oxidizers, power boilers, lime kilns, and recovery f urnaces.  Pulping process condensates

— steam strippers, biological wastewater treatment, and recycling to pulping equipment that is controlled by the standards.  Bleaching s ys tem vents

— caustic scrubbers (for chlorinated HAP other than chloroform) and proc ess modifications to eliminate the us e of chlorine and hypochlorite.4

**C. Estimated HAP Emissions**  Substantial HAP emission reductions have been achieved through implementation of subpart S for pulping and bleaching vents and kraft condensates. Nationwide basel ine HAP emissions for the subpart S source category were estimated at 2 3 0,000 t ons per year (tp y) prior to implementation of subpart S . (EPA 1993 ) The EPA conducted an information collection request (I CR) in 2011 that requested updated emissions inventories from major source pulp and paper production facilities. Post - MACT nationwide emissions estimates based o n response s to Part II of the pulp and paper ICR were 4 4,726 tpy . Methanol accounts for 86 percent of the total HAP emissions , while acetaldehyde accounts for 5 percent. Numerous other HAP account for the remaining emissions reported for subpart S equipment in Part II of the ICR. Table 2 at the end of this memorandum presents a list of the pollutants and th eir reported emissions for equipment in the subp art S source category . Figure 1 depicts the magnitude of subpart S emissions by process. Processes with the most emissions following MACT implementation are kraft pulping, wastewater, and papermaking
. B leaching emissions remain as well, but are not of the same magnitude as the aforementioned processes
. Emissions from non - kraft pulping processes are very low relative to kraft pulping, in part because there are fewer of these processes nationwide, and because the emissions sources in these processes differ from kraft processes. At the time of subpart S promulgation, it was concluded that wood yard operations, tall oil recovery

s ys tems, and pulping s ys tems at mechanical, secondary fiber, and non
- wood fiber pulping mills do not emit significant quantities of HAPs . (72 FR 18519, April 15, 1998) As clearl y shown in Figure 1 for tall oil and mechanical pulping , this conclusion remains true today following MACT implementation. Wood yards do not appear in Figure 1 becau se no HAP data for wood yards were reported in the Part II subpart S inventory
. Secondary fiber operations also are not shown separately on Figure 1 because they are often co
- located with and integrated into other pulping or papermaking operations , and , therefore , secondary fiber emissions are embedded in the Figure 1 bars for other processes
. There are no known major source non
- wood mills (e.g., the onl y non - wood mill responding to the I CR was found to be a true area source). Consequently , the remainder of this memorandum focuses on chemical pulping processes and papermaking with limited additional discussion of the processes noted in this paragraph. **II. Developments in**  **Practices, Processes, and Control Technologies** The RACT/BACT/LAER Clearinghouse (RBLC) and responses to Part I of EPA’s pulp and paper IC R were reviewed to determine if there have been developments in practices, processes, or control technologies for pulping and papermaking. In addition, we contacted states for details on BACT determinations made for papermaking processes. No new measures f or reducing pulping HAP emissions were identified beyond the technologies used to comply with MACT for most equipment. A separate memorandum discusses the technology review for kraft condensates (wastewater), where a separate investigation was performed. T he technology review for bleaching is also provided in a separate memorandum, though no new emissions reduction measures were identified.5

**A. RACT/BACT/LAER Clearinghouse**  The information found in our search of the RBL C is described and tabulated in a separate memorandum. ( RTI2011a) A few emissions reduction measures for pulping processes were identified in the RBL C. P ulping emissions of HAP, volatile organic compound (VOC ) , total reduced sulfur (TRS) , and/or acetone at 1 2 kraft pulp mills were controlle d by routing them to an incineration device, such as a boiler, lime kiln, recovery furnace, or thermal oxidizer. Pulping condensate VOC and TRS emissions in wastewater at two mills were controlled by biodegradation or good management practices. In each of these cases, the information obtained through the RBL C search did not represent any practices, processes, or control technologies not already identified and evaluated during the original MACT development
. The findings of EPA’s ICR relative to these control s are described below. Controls other than those considered as HAP
- reducing technologies during the original MACT development were also noted in the RBLC for some processes. Specificall y, l ime slaker particulate matter (PM) emissions at one mill were controlled by a wet scrubber. T all oil recovery s ys tem VOC emissions at one mill were controlled by venting them to incineration
based control
. P ulping VOC emissions were controlled at two mechanical pulp mills by using a regenerative thermal oxidizer ( RTO ) an d at o ne mill by using existing fiber scrubber s/ condensers
. Non - HAP VOC (e.g., pinenes) are the predominant pollutants from t all oil recovery and mechanical pulping s ys tems . TRS may also be important for tall oil recovery
.6

**B. Review of Pulp and Paper Part I S** **urvey Data** 1 . Kraft p ulping p rocesses Ninety
- s even mills in the Part I data base perform kraft pulpin g which is a chemical pulping process that uses a mixture of sodium hydroxide (NaOH) and sodium sulfide (Na2 S) as the cooking liquor
. Figure 2 is a general diagram of the kraft pulping process.

**Figure 2. General Diagram of the Kraft Pulping Process**  ( Smook 2002)7

Kraft pulping emissions sources include the digester, washer, evaporator, black liquor storage, knotter, screen, ox ygen delignification, steam stripper , causticizing, and turpentine production sy stem s. Each of these s ys tems is comprised of several pieces of process equipment and multiple vents. Vent gas collection s ys tems are used to transport emissions to a control device. Subpart S defines th e following collection sy stems: High volume, low concentration or HVLC system means the collection of equipment including the pulp washing, knotter, screen, decker, and ox ygen delignification systems, weak liquor storage tanks, and any other equipment servin g the same function as those previously

listed. Low volume, high concentration or LVHC system means the collection of equipment including the digester, turpentine recovery , evaporator, steam stripper sy stems, and any other equipment serving the same functi on as those previousl y listed. These collection sy stems are often referred to more generally as non - condensable gas (NCG) collection sy stems. The gas collection s ys tems ty pically route the collected vent gases to a combustion unit such as a thermal oxidizer, lime kiln, recovery furnace, process heater, or boiler for incineration
- based control (destruction) of HAP emissions. Based on our review of the Part I survey data , it is apparent that the actual configuration of NCG sy stems is mill
- specific , and confi gurations are not constrained b y the equipment listings in the definitions of “HVLC s ys tem” and “LVHC sy stem” above. For example, some vents from an evaporator s ys tem (technicall y part of the LVHC system definition) may be collected in the HVL C sy stem; or some pulp washing s ys tem vents (technicall y part of the HVL C sy stem definition) may

be collected in the LVHC sy stem. Some mills do not refer to their sy stems as “LVHC” or “HVLC” but simply refer to their NCG collection sy stem. Stripper off gases (SOG s ), wh ich are technically

part of the LVHC sy stem by definition, are also referred to separatel y and often have their own collection sy stem. Regardless of how the collection sy stem is configured or referred to, the end result of incineration
- based control is the same. In this memorandum, for simplicity, we will refer to LVHC, HVL C, NCG, and SOG collection s ys tems as the “NCG sy stem.” The most common incineration
- based controls reported in the Part I survey for NCG sy stems included lime kilns, power boilers, ther mal oxidizers, and recovery furnaces. Some mills reported use of scrubbing in conjunction with incineration
- based control. In some cases , white liquor scrubbers are used prior to incineration to remove TRS fro m the emissions stream to be incinerated (to prevent sulfur dioxide [ SO 2 ] emissions). In other cases, a scrubber may appear after incineration
- based control (e.g., as the boiler or lime kiln’s control device; or as an SO 2 scrubber on a thermal oxidizer). A few mills reported use of scrubbers both before and after incineration
- based control. Inaddition, 80 kraft mills reported use of backup controls for some portion of their NCG s ys tems . Digester s ys tems . Continuous or batch dig ester s ystems are used for the chemical treatment of wood or non
- wood fiber s. Digester chip bins that pre - steam the wood chips may operate under high or low pressure and are considered part of the overall digester s ys tem if, as defined in subpart S, the steam used is not fresh steam. Several chip bins pre
- steaming wood8

chips were noted in the Part I survey responses as being routed through the NCG sy stem for incineration
- based control (e.g., in a lime kiln, boiler, recovery furnace, or thermal oxidizer). Other components of the digester s ys tems include associated flash tanks, blo w tank s, blow heat recovery

accumul ators, relief gas condensers , prehydrol ys is unit s preceding the pulp washing s ys tem, and related equipment. These components are routed to incineration
- based control through the NCG sy stem , consistent with the control req uirements under subpart S . The practices, processes, and controls reported in the Part I survey responses for digester sy stems were consistent with those evaluated during MACT development. No new developments were identified
. Pulp washing sy stems . Pulp washing s ys tems are part of the HVL C sy stem and include all equipment used to wash pulp and separate spent cooking chemicals following the digester sy stem and prior to the bleaching s ys tem, oxygen delignification sy stem, or paper making sy stem (at unbleache d mills)
. The pulp washing sy stem equipment includes vacuum drum washers, diffusion washers, rotary

pressure washers, horizontal belt filters, intermediate stock chests, and their associated vacuum pumps, filtrate tanks, foam breakers or tanks, and related equipment. Controls reported in the Part Isurvey for kraft pulp washing included incineration
- based controls ty

pical of NCG sy stems. Process improvements noted by some mills included use of clean condensates (e.g., stripped condensates) or fresh water on the last stage of pulp washing. These types of process improvement s and controls were previously identified and evaluated during the original MACT development
. As part of the HVL C sy stem, pulp washing s ys tem vent gases are eligible for use as emissions averaging debits under the clean condensate alternative (CCA). As discussed in a separate memorandum, 38 mills used the CCA as part of their MACT compliance strategy
. (EPA 2011c) No new developments in practices, processes, or controls were observed for pulp washing sy stems. Evaporator s ys tems . Evaporator s ys tem s include equipment associated with increasing the solids content and/or concentrating spent cooking liquor from the pulp washing s ys tem . P re evaporators, multi
- effect evaporators, concentrators, and vacuum s ys tems, as well as associated condensers, hotwells, and condensate streams, and similar equipment are all part of the evaporator sy stem . Evaporation s ys tems are part of the LVHC sy stem defined in subpart S. Controls reported in the Part Isurv ey

for evaporator s ys tems included NCG collection and incineration
- based control. Some mills reporte d use of a scrubber
- incineration control configuration (as also noted above for other equipment routed through the NCG sy stem). No process controls specific to evaporator sy stems were reported.9

No new developments in practices, processes, or controls were revealed in the Part I survey responses for evaporator s ys tems . Knotter and screen s ys tems . Knotters remove knots, oversized material, or pieces of uncoo ked wood from the pulp slurry after the digester sy stem and prior to the pulp washing sy stem. The knotter sy stem equipment includes the knotter, knot drainer tanks, ancillary tanks, and related equipment
. Screens remove oversized particles from the pulp sl urry prior to washed stock storage for bleaching or papermaking. Knotter and screen s ys tems may be combined such that there is no vent in between s ys tems. The kraft pulping vent gas emission limits apply for all knotters and screens at new sources, and ex isting knotters and screens above certain total HAP level s (0.1 pounds [lb] of total HAP per ton of oven dried pulp [ODP] for knotters; 0.2 lb/ton ODP for screens; and 0.3 lb/ton ODP fo r kno tters and screens). According to the P art I survey results, m any knotters and screens are not vented, or a fugitive emission sources vented into a building . Vent gases for other knotters and screens are collected in the NCG s ys tem and incinerated. No new developments in practices, processes, or controls were obs erved f or knotters and screens. Deckers. Deckers are used to thicken the pulp slurry or reduce its liquid content after the pulp washing s ys tem and prior to high
- density pulp storage. The decker s ys tem includes decker vents, filtrate tanks, associated vacuum pumps, and related equipment. The kraft pulping vent gas emission limits apply for all new deckers and existing d eckers using any process water other than fresh water or paper machine white water , or that use any process water with a total HAP concentration (measured as methanol) greater than 400 parts per million by weight (ppmw)
. The Part I survey

results indicated that most deckers are either uncontroll ed (e.g., operating with fresh or white water) or are routed to the NCG sy stem for incinerati on, consistent with the requirements of subpart S. A couple of mills noted, in general, that their foul condensate collection practices reduce emissions associated with process water (and as a result emissions from equipment using process water would be r educed, inclu ding the decker). No new developments in practices, processes, or controls were observed for deckers. Liquor storage
. Spent pulping liquor is generate d when cooking liquor is separated f ro m the pulp during washing. Spent liquor contains dissolved organi c wood materials and residual cooking compounds. After concentration in the evaporator s ys tem, this spent liquor (e.g., kraft black liquor) is a valuable fuel that is burned in the chemical recovery furnace. In addition to producing steam, the recovery fur nace is where the process of reclaiming the residual inorganic cooking compounds begins. Kraft recovery furnaces are subject to a different MACT standard (subpart MM) and are not discussed further in this memorandum. Spent liquor storage consists of vari ous tanks (or , in rare cases , liquor ponds). Strong liquor storage tanks contain liquor that has been concentrated (through evaporation) in preparation for combustion or oxidation in the recovery process. Weak liquor storage tanks10

(other than washer filtrate tanks ) contain spent liquor recovered from the pulping process prior to the evaporator s ys tem. Weak liquor storage tanks are considered part of the HVL C sy stem and are subject to the pulping vent gas standards for new kraft pulping lines. Strong (or heavy) liquor storage tanks are not subject to the pulping vent gas limits. Most liquor tanks were reported as fugitive, vented into a building, or otherwise uncontrolled. Some weak, strong, and intermediate liquor tanks were reported as being vented to the NCG sy stem for incineration control. One mill reported used of black liquor temperature control (to minimize flashing) but did not indicate how the temperature control was achieved. No other process changes specific to liquor storage HAP emissions were not ed. Ten kraft mills reported use of liquor ponds, most likely temporary

emergency

storage areas use d to capture spills or leaks, which can be inferred since these same ten kraft mills also reported use of a series of spent liquor storage tanks. Li quor pond s are fugitive emissions sources. In sum, n o new developments in practices, processes, or controls beyond NCG collection and incineration control were identified for l iquor storage
. Ox ygen delignification
. Ox ygen delignification is subject to the kraft pulping vent gas standards for new and existing pulping lines. Ox ygen delignification uses oxygen to remove lignin from pulp after high
- density stock storage and prior to the bleaching sy stem. The ox ygen delignification sy stem equipment includes the blow t ank, washers, filtrate tanks, any interstage pulp storage tanks, and any related equipment. Based on review of the Part I survey results, most oxygen delignification s ystems are vented through the NCG sy stem to incineration
- based control. A few ox ygen de lignification sy stems are not vented, some are included as a debit generated source under the CCA, and a few are subject to site
- specific MACT provisions or equivalency by permit. No process controls were noted. No new developments in practices, processe s, or controls were identified for ox ygen delignification. Condensate strippers
. Condensate strippers are most commonly steam strippers. St eam stripper sy stem s contain a column used to remove compounds from wastewater or condensates using steam , stripper feed tanks, condensers, or heat exchangers, and (if present at the mill) equipment associated with a methanol rectification process including rectifiers, condensers, decanters, storage tanks, and related equipment. Steam stripper s ys tem vents are commonl y controlled through collection and incineration of the SOG. No new developments in practices, processes, or controls beyond SOG collection and incineration control were identified for condensate strippers. However, as discussed in a separate memorandum pertaining to kraft condensates, the HAP removal efficiency of steam strippers is expected to have improved since promulgation of subpart S. (EPA 2011a) Causticizing
. Inthe kraft pulping process, smelt exi ting from the recovery furnace is causticized to remove impurities left over from the furnace and to convert sodium carbonate (Na2 CO 3 ) into active NaOH
. The causticizing procedure begins with the mixing of smelt with11

“weak ” liquor to form green liquor, named for its characteristic color. Contaminant solids , called dregs, are removed from the green liquor, which is mixed with lime (CaO). After the lime mixing step, the mixture, now called white liquor due to its new coloring, is processed to remove a layer of lime mud (CaCO 3 ) that has precipitated. The primary chemicals recovered are cau stic (NaOH) and Na2 S . The remaining white liquor is then used in the pulp cooking process. The lime mud is treated to regenerate lime in the lime kiln calcining process. ( EPA 2002) Figure 2 shows the kraft pulping process with chemical recovery , including the causticizing loop. The principle equipment in the causticizing loop include:  Equipment handling green liquor (e.g., green liquor clarifiers, green liquor storage tanks, dregs washers)  S laker (and associated slaker grits handling equipment)  Causticizer tanks  White liquor clarifier and storage tanks  L ime mud washer, precoat filter (thickener), and associated weak wash tanks Lime kilns are covered under a separate MACT standard (i.e., subpart MM) for chemical recovery combu stion sources. According to the Part I data base, no add
- on controls are used for green liquor processing. Green liquor tanks were mostly uncontrolled fixed roof tanks , though there are a few open tanks (some of which are in a building). Several mills rep orted that their green liquor processing equipment is a source of fugitive emissions (i.e., not vented through a conveyance). P rocess techniques that may

reduce HAP were reported, including u se of stripped condensates and m akeup water derived from freshwat er . P articulate matter is generated from the strong reaction of the lime with green liquor in the slaker , which produces some steam
. The steam carries PM with it as it is released out the vent . S lakers operate with s ome form of water spray scrubbing designed for PM control. Based on emission unit descriptions, it appears that some slakers and causticizers may vent through the same scrubber. Slakers (and causticizers) at one mill were reported to be vented to a scrubber and lime kiln, while the slaker at an other mill was reported to vent to the LVHC collection sy stem , where emission s are destro ye d by a lime kiln. The effectiveness of slaker scrubbers at reducing HAP is limited
. General p rocess techniques reported that may reduce HAP from slakers and caustici zers include u se of stripped condensates and m akeup water derived from freshwater
. Most lime mud handling equipment is uncontrolled. However, dust collectors (mainly baghouses) were reported for some lime mud handling s ys tems. One facility uses the lime kiln electrostatic precipitator ( ESP ) for PM control. Two facilities use the lime kiln wet scrubber for particulate control. Although no add
- on controls specific to HAP are used for lime mud processing, use of fresh water or clean process water (i.e., water that is not contaminated with untreated condensates) is a process control measure in use b y many facilities. Add
- on controls for weak wash handling are non
- existent, with one exception. One weak wash storage tank was reported to be routed to HVL C and in cinerated in a boiler. Of the weak12

wash handling units that were reported , mo st of the tanks had a fixed roof. No process controls (beyond those mentioned above in general) were reported. Most causticizers, white liquor clarifiers, and white liquor tanks are uncontrolled. Most tanks are fixed roof tanks, though some have an open roof (often located in a building). Some white liquor processing equipment was reported as a fugitive emission source
. A few were reported to have a wet scrubber or mist eliminator , but it is not clear whether these scrubbers would have any effect on HAP emissions. Insome cases , the slaker scrubber is used. General p rocess techniques reported that may reduce HAP include u se of stripped condensates and m akeup water derived from fres hwater
. Miscellaneous causticizing equipment includes equipment that could not be easil y characterized based on the emission unit description provided in the I CR (or did not fit i n the green liquor, lime mud, slaker, or white liquor groupings )
. Nearl y all of this equipment is uncontrolled with the following three exceptions:  A “Causticizer Receiver Tank” that operates with wet scrubber control  A “MACT I Phase I Tank” that operates with scrubber and lime kiln control  A “Recovery

Accumulator” that is routed through the LVHC sy stem for thermal oxidizer control These equipment are believed to be unique and specific to the mill where they operate, and , therefore , are not considered further in the technology review. In general, causticizing equipment does not op erate with HAP
- reducing add
- on controls (with the exception of a couple of random causticizing units tied into an NCG sy stem). P rocess techniques reported that may reduce HAP emissions include u se of stripped condensates as c a u sticizing equipment makeup water or m akeup water derived from freshwater
. Use of process liquids including evaporator or recycled condensates was reported by some mills. Recycling of kraft condensates is one compliance option available to facilities that must meet the requirements of 40 CFR 63.446. However, most mills reporting use of condensates often reported use of such condensates along with fresh water as makeup to the causticizing s ys tem. Given the site
- specific nature of condensate recycle practices (i.e., the extent to which treated vs. untreated condensates are reused) , the lack of information on water flow rates and excess wastewater treatment plant capacity , and issues of fresh water availability , it would be extremely dif ficult to determine emissions reductions, costs , and i mpacts associated with changes to causticizing makeup water. As noted above, k

raft mills are already subject to the subpart S kraft condensate standards , which require condensates to either be treated or recycled to process equipment subject to the pulping vent gas standards. Thus, reuse of contaminated condensates in causticizing equipment not subject to the vent gas standards is minimized by the existing kraft condensate standards. This is evidenced b y the fact that post - MACT nationwide emissions from c au sticizing are low compared to other kraft pulping processes
. Changes to the causticizing sy stem were not explored further as part of the technology

review for these reasons. Turpentine production
. Turpentine is often recovered as a b yp roduct from the dig ester gases at kraft pulp mills. Approximately 80 mills reported production of turpentine in response to the Part I survey . The turpentine recovery s ys tem includes condensers, decanters, storage tanks, and related equipment. Turpentine recovery is part of the LVHC sy stem at kraft pulp mills.13

No new developments in practices, processes, or controls beyond NCG collection and incineration were identified for turpentine recovery. 2 . Soda p ulping p rocesses Soda pulping is a chemical pulping process that use s NaOH as the active c hemical in the cooking liquor. As shown in Table 1, LVHC s ys tem equipment at existing soda mills (digesters, evaporators, and steam strippers) is subject to the pulping vent gas standards in subpart S. In addition, the pulp washing s y stem at new soda mills is subject to the pulping vent gas standards in subpart S. One soda pulping mill operates in the U.S. This mill operates a steam stripper to reduce emissions associated with condensates, and routes all affected emission points including washers and several liquor storage tanks to its NCG sy stem and a thermal oxidizer control. No new practices, processes, or controls we re identified for soda pulping. 3 . Semi
- chemical p ulping p rocesses As defined in subpart S, semi
- chemical pulping means a pulping process that combines both chemical and mechanical pulping processes. The semi
- chemical pulping process produces intermediate pulp yi elds ranging from 55 to 90 percent. The major process difference between chemical pulping and semi
- chemi cal pulping is that semi
- chemical pulping uses lower temperatures, more dilute cooking liquor or shorter cooking times, and mechanical disintegration for fiber separation. There are two ty pes of semi
chemical pulping processes currently in use

—the neutral sulfite semi
- chemical (NSSC) pulping process and the nonsulfur semi
- chemical pulping process. The digestion step in the NSSC pulping process consists of heating pulp in sodium sulfite (Na2 SO 3 ) and Na2 CO 3 . The digestion step in nonsulfur semi
- chemical pulpi ng consists of heating pulp in Na2 CO 3 alone or with NaOH
. A total of eight stand
- alone semi
- chemical pulp mills were reported in the P art Isurvey (two NSSC mills and six nonsulfur semi
- chemical mills)
. This is a declining segment of the s ubpart S category; there were 32 semi
- chemical mills in operation at rule promulgation. Secondary

fiber pulps are now used in many of the same products as virgin semi
- chemical pulp. Semi
- chemical pulping is often combined with secondary fiber pulp processing. Since second ary fiber pulping is essentially a recycle operation (and not a chemical pulping process), we considered mills that produce onl y semi
- chemical and secondary fiber pulps to be stand
- alone semi
- chemical pulping operations. The subpart S pulping vent gas st andards for semi
- chemical mills apply to the LVHC sy stem at existing sources and the LVHC sy stem and pulp washing sy stem at new sources. Emissions from these sy stems are to be enclosed , vented to a closed
- vent sy stem , and routed to a control device that ei ther (1) reduce s total HAP emissions by at least 98 percent ; (2) reduces total HAP at the thermal oxidizer outlet to 20 ppmv or less ; (3) reduces total HAP emissions using a thermal oxidizer operating at a temperature > 1600 °F and a residence time > 0.75 sec onds; or (4) reduce s total HAP emissions using a boiler, lime kiln, or recovery furnace
.14

Based on information in the Part I database, all semi
- chemical mills are equipped with some ty pe of s ys tem for collecting and venting NCGs . Most mills vent the collec ted emissions to boilers, although a couple of mills vent the emissions to lime kilns. One mill uses a combination of a condenser and packed
- bed scrubber to meet the 98 percent limit. We identified no new practices, processes, or controls for pulping proce sses at semi
- chemical mills. 4 . Sulfite p ulping p rocesses The sulfite pulping process relies on acid solutions of sulfurous acid (H 2 SO 3 ) and bisulfite ion (HSO 3 - ) as the cooking liquor
. The bisulfate ion enters the process as a compound of the form M (HS O 3 - ) , where the “M” may be calcium (Ca), ammonia (NH 3 ), sodium (Na), or magnesium (Mg). Six mills reported sulfite pulping processes in re sponse to the Part I survey
. Three mill s perform NH 3 - based sulfite , two perform Ca - b ased sulfite, and one mill is co
- l ocated with k raft pulping and performs Na
- based sulfite pulping. There are no longer any Mg - based sulfite mills. Sulfite pulping is a declining segment of the s ubpart S category ; there were 16 sulfite mills in operation at rule promulgation. The subpart S pulping vent gas standards for sulfite mills apply for digester, evaporator, and washer vent gases at existing sources. At new sources, the vent gas standards also appl y for strong and weak liquor storage tanks, and acid condensate storage tanks
. Acid co ndensate storage tanks store c ooking ac id following the SO 2 gas fortification process used to generate H 2 SO 3 . Different numerical vent gas emission limits apply for Ca
- and Na
- based sulfite than for NH 3 or Mg - based sulfite. The HAP emissions at the Ca
- bas ed and NH 3 - based sulfite mills are ty pically collected and routed through a scrubber s ys tem. The HAP emissions from equipment at the co
- located kraft and Na
- based sulfite mill are controlled through the kraft LVHC sy stem. No new practices, processes, or co ntrols were identified for sulfite mills. 5 . Pulp s torage All ty pes of mills operate tanks, high density storage, stock chests, etc
. to store pulp at various points along the pulp production line, prior to bleaching, or prior to papermaking. Several pulp storage tanks are either not vented, fugitive sources , or vented inside a building. Very few controls were noted for pulp storage in the Part I responses, with the exception of a few storage tanks that are connected with the mill’s NCG sy stem (e.g., like ly because they

are part of a larger sy stem with emission limits under subpart S)
. Itwas unclear from the descriptions provided in survey

responses i f the pulp storage may have been part of another sy stem (e.g., some mills reported pulp storage for equipm ent that is part of the digester or washer sy stem). No new process changes were noted for pulp storage. 6 . Papermaking Papermaking includes equipment used to convert pulp into paper, paperboard, or market pulp, including the stock storage and preparatio n sy stems, paper or paperboard machines, paper15

machine white water s ys tem, broke recovery s ys tems, and the sy stems involved in calendering, drying, on
- machine coating, slitting, winding, and cutting. EPA previously (during original rule development) evalu ated two undemonstrated control measures that could potentially reduce HAP emissions from papermaking: (1) removal of HAPs from the pulp stock and white water before the papermaking s ys tem (e.g., with a white water steam stripper); and (2) control of paper making s ys tem vent streams through vent gas collection and incineration. Analy sis of these control options concluded that there are no demonstrated methods for removing HAPs from the pulp stock or white water and that applying HAP control to the vent streams of papermaking sy stems is not cost
- effective (Air Docket A

– 95

– 31, IV

– B

– 8 [ERG 1997a] ). Technical challenges noted with these two control options included fiber clogging of the steam stripper columns and heat exchangers, and the extremely high air flow rates from paper machines to be treated with incineration controls. The EPA also investigated the use of HAP
- containing additives in papermaking s ys tems, the magnitude of HAP emissions resulting from the use of papermaking s ystem additives, and the viabil ity

of a MACT standard based on additive substitution. Itwas concluded that additives did not contribute significantly to HAP emissions from the paper industry , with only 20 percent of the HAP additive content emitted to air , while the remaining 80 percent remained in the paper product or white water
. The industry
- wide total annual HAP emissions attributable to additives were estimated to be around 50 tpy , and were considered negligible in comparison to the industry pre - MA CT baseline emissions of over 20 0, 000 tpy of total HAPs. EPA also noted that papermaking chemical and additive suppliers are continually working to reduce the HAP content of additives, but that it was not clear from available information that substitution options are technicall y feasible f

or all products. Therefore, EPA concluded that a standard for papermaking sy stems based on low
- HAP additive substitution was not warranted at the time of promulgation in 1998. ( 72 FR 18525 - 18526 , April 15, 1998 and Air Docket A

– 95

– 31, Item IV

–B

– 6 [ERG 1997 b] )
. As part of the current technology review , the Part I IC R data along with BACT determinations for papermaking were examined to determine if there have been developments in practices, processes, or controls applicable to papermaking s ys tems since subpart S promulgation in 1998. (RTI2011b) The only available measures for reducing p apermaking HAP emissions include process changes or work practic es (e.g., practices relating to VOC in papermaking additives)
. Add
- on controls for HAP e missions have not been put into practi ce and remain undemonstrated.16

**III. References**  EPA 2002 U.S. Environmental Protection Agency Office of Compliance
. Profile of the

Pulp and Paper Industry , 2nd Edition. EPA/310
- R- 02 - 002. November 2002. EPA 2003 U.S. Environmental Protection Agen cy . Pulp, Paper, and Paperboard Industry

–

Background Information for Proposed Air Emission Standards; Manufacturing Processes at Kraft, Sulfite, Soda, and Semi
- Chemical Mills. Document No. EPA 453/R
- 93 - 050a. Research Triangle Park, NC. October 1993. EPA 2011a J. Bradfield and K. Spence, EPA. Memorandum to Docket EPA
- HQ - OAR - 2007 -

0544. Summary of Kraft Condensate Control Technology Review . October 23, 2011 EPA 2011b J. Bradfield and K. Spence, EPA. Memorandum to Docket EPA
- HQ - OAR - 2007 -

0544. Summary of Pulp Bleaching Technology Review. November 17, 2011 EPA 2011c J. Bradfield and K. Spence, EPA. Memorandum to Docket EPA
- HQ - OAR - 2007 -

0544. Summary of Clean Condensate Alternative Technology Review. October 20, 2011 ERG 1997 a Memorandum from C. Leatherwood, Ea stern Research Group (ERG), to P.

Lassiter, U.S. EPA. September 10, 1997. Maximum Achievable Control Technology (MACT) Determination For Papermaking Systems. Air Docket A

– 95

– 31, IV

–B

– 8. ERG 1997b Memorandum from C. Leatherwood, ERG, to E. Manning, EPA. March 11,

1997. Analysis of Papermaking System Additives. Air Docket A

– 95

– 31, IV

–B

– 6. NCASI2010 National Council for Air and Stream Improvement. Compilation of ‘Air Toxic’

and Total Hydrocarbon Emissions Data for Pulp and Paper Mill Sources

– A Second Upda te. Technical Bulletin No. 973. February 2010. ICR 2011 Pulp and Paper ICR Data
. RTI2011a Memorandum from T. Holloway and C. Gooden, RTI , to J. Bradfield and B Schrock, U.S. EPA. September 30, 2011. Summary of RBLC and Other Findings to Support Section 112(d)(6). RTI2011b Memorandum from V. Hanzel, RTI , to J. Bradfield and B Schrock, U.S. EPA.

August 2, 2011. Papermaking Technology Review Information Received from State Contacts. Smook 2002 Smook, G. Handbook for Pulp & Paper Technologists. 3 rd Editio n. Angus Wilde

Pub lications Inc., Bellingham WA. 2002.17 **Table 1. Summary of MACT I and III (Subpart S) Standards**  **Source limit details Typical source control**  **systems Gaseous organic HAP standard**  Kraft pulping vent gases : Existing sources: LVHC system 1 ; knotter or screen (above HAP cutoffs), pulp washing, decker (using contaminated water), and O 2 delignification. New sources: Same as existing, except applies for all knotters, screens, and deckers plus weak liquor storage tanks. Route through a closed v ent collection system to a b oiler, lime kiln, recovery f urnace, or thermal o xidizer (1) Reduce total HAP emissions by ≥98 w t%; or (2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppm v @ 10% O 2 (dry basis); or (3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600 ° F and ≥0.75 sec residence time; or (4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or (5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the co mb ustion air. Soda or semichemical pulping vent gases : Existing sources: LVHC system 1 New sources: Same as existing, plus pulp washing system. Route through a closed vent collection system to a b oiler, lime kiln, recovery furnace, or thermal o xidizer (1) Reduce total HAP emissions by ≥98 w t%; or (2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppm v @ 10% O 2 (dry basis); or (3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600 ° F and ≥0.75 secs residence ti me; or (4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or (5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the comb ustion air. Sulfite pulping vent gases : Existing sources: Digester vent, evaporator vent, and pulp washing. New sources: Same as existing, plus strong and weak liquor storage tanks, and acid condensate storage tanks. Route through a closed vent collectio n system to a s crubber or other control device (emission limits apply to combined emissions from vents, control device wastewater, and condensates) (1a) Ca - or Na - based : Emit t otal HAP (a s methanol ) ≤0.89 lb/ton ODP, or (1b) Ca - or Na - based : Reduce total HAP (as methanol) by ≥ 92%; (2a) NH 3 - or Mg -based : Emit t otal HAP (as methanol ) ≤ 2.2 lb/ton ODP, or (2b) NH 3 - or Mg -based : Reduce total HAP (as methanol) by ≥87% .18

**Source limit details Typical source control**  **systems Gaseous organic HAP standard**  New and e xisting bleaching vent gases : Chlorine bleaching systems, kraft/sulfite/soda bleaching with any chlorinated compounds, and mechanical/secondary fiber/non
wood bleaching with ClO 2 . Route through a closed vent collection system to a caustic scrubber or s imilar d evice (1) Re duce t otal chlorinated HAP (except chloroform) limit: ≥ 99 w t%, or (2) Meet ≤ 10 ppmv of t otal chlorinated HAP (except chloroform) at control device outlet , or (3) Meet ≤ 0.002 lb t otal chlorinated HAP (except chloroform)/ton ODP at control device outlet. (4) Work practice for chloroform
- either meet e ffluent guidelines or use no hypochlorite or chlorine for bleaching. Kraft pulping process condensates (process liquids) from digester, turpentine recovery, evaporator, LVHC system 1 , and HV L C system 2 (some exceptions) Route through a c losed vent collecti on systems to pulping equipment (1) Reduce total HAP emissions by ≥98 w t%; or (2) Reduce total HAP concentration at the outlet of thermal oxidizer to ≤20 ppm v @ 10% O 2 (dry basis); or (3) Reduce total HAP emissions using a thermal oxidizer operating ≥1600 ° F and ≥0.75 secs residence time; or (4) Use a boiler, LK, or RF in which the HAP gas stream in introduced with the primary fuel into the flame zone; or (5) Use a boiler or RF with a heat input capacity ≥150 MMBtu/hr (44 MW) in which the HAP gas stream is introduced with the c om bustion air. Route to biological treatment/ steam stripp er or other control device (1) Reduce total HAP ≥ 92 wt%; or (2a) For mills without bleaching, remove ≥ 6.6 lb total HAP/ton ODP, or (2b) For mills without bleaching, meet ≤ 210 ppmw total HAP at control device outlet; or (3a) For mills with bleaching, remove ≥ 10.2 lb total HAP/ton ODP, or (3b) For mills with bleaching, meet ≤ 330 ppmw total HAP at control device outlet. Clean condensate alternative (CCA) is an emissions averaging approach to offset emissions from certain existing kraft pulping sources. Install and operate clean condensate alternative technology. Emissions reductions from CCA ≥ emissions reductions achieved through kraft pulping HVLC system standards
1 The LVHC system includ es digester, turpentine recovery, evaporator, and steam strippers. 2 The HVLC system includes pulp washing, knotter, screen, decker, O 2 delignification, weak liquor storage tanks.19

**Table 2. Nationwide HAP Emissions from the Subpart S Source Category** 

**Report ed in Part II of the 2011 ICR**  **HAP Category Name Nationwide HAP emissions, tpy**  Methanol 38,650 Acetaldehyde 2,029 Cresol/Cresylic Acid (Mixed Isomers) 758 Phenol 454 Chloroform 356 Formaldehyde 274 Hydrochloric Acid 259 Biphenyl 218 Hexachloroethan e 207 Xylenes (Mixed Isomers) 137 Propionaldehyde 135 1,2,4 - Trichlorobenzene 129 Methylene Chloride (Dichloromethane) 120 Acrolein 101 Carbon Disulfide 90 Cumene 83 Toluene 82 Styrene 77 Tetrachloroethylene (Perchloroethylene) 75 Methyl Isobutyl Ketone (Hexone) 61 Acetophenone 60 Hexane 56 Carbon Tetrachloride 40 Trichloroethylene 37 Benzene (Including Benzene From Gasoline) 25 Naphthalene 24 Chlorine 24 1,1,2 - Trichloroethane 23 Methyl Chloroform (1,1,1
- Trichloroethane) 22 Ethylbenzene 18 Vinyl Acetate 16 Chlorobenzene 15 Methyl Chloride (Chloromethane) 14 Hexachlorocyclopentadiene 10 Vinylidene Chloride (1,1
- Dichloroethylene) 8 Glycol Ethers 7 Acetonitrile 5 Ethylene Dichloride (1,2
- Dichloroethane) 4 Vinyl Chloride 4 Triethyl amine 3 Carbonyl Sulfide 3 Acrylonitrile 3 Chloroacetic Acid 2 Pentachlorophenol 1 Ethylene Glycol 0.8 Diethanolamine 0.820 **HAP Category Name Nationwide HAP emissions, tpy**  Cyanide Compounds 0.7 1,3 - Butadiene 0.5 2,4,5 - Trichlorophenol 0.4 Methyl Bromide (Bromomethane) 0.3 Nickel Compounds 0.2 A crylamide 0.2 Ethylene Dibromide (Dibromoethane) 0.1 Nitrobenzene 0.1 Antimony Compounds 0.1 Lead Compounds 0.1 Propylene Dichloride (1,2
- Dichloropropane) 0.1 2 -Nitropropane 0.05 Toluene
- 2,4 - Diamine 0.02 Methyl Iodide (Iodomethane) 0.02 Chromium C om

pounds 0.02 Ethylidene Dichloride (1,1
- Dichloroethane) 0.01 Bromoform 0.01 Cadmium Compounds 0.01 Beryllium Compounds 0.01 2,4,6 - Trichlorophenol 0.01 Polycyclic Organic Matter as 15
- PAH 0.01 Manganese Compounds 0.01 Catechol 0.01 N,N - Dime thylaniline 0.005 Mercury Compounds 0.004 Arsenic Compounds(Inorganic Including Arsine) 0.004 Selenium Compounds 0.004 Dibutyl Phthalate 0.003 1,4 - Dichlorobenzene 0.003 Chlorobenzilate 0.002 Cobalt Compounds 0.002 Bis(2
- Ethylhexyl)Phthalate (Dehp) 0.001 Polycyclic Organic Matter as non
- 15 PAH 0.001 Polycyclic Organic Matter as 7
- PAH 0.001 1,1,2,2 - Tetrachloroethane 0.001 Ethylene Oxide 0.0003 Aniline 0.00001 **Total 44,726**