## Date: March 29 , 2013

Subject: Technology Review and Regulatory Options for the Kraft Pulp Mill NSPS

EPA Contract No. EP

- D

- 11

- 0 84 ; Work Assignment No. 1

- 0 8

From: Katie Hanks

, Thomas Holloway

To: Kelley Spence and Bill Schrock

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

I. Introduction

Under section 11 1 ( b )( 1 ) (B) of the Clean Air Act (CAA)

, the U.S. Environmental

Protection Agency (EPA) is required to review and, if appropriate, revise existing new

source performance standards (NSPS) at least every 8 years. The NSPS for kraft pulp

mills (40 CFR part 60, subpart BB) were promulgated in 1978 and last reviewed in 1986,

and are due for another review. The purpose o f this memorandum is to present

information on developments in practices, processes, and control technologie s that apply

to kraft pulp mills and regulatory options for EPA consideration as part of the 2013 NSPS

review

.

Section I I of this memorandum provides background information on the

requirements of CAA sec tion 111 (b)(1)(B), the kraft pulp mill source category, the

requirements of the kraft pulp mill NSPS

, and the purpose of the kraft pulp mill

emissions guidelines

. Section I II discusses the review of information on developments in

practices, processes, and control technologies that have occurred since the 1986 review of

the NSPS. Section I V summarizes the r egulatory o ptions for the 2013 review of t he

NSPS. Section V presents references.

II. Background

A. Requirements of CAA Section 111(b)(1)(B)

New source performance standards implement CAA s ection 111 (b) and are issued

for categories of sources which cause

, or significantly contribute to

, air pollution which

may reasonably be anticipated to endanger public health or welfare. The primary purpose

of the NSPS is to attain and maintain ambient air quality by ensuring that the best

demonstrated emission control technologies are installed as the industrial infrastructure is

modernized, when it is most cost effective to build in controls. Since 1970, NSPS for

many industries have been successful in achieving long

- term emissions reductions in

numerous industries by assuring that cost

- effective controls are ins talled on new,

reconstructed, or modified sources.

### 2 

## Section 111 of the CAA requires that NSPS reflect :

“ the degree of emission limitation achievable through the application of the best system

of emission reduction which (taking into account the cost of ach ieving such reduction and

any nonair quality health and environmental impact and energy requirements) the

Administrator determines has been adequately demonstrated. ”

This level of control has sometimes been referred to as “ best demonstrated technology ” or BDT.

In order to better reflect that, CAA section 111 was amended in 1990 to clarify that “ best

systems ” may or may not be “ technology. ” T he EPA is now using the term “ best system of

emission reduction” or BSER. In assessing whether a standard is achie vable, EPA must account

for routine operating variability associated with performance of the system on whose

performance the standard is based. See National Lime Ass’n v. EPA , 627 F. 2d 416, 431

– 33 (DC

Cir. 1980).

Common sources of information as to what constitutes a BSER, and for assessing that

technology’s level of performance, include emissions test data collected during development of

proposed rules, best available control technology (BACT) determinations made as part of new

source review (NSR), emiss ions limits that exist in state and federal permits for recently

permitted sources, and emissions test data for demonstrated control technologies collected for

compliance demonstration or other purposes. The EPA compares permit limitations and BACT

determi nation data with actual performance test data to identify any site

- specific factors that

could influence general applicability of this information.

Section 111 of the CAA also requires EPA to periodically review and revise the standards

of performance, as necessary, to reflect improvements in methods for reducing emissions.

Specifically, paragraph 111(b)(1)(B) states:

...The Administrator shall, at least every 8 years, review and, if appropriate, revise such

standards following the procedure required by this subsection for promulgation of such

standards. Notwithstanding the requirements of the previous sentence, the Administrator

need not review any such standard if the Administrator determines that such review is not

appropriate in light of readily available information on the efficacy of such standard.

Standards of performance or revisions thereof shall become effective upon promulgation.

When implementation and enforcement of any requirement of this chapter indicate that

emission limitations and percent red uctions beyond those required by the standards

promulgated under this section are achieved in practice, the Administrator shall, when

revising standards promulgated under this section, consider the emission limitations and

percent reductions achieved in pr actice.

For the purpose of this technology review, a n improvement 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 NSPS;

• Improvements in add

- on control technology or other equipment that were not

identified and considered during NSPS development that could result in significant

additional emissions reductions in criteria air pollutants ;

### 3 

## • Work practice or operational procedure that was not identifie d and consider ed during

NSPS development; or

• Process change or pollution prevention alternative that could be broadly applied that

was not identified and considered during the development of the NSPS.

In addition to new sources, e xisting affected sources that are modified or reconstructed

would also be subject to these revisions for affected facilities . Under CAA section 111(a)(4),

“modification” means any physical change in, or change in the method of operation of, a

stationary source which increases the amount of any air pollutant emitted by such source or

which results in the emission of any air pollutant not previously emitted. Changes to an existing

source that do not result in an increase in emissions are not considered modifications. A similar

definition of modification is included in 40 CFR subpart A (the NSPS General Provisions).

“Reconstructed” affected sources would become subject to the standards regardless of

changes in emission rate. “ Reconstruction ” means the replacement of components o f an existing

process unit such that (1) the fixed capital cost of the new components exceeds 50 percent of the

fixed capital cost that would be required to construct a comparable entirely new stationary

source ; and (2) it is technologically and economical ly feasible to meet the applicable standards

. (40 CFR 60.15)

B. Kraft Pulp Mill Source Category

In the kraft pulping process, wood chips are cooked (digested) at an elevated temperature

and pressure in white liquor, which is a water solution of sodium sulfide (Na 2 

## S) and sodium

hydroxide (NaOH). The white liquor chemically dissolves lignin from the wood. The remaining

cellulose (pulp) is filtered from the spent cooking liquor and washed with water. Usually, the

pulp then proceeds through various intermittent st ages of washing and possibly bleaching, after

which it is pressed and dried int o the finished product ( e.g., paper , paperboard ).

The balance of the kraft pulping process is designed to recover the cooking chemicals and

heat. Spent cooking liquor and the p ulp wash water are combined to form a weak black liquor

which is concentrated in a multiple

- effect evaporator system to about 55 percent solids. The

strong black liquor from the evaporators is then further concentrated to about 65 percent solids in

a conce ntrator (non

- direct contact evaporator [NDCE]) or a direct

- contact evaporator (DCE). If

the black liquor is further concentrated in a DCE, the liquor is first oxidized in a black liquor

oxidation ( BLO ) system to convert the sulfide to thiosulfate, which re sult s in a more stable liquor

that results in less odor when process ed . The strong black liquor is then fired in a recovery

furnace. Combustion of the organics dissolved in the black liquor provides heat for generat ing

process steam and converts sodium sul fate (Na 2 

## SO 4 

## ) to Na 2 

## S . To make up for chemicals lost in

the operating cycle, salt cake ( Na 2 

## SO 4 

## ) may be added to the concentrated black liquor before it is

sprayed into the furnace.

Inorganic chemicals present in the black liquor collect as a molten smelt at the bottom of

the furnace. The smelt, consisting of sodium carbonate (Na 2 

## CO 3 

## ) and Na 2 

## S , is dissolved in water

in a smelt dissolving tank ( SDT ) to form green liquor

, which is transferred to a causticizing tank

, where lime (CaO) is added to convert the Na 2 

## CO 3 

## to NaOH . Formation of the NaOH completes

the regeneration of white liquor, which is returned to the digester system. A calcium carbonate

### 4 

## (CaCO 3 

## ) mud , referred to as “lime mud,” precipitates from the causticizing tank and is calcine d

in a lime kiln to regenerate the lime. A simplified diagram of the kraft pulping process is

provided in Figure 1.

Figure 1. Simplified Diagram of the Kraft Pulping Process

C. Requirements of the Kraft pulp mill NSPS

1. Background

The kraft pulp mill NSPS (40 CFR part 60, subpart BB) was promulgated on Feb ruary

23, 1978 and last reviewed on May 20, 1986. A complete list of the relevant Federal Register

( FR ) actions associated with the NSPS is provided in Table 1. The NSPS applies to the following

emiss ion units installed after September 24, 1976 at facilities that perform kraft pulping:

• Digester systems

• Brown stock washer systems

• Multiple

- effect evaporator systems

• Condensate stripper systems

• Blac k liquor oxidation systems ChipsDigester



### Pulp & Black

Liquor

Washers

Evaporators

(Tall Oil)

Recovery

Furnace /

Smelt

Dissolving

Tank 

### Caustic Plant Lime

CaO



## Lime Kiln

Lime Mud

CaCO 3 

### Green Liquor

Na 2 

### S, Na 2 

### CO 3 

### Strong Black

Liquor Weak

Black Liquor Wash Water

Pulp to

screens and

cleaners White Liquor

Na 2 

### S, NaOH 

# Subpart S

Subpart MM

NSPS

### 5 

## • Recovery furnaces

• Smelt dissol ving tanks (SDTs)

• Lime kilns

There are currently 98 kraft pulp mills in the U.S., and 90 of those mills have at least one

emission unit subject to the NSPS. The e mission units covered under the subpart BB NSPS are

also covered under two national emission standards for hazardous air pollutants (NESHAP) for

the pulp and paper industry , both found in 40 CFR part 63 :

• Subpart S (NESHAP from the pulp and paper industry); and

• Subpart MM (NESHAP for chemical recov ery combustion sources at kraft, soda, sulfite,

and stand

- alone semichemical pulp mills).

As indicated in Figure 1, digester systems, brown stock washers, evaporators, and condensate

strippers are regulated for hazardous air pollutants ( HAPs ) under the sub part S NESHAP. Black

liquor oxidation units, recovery furnaces, lime kilns, and SDTs are combustion sources regulated

for HAPs under the subpart MM NESHAP. The NESHAP are based on maximum achievable

control technology (MACT) as specified under the CAA sect ion 112.

The kraft pulp mill NSPS regulates particulate matter (PM ) and total reduced sulfur

(TRS). Particulate matter standards for digester systems, evaporators, brown stock washers,

black liquor oxidation, and condensate strippers are not applicable be cause these sources do not

generate PM. The TRS compounds are defined under the kraft pulp mill NSPS to include the

following four compounds: hydrogen sulfide (H 2 

## S), methyl mercaptan, dimethyl sulfide, and

dimethyl disulfide. (40 CFR 60.281) Table 2 summar izes the current NSPS emission limits and

work practice standards for kraft pulp mills.

In addition to emission limits, the subpart BB recovery furnace PM and TRS standards

also include monitoring allowances. These allowances are provisions that allow a s ource to

exceed the standard for a given period of time, but the exceedance is not considered a violation

of the standard. The current NSPS contains a 6 percent monitoring allowance for recovery

furnace opacity and a 1 percent monitoring allowance for reco very furnace TRS. These

allowances are based on a percentage of continuous monitoring averaging periods. Aside from

the monitoring allowances, the applicable PM and TRS limits in subpart BB apply at all times

except during periods of startup, shutdown, and malfunction.

### 6 

## Table 1. List of Federal Register Notices Associated with the Kraft Pulp Mill NSPS

FR notice FR citation Nature of FR notice

September 24,1976 41 FR 42015 Original proposal of kraft pulp mill NSPS

February 23, 1978 43 FR 7572 Original p romulgation of kraft pulp mill NSPS

January 19, 1984 49 FR 2455 Proposal of kraft pulp mill NSPS review

February 14, 1985 50 FR 6317 Amendment to TRS emission limit for digesters;

addition of innovative technology waiver (40 CFR

60.286) for kraft pulp mill in Clyattville, Georgia

May 20, 1986 51 FR 18544 Promulgation of kraft pulp mill NSPS review

February 14, 1989 54 FR 6673 Amendments to test methods and procedures

May 17, 1989 54 FR 21344 Technical corrections to the February 14, 1989

amendments

February 14, 1990 55 FR 5212 Additional technical corrections

October 17, 2000 65 FR 61759 Amendments to testing and monitoring provisions

adding continuous monitor performance specifications

and 40 CFR Appendix F requirements

September 21, 2006 71 FR 55 127 Technical correction to remove 40 CFR Appendix F

which was inadvertently added in October 2000

Table 2

. Summary of the 40 CFR Part 60 Subpart BB NSPS for Kraft Pulp Mills

Affected s ources New sou rce performance standards

Particulate m atter Total reduced s ulfur

Digester s ystem N / A

- Combust emissions from affected source in one of the

following:

(a) lime kiln subject to subpart BB (8 ppm dv TRS limit)

(b) recovery furnace subject to subpart BB (5 or 25

ppm dv TRS limit)

(c) incinerator, recovery furnace , or lime kiln not

subject to subpart BB

, must be operated at a minimum

temperature of 650 o 

### C (1200 o 

### F) for 0.5 sec (no ppm dv

limit)

— OR

—

- Use non

- combustion control device with a limit of 5

ppm dv

— OR

—

- No control required if emissions are below 5 ppm dv Brown stock

washers

Evaporators

Condensate s tripper

s ystem

Recovery f urnace

- 0.10 g/dscm (0.044 gr/dscf) @

8% O 2



### - 35% opacity

- 6% monitoring allowance for

opacity - Straight 1 

### : 5 ppm dv @ 8% O 2



### - Cross 2 

### : 25 ppm dv @ 8% O 2



### - 1% monitoring allowance for TRS

Smelt dissolving

t ank 0.1 g/kg (0.2 lb/ton) BLS dry

weight 0.016 g/kg (0.033 lb/ton) BLS as H 2 

### S

Lime k iln

- Gas

- fired kilns : 0.15 g/dscm

(0.066 gr/dscf) @ 10% O 2



### - Liquid fuel

- fired kilns : 0.30

g/dscm (0.13 gr/dscf) @ 10% O 2 

### 8 ppm dv @ 10% O 2

1 

### A straight recovery furnace is one that only burns kraft pulping liquors

. 2 

### A cross recovery furnace is one that burns kraft and neutral sulfite semi

- chemical pulping liquors

.

### 7 

## 2. Technology B asis for Original NSPS

The basis for the original NSPS was documented for proposal in the September 1976

document Standards Support and Environmental Impact Statement Volume I : Proposed

Standards of Performance for Kraft Pulp Mills

, and public comments on the proposed NSPS

were addressed for promulgation in the December 1977 document Standards Support and

Environmental Impact Statement Volume II : Promulgated Standards of Performance for Kraft

Pulp Mills

. (EPA 1976, EPA 1977)

The original standards were based on data on emission control systems and methods of

process operation received through (1) on

- site observations of plant processes and control

equipment, (2) consultation with industry representatives and control equipment vendors,

(3) emission tests conducted by EPA and contr ol equipment vendors, and (4) meetings with the

National Air Pollution Control Techniques Advisory Committee (NAPCTAC). (EPA 1976)

The selection of the best demonstrated technology (later referred to as best system of

emission reduction ) considering costs for the original kraft pulp mill NSPS was based on an

evaluation of the incremental impacts (compared to average state standards) on air emissions, air

pollution control costs, energy requirements, water pollution, and solid waste polluti on. (EPA

1976) The first step was to select the most effective emission reduction methods for each

affected facility; then the impacts of the individual methods were compared to determine the best

emissi on reduction method. (EPA 1976) The results , as repor ted in EPA 1976 and

revised/ affirmed in EPA 1977 and at promulgation ( 43 FR 7569 to 7570 )

, are summarized in

Table 3.

### 8 

## Table 3 . Technology Basis for the Original Subpart BB NSPS Promulgated in 1978

Affected source Particulate m atter Total reduced s ulfur



### Digester system Not applicable Incineration of the gases in the recovery furnace, lime

kiln, or separate incineration unit. Brown stock washers

Evaporators

Condensate stripper

system

Black liquor oxidation

Recovery furnace Use of an electrostatic

precipitator (ESP) with

a collection efficiency

of approximately 99.5

percent Either a DCE recovery furnace with two or more stages

of black liquor oxidation or an NDCE recovery furnace

with good combustion control in the furnace. In

response to public comments on the NSPS proposal, a

separate TRS standard for cross recovery furnaces

issued after proposal took into account the difference in

the sulfidity of the black liquor burned in cross recovery

furnaces and the heat content of the liquor, both of

which were considered significant factors influencing

TRS emissions.

Smelt dissolving tank Use of a low

- energy

water scrubber or a

combination

demister/low

- energy

water scrubber Use of water that is not highly contaminated with

dissolved sulfides for dissolving the smelt and for

scrubbing.

Lime kiln Use of a 30

- inch water

pressure drop venturi

scrubber More efficient process controls and use of caustic

solution in the scrubber. Efficiency improvements to the

process controls included raising the c old

- end

temperature as much as 100°F, while maintaining the

proper oxygen (O 2 

### ) concentration and temperature, to

provide better combustion conditions in the kiln, and

improving the efficiency of the mud washing used prior

to the calcining process.

### 9 

## 3. NSPS R eview (1986)

In accordance with CAA section 111(b)(1)(B), EPA conducted a review and proposed

revisions to the kraft pulp mill NSPS on January 19, 1984

, and promulgated revi sions on May

20, 1986. The findings of the review w e re published in the September 1983 document Review of

New Source Performance Standards for Kraft Pulp Mills (EPA 1983) and aff irmed at

promulgation (51 FR 18537 , May 20, 1986 ) . The review found that:

• N o new control technology had emerged since the original NSPS;

• Some recovery furnaces with wet

- bottom ESPs using unoxidized black liquor had

experienced an increase in TRS emissions through the ESP

, resulting in TRS emissions

above the NSPS, with modifications made or under investigation to achieve NSPS

compliance;

• There was a larger range of variation in TRS emissions from well

- controlled SDTs than

indicated by data obtained during NSPS development;

• Most lime kilns subject to the NSPS had demonstrated compliance with the TRS standard

without scrubber caustic addition, but, without continuo us monitoring data, there were

insufficient data to judge whether the kilns could continuously achieve the TRS standard

without caustic scrubbing;

• Controlling PM so urces was determined to be cost

- effective because the recovered PM is

a valuable material (e .g., lime, salt cake) ;

• The cost effectiveness of TRS control for the BLO system was estimated to be

$9,250/ton, due to the small amount (16 tons per year) of TRS controlled ;

• The cost effectiveness of TRS incineration control for the brown stock washer syst em was found to range from $900/ton for diffusion washers (installed at newer mills) to

$2,500/ton for vacuum drum washing systems ( c ost effectiveness in February 1982

dollars; updated to October 2012 d ollars, cost effectiveness range s from $ 1,700 /ton to

$ 4,600 /ton) ;

• Method 16A was determined to be equivalent to and less expensive than Method 16 so

Method 16A was added as an alternative ;

• High volume low concentration ( HVLC ) gases from NSPS facilities were most

commonly found to be incinerated in a power boiler instead of a recovery furnace; and

• There was no need to monitor combustion temperatures from devices other than an

incinerator if compliance with a minimum temperature of 1200°F for at least 0.5 second

had been demonstrated, because thes e devices would normally operate at temperatures

higher than that required by the NSPS.

Based on the aforementioned conclusions, t h e kraft pulp mill NSPS was revised in 1986

as follows (EPA 1983, 51 FR 18537) :

• T he SDT TRS limit was raised from 0.0084 to 0.016 gram per kilogram of black liquor

solids ( g/kg BLS ) ( 0.0168 to 0.033 lb/ton BLS) because some units with the installed

technology could not meet the original limit;

• T he TRS limit for BLO units was removed because of the high cost effectiveness of

control and the trend towards NDCE recovery furnaces (which do not require BLO units

to meet the NSPS);

### 10 

## • T he units of the SDT TRS standard were changed from “g/kg BLS” to “g/kg BLS as

H 2 

## S” to permit the use of Method 16A to demonstrate compliance; and

• T he temperature monitoring requirements were removed for lime kilns and recovery

furnaces used to combust gases from other affected sources if compliance with a

minimum temperature of 1200°F for at least 0.5 second ha d been demonstrated.

In addition to inv estigating whether the existing standards should be revised to reflect

improvements in emissions reduction methods , the 1986 review also investigated whether the

standards should be extended to include other processes and pollutants . In its 1986 review, EP A

concluded that standards for other processes and pollutants should not be considered at that time

as summarized below

. (EPA 1983)

At the time the original NSPS was proposed, EPA noted that all process gas streams were

covered by the NSPS except for power boilers and water treatment ponds. (EPA 19 76 ) Power

boilers, which are a source of PM emissions from kraft pulp mills, were not included in the

original NSPS because EPA intended to develop standards for industrial boilers in a separate rule

that wou ld include power boilers at kraft pulp mills. (EPA 19 76 ) When the 1986 NSPS review

was being conducted , EPA noted that the standard for industrial boilers was in the process of

being proposed. (EPA 1983) Therefore, there was no need to extend the kraft pul p mill NSPS to

include power boilers at kraft pulp mills.

Water treatment ponds, which are potentially significant sources of TRS emissions, were

not included in the original NSPS because methods of meas uring TRS emissions from the po nds

were not availab le at that time , and further investigation of possible measurement and control

technology was needed. (EPA 19 76 ) The 1986 review concluded that this rationale still applied

(i.e., no proven sampling method was available), but also noted that condensate str ipping

systems ha d been installed at most new pulping operations to control biological oxygen demand

( BOD ) , odor from recycle water, or odor from ponds. (EPA 1983) Consequently, the review

co ncluded that, at the time, that there was no justification to rev ise the NSPS to include treatment

ponds. (EPA 1983)

In addition to PM and TRS, t he original NSPS noted that kraft pulp mills are also sources

of sulfur dioxide ( SO 2 

## ), nitrogen oxides ( NOx ) , and carbon monoxide ( CO ) emissions and

specifically identified r ecovery furnaces, lime kilns, and power boilers as sources of these

emission s. (EPA 1976) As noted previously, emissions from power boilers a re covered under a

separate rule for industrial boilers. The original NSPS did not include SO 2 

## , NOx, and CO

emissions from recovery furnaces and lime kilns because no demonstrated control techniques,

considering costs, had been identified for these pollutants and sources in the kraft pulping

industry . (EPA 1976) The 1986 review c oncluded that this rationale still applied , but indicated

that a study should be performed to investigate SO 2 

## emission control methods and determine

whether regulation was appropriate

. (EPA 1983)

D. Emission Guidelines

Section 111(d) of the CAA requires that “designated” pollutants controlled under

standards of performance for new sources (section 111(b)) also be c ontrolled at existing sources

in the same source category. Designated pollutants exclude those pollutants listed for regulation

### 11 

## under national ambie nt air quality standards ( NAAQS ) and NESHAP. Of the two pollutants (PM

and TRS) regulated under the kraft pulp mill NSPS , one (PM) is criteria air pollutant (CAP)

listed for regulation under NAAQS. Therefore, TRS is the only designated pollutant for existi n g

sources and was addressed in the emission guidelines for kraft pulp mills.

Subpart B of 40 CFR part 60 contains the procedures and requirements under which

states submit plans to control existing sources of designated pollutants. Subpart B provides that

, after NSPS are promulgated, EPA is to publish a draft guideline s document containing

information pertinent to the control of the pollutant from existing sources, publish a notice of

availability of the draft guidelines, invite comments, and then publ ish a final guidelines

document. The final guidelines document for kraft pulp mills, Kraft Pulping: Control of TRS

Emissions from Existing Mills

, was published in March 1979 (EPA 1979), and a notice of

availability of the final guidelines document was publ ished in the Federal Register on May 22,

1979

. (44 FR 29828) Table 4 summarize s the emission guidelines that were pub lished in the

guideline document for existing sources at kraft pulp mills

.

Table 4

. TRS Emission Guidelines for TRS for Kraft Pulp Mills

Affected s ources E mission guidelines for TRS

Digester s ystem 5 ppmdv as H 2 

### S (12

- hr avg )

Brown stock washers NA 1



### Evaporators 5 ppmdv as H 2 

### S (12

- hr avg)

Condensate s tripper s ystem 5 ppmdv as H 2 

### S (12

- hr avg)

Recovery f urnace

- Straight (designed for low TRS emissions) 2 

### : 5 ppm dv as H 2 

### S @ 8% O 2 

### (12

- hr avg )

- Straight (all other) 2 

### : 20 ppm dv as H 2 

### S @ 8% O 2 

### (12

- hr avg)

- Cross 3 

### : 25 ppm dv as H 2 

### S @ 8% O 2 

### (12

- hr av g )

- 1% monitoring allowance for TRS

Smelt dissolving t ank 0.0 0 84 g/kg (0. 0 168 lb/ton) BLS as H 2 

### S (12

- hr avg)

Lime k iln

- 20 ppm dv as H 2 

### S @ 10% O 2 

### (12

- hr avg )

- 2% monitoring allowance for TRS

Source: EPA 1979

1 

### No emissions guideline was developed for brown stock washers due to the high costs associated with hooding and

gas collection and the possible effect that gases were believed to have on existing recovery furnaces.

2 

### A straight recovery furnace is one that only burns kraft pulping liquors

. Straight recovery furnaces designed for low

TRS emissions refer to NDCE recovery furnaces , while a ll other straight recovery furnaces refer to DCE recovery

furnaces.

3 

### A cross recovery furnace is one that burns kraft and neutral sulfite semi

- chemical pulping liquors

.



## States were given 9 months to develop and submit plans for controlling the designated

pol lutant, with EPA approval or disapproval of each plan (or portion thereof) given within

4 months. States that did not submit an approvable plan or revision to a disapproved plan became

subject to an EPA

- promulgated plan. (44 FR 29828 , May 22, 1979 ) The statute and EPA’s

regulations in 40 CFR 60.24 allow states and the EPA to set less stringent standards or longer

compliance schedules for existing sources where warranted considering cost of control; useful

life of facilities; location or process desi gn at a particular facility; physical impossibility of

installing necessary control equipment; or other factors making less stringent limits or longer

compliance schedules appropriate.

Unlike the NSPS, CAA section 111 does not require periodic review of the emission

guidelines. Therefore, only the requirements under the NSPS are currently u ndergoing review.

Section III below discusses the present (2013) NSPS technology review

.

### 12 

## III. 2013 NSPS Technology Review

The practices, processes, and controls currently in use in kraft pulp mills were reviewed

to formulate regulatory options for the 2013 NSPS review. Several information s ources were

used as part of the 2013 technology review, including:

• Process, equipment, and control device details from industry responses to EPA’s 2011

information collection request ( ICR ) ;

• Permit limits from permits submitted with the ICR and collected from state agencies ;

• RACT/BACT/LAER Clearinghouse (RBLC) ;

• A 20 1 0 European Commission document entitled Integrated Pollution Prevention and

Control (IPPC): Reference Document on Best Available Techniques in the Pulp and

Paper Industry ;

• A document from the State and Territorial Air Pollution Program Administrators and the

Association of Local Air Pollution Co ntrol Officials (STAPPA/ALAPCO) titl ed

Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options ;

• Stack test data for PM and TRS ;

• Continuous opacity monitoring system (COMS) data for recovery furnaces a nd lime

kilns ;

• TRS c ontinuous emissions monitoring system (CEMS) dat a for recovery furnaces

, lime

kilns , and NCG sources ; and

• T echnical bulletins prepared by the National Council for Air and Stream Improvement,

Inc. (NCASI)

, a major source of environmental data affecting the pulp and paper

industry

.

The conclusions from our review of the above information are consolidated in this

memorandum

. Separate memoranda provide a detailed discussion of the data sets and

infor mation sources described above. (EPA 2013a, EPA 2013b , RTI 2012, RTI 2013a ) The

following subsections discus s TRS emissions from NCG sources (section A), and PM and TRS

emissions from recovery furnaces (section B), lime kilns (section C), and SDTs (section D).

Extension of the NSPS to other processes and pollutants is discussed in section E.

A. Non

- condensable G as Sources

Subpart BB limits TRS emissions from digesters, brown stock washers, multiple

- effect

evaporators, and condensate strippers to 5 parts per million dry volume ( ppmdv ) at 10 percent O 2



## based on incineration of TRS

- laden NCG s from these emission sources in a thermal oxidizer,

power boil er, lime kiln, or recovery furnace

. In addition to TRS, NCG s from digesters, brown

stock washers, multiple

- effect evaporators, and condensate strippers emit HAP s, which are

regulated under t he 40 CFR pa rt 63 , subpart S NESHAP based on the performance of t he same

incineration controls that are the basis for the NSPS. For mills using a thermal oxidizer, an

incineration temperature of 1200 o 

## F is required to demonstrate destruction of TRS under the

NSPS . A thermal oxidizer temperature of 1600 o 

## F is required for reduction of HAP under the

NESHAP

. The EPA's prior analysis indicates that while the NSPS requirements of 1200 o 

## F and

0.5 seconds residence time are sufficient to achieve 98 percent destruction of TRS c ompounds,

kinetic calculations for methanol (the majority of HAP in pulping vent gases) show that the

NSPS criteria will not provide the required 98 percent reduction of HAP s. (EPA 1997 )

### 13 

## There are some exceptions to incineration

- based controls under both the NESHAP and

NSPS that are discussed in the paragraphs below. Methods of reducing emissions other than

incineration

- based controls are allowed under both the NSPS and NESHAP, provided that the

alternative controls meet the emission limits in each rule. Alternatives to incineration, such as

scrubbing, are less effective at the removal of TRS because only two of the four TRS compounds

( H 2 

## S and methyl mercaptan) are acidic enough to be removed with alkaline scrubbing, resulting

in a removal efficiency much lower than that achieved by incineration.

Digester systems with exhaust gases containing TRS at less than 0.01 pound per ton of

air

- dried pulp ( lb/ton ADP ) are not required to meet the NSPS limit. However, there is no

exemption for digester NCG under the NESHAP , except perhaps for chip steamers using fresh

steam , by definition

.

Brown stock washer systems result in NCG streams tha t are more dilute than the NCGs

from digester, evaporator, and condensate stripper systems. Under the s ubpart S NESHAP,

brown stock washer vent gases are characterized as HVLC NCGs

, while vent gases from

digester, evaporator, and condensate stripper system s are characterized as low volume high

concentration (LVHC) NCGs. The HVLC and LVHC NCGs are typically routed through

separate vent gas collection systems (for safety reasons) to incineration

- based control. In some

cases, collecting HVLC vent gases from brown stock washer systems for incineration may not be

the most effective means of reducing emissions associated with brown stock washers (e.g.,

situations where there is not enough vent gas incineration capacity at the mill to handle the

HVLC in addition to the LVHC). Both the NSPS and NESHAP account for situations where it is

not feasible to collect and incinerate brown stock washer vent gases. T he NSPS con tains a

provision where mills may be exempted from the TRS limit for new, modified, or reconstructed

brown stock washers if they demonstrate to the Administrator’s satisfaction that incinerating the

exhaust gases from the washer system is technologically o r economically unfeasible. Any

exempted washer system will become subject to the NSPS provisions if the facility is changed so

that the washer vent gases can be incinerated. Under the NE S HAP, H VLC emissions from

existing or new sources may be offset throug h use of the clean condensate alternative (CCA)

standards, where additional process liquids (condensates) are treated to reduce HAP emissions

by an amount equal to or greater than the HAP reduction that would be achieved by controlling

certain HVLC vent ga s streams. Thirty

- eight kraft mills have integrated the CCA compliance

strategy into the ir operations and are achieving equal or better reductions in HAP emissions than

would be achieved through in cineration of HVLC gases

. (EPA 2011)

Different types of brown stock washers exist with in the pulp and paper industry. Vacuum

drum washers are the most commonly used type of washer and represent mature washing

technology that has been in place for years. Pressure and diffusion washers are also being put

into ser vice as vacuum drum washers reach the end of their useful life. Pressure and diffusion

washers are considered low

- emitting washers because they do not vent to the atmosphere.

Diffusion washers were excluded from coverage under the NSPS with the 1986 NS PS r eview

due to their low emis s i ons.

### 14 

## In addition to reviewing the requirements of NESHAP subpart S for NCG sources, TRS

CEMS data , permit limits, and the RBLC were reviewed to reevaluate the subpart BB TRS

limits. A residual risk and technology review for subpart S was completed in 2012. (77 FR

55698, September 11, 2012)

NCG source TRS p ermit l imits

. As discussed in a separate memorandum, permit limits

for kraft pulping processes emitting NCGs were reviewed. (EPA 2013a) The permits for

condensate strippers (if applicable), brown stock washers, digesters, and evaporators at 97 kraft

pulp mills were tabulated. Condensate strippers are located at 56 of the mills for which permits

were reviewed

, and all are permitted to treat off gases using incineration. The majority of brown

stock washer systems (58) are permitted to treat gases through incineration, but 36 comply with

the CCA in the subpart S NESHA P or the diffusion washer exemption in the N SPS. Three units

permitted for a TRS limit of 5 ppmdv uncorrected for O 2 

## achieve this limit through controls other

than combustion. (EPA 2013a)

RBLC

. A recent search of the RBLC for information on air pollution control options in

the kraft pulp ing industry found that emissions of TRS from the digesters at 12 kraft pulp mills

are controlled by venting to a lime kiln, NCG incinerator, or boiler. The TRS emissions at one of

these mills are further controlled by adjust ing the p H of the boiler’ s scrubber w ater to 8.0 prior to

incinerati n g the TRS in the boiler

. (RTI 2012) Other than this process change unique to one

mill’s NCG system, no other evidence of additional TRS control of NCG sources beyond vent

gas incine ration was found in the RBLC.

NCG source TRS e missions data . As discussed in a separate memorandum, TRS CEMS

data for kraft pulping processes emitting NCGs were reviewed. (EPA 2013b) The TRS data sets

were available for four systems (other than recovery f urnaces or lime kilns) controlling TRS

emissions from NCG sources: 1



## • A scrubber system controlling TRS from a washer,

• A power boiler used as backup control for digester and washer system, and

• Two thermal oxidizers controlling emissions from condensate stri ppers, evaporators,

digesters.

For three of the above systems, the maximum 12

- hour TRS concentration during the year

provided approached 5 ppmdv at 10 percent O 2 

## (4.4, 4.8, and 4.9 ppmdv), and one system

reached a maximum of 16 ppmdv (though it was less t han 5 ppmdv on average). 2 

## Based on this

limited amount of data, the current NSPS limit of 5 ppmdv was judged to be the appropriate limit

for each of these operations. (EPA 2013b)

Regulatory options for NCG source TRS

. Digester system, multiple

- effect evaporator

system, and condensate stripper system NCGs are collected through the LVHC system under

Subpart S for incineration control. Brown stock washer system NCG s are collected through the

HVLC system under Subpart S for incineration control, or are off set with the CCA. The

incineration

- control technology used for NESHAP compliance is the same as that needed to meet

1 

### Recovery furnaces and lime kilns, which have TRS limits in the NSPS separate from NCG sources, are also used

for NCG control. Those systems are reviewed in later sections of this memorandum

. 2 

### Note that the TRS emissions from the scrubber

- controlled washer were uncorrected for O 2 

### because this system is

not a combustion source.

### 15 

## the TRS emission limit under the NSPS

, and the incineration control technology has not changed

over the years. In many respects the NESHAP i s more expansive in its coverage of NCG sources

than the NSPS (e.g., because the NESHAP targets HAP emissions while the NSPS targets the

largest sources of TRS emissions), such that additional reductions in TRS emissions from kraft

pulp mills have occurred as a result of the TRS co

- control benefits of the NESHAP.

Implementation of the NESHAP has expanded use of incineration

- based controls and mills are

likely to have made process monitoring improvements to ensure the reliability and effectiveness

of NCG gas collection systems and incineration

- based controls as part of NESHAP

implementation. 02 While TRS control will benefit from enhancements of NCG collection and

control systems made for NESHAP implementation, the underlying technology that is the basis

of th e 5 ppmdv TRS limit has not changed. In addition, TRS CEMS data for NCG sources show

that the 5 ppmdv TRS limit remains representative of the performance of incineration

- based and

non

- incineration based control. Therefore, no regulatory options for changin g the TRS limit were

identified for the NSPS review.

B. Recovery Furnaces

The purpose of the kraft recovery furnace is to : (1) recover ino rganic pulping chemicals

(e.g., Na 2 

## S) ; and (2) produce steam. Inputs to the furnace include concen trated black liquor,

combustion air, and auxiliary fuel . A uxiliary fuel is typically only used during startup or

shutdown . Outputs from the recovery furnaces include molten smelt (primarily Na 2 

## S and

Na 2 

## CO 3 

## ), flue gases, and steam. The smelt exits from the bottom of the furnace into an SDT,

where th e recovery of kraft pulping chemicals continues. Particulate matter (primarily Na 2 

## SO 4 

## [salt cake] and Na 2 

## CO 3 

## ) entr ained in the flue gases is also recovered using an ESP , collected in a

chemical ash tank or salt cake mix tank

, and sub sequently added to the c oncentrated black liquor.

Steam produced by the recovery furnace is used in other processes around the mill or for

electricity generation

.

As noted previously, p rior to being fired in the recovery furnace, the black liquor is

concentrated using an NDCE or DCE. The NDCE is an indirect, steam

- heated black liquor

concentrator. The DCE uses the hot combustion gases exiting the furnace to increase the solids

content of the black liquor. A BLO system precedes the DCE to reduce malodo rous TRS

emissions (primarily H 2 

## S) that can be stripped in the DCE when hot flue gases from the recovery

furnace come in contact with the black liquor. The BLO system uses molecular oxygen or air to

oxidize Na 2 

## S to nonvolatile sodium thiosulfate (Na 2 

## S 2 

## O 3 

## ) to reduce the potential for stripping.

Either weak or strong black liquor may be oxidized in the BLO, and some BLO systems are

comprised of multiple oxidation stages. (EPA 2001)

Data from EPA’s 2011 ICR indicate that 149 recovery furnaces are currently operating in

the U.S , including 41 DCE recovery furnaces and 108 NDCE recovery furnaces

. 3 

## Three DCE

and 75 NDCE recovery furnaces are subject to the NSPS. Thus, a total of 78 recovery furnaces

(52 percent of the population) are subject to the current subpart BB NSPS. Electrostatic

precipitators designed to capture recovery furnace PM for reuse are the most commonly used to

3 

### Two additional DCE recovery furnaces with a wet

- bottom ESP were included in the ICR responses but are no

longer operating (for a total of 151 recovery furnaces reported in the ICR, including 43 DCE furnaces and 108

NDCE furnaces).

### 16 

## control emissions. However, a few mills use wet scrubbers. The ICR data indicate that 143

recovery fur naces (96 percent) have ESPs, 2 recovery furnaces have wet scrubbers, and 4

recovery furnaces have ESP

- scrubber combinations. The PM controls used by the 78 recovery

furnaces subject to the NSP S include 77 ESPs and 1 ESP

- scrubber combination

. ( RTI 2013b,

R TI 2013c )

Elect r o static precipitators used to control PM emissions from kraft recovery furnaces

typically have two parallel chambers (i.e., flue gas passages) with three or four electrostatic

fields per chamber. ( EPA 2001 ) Recovery furnace ESPs can be further characterized as wet

- or

dry

- bottom ESPs having either a wet or dry PM return system. Either oxidized or unoxidiz ed

b lack liquor is used in a wet

- bottom ESP to collect the PM and carry it to the salt cake mix tank

via a wet PM return system. In a dry

- bottom ESP , the capture d PM is routed to the mix tank via a

screw conveyor or drag chain without the use of liquid, typically with a dry PM return syste m.

However, there are some dry

- bottom ESPs with a wet PM return system in which black liquor is

used to transport the dry collected PM to the mix tank

. Table 5 presents a breakout of the

different types of control systems used on DCE and NDCE recovery furnaces.

Table 5 . Breakout of Recovery Furnace Control Systems

Recovery Furnace Control Type DCE NDCE Total

DBESP 10 78 88

DBESP/SCBR 1 1 2

DBESP

- WPR 3 12 15

DBESP

- WPR/DBESP/DBESP NA 1 1

DB

- WBESP [2

- sided dry and wet] NA 1 1

SCBR NA 2 2

WBESP 25 13 38

WBESP/SCBR 2 NA 2

Total 41 108 149

DBESP = dry

- bottom ESP, WBESP = wet

- bottom ESP, SCBR = scrubber, and

WPR = wet PM return . If “WPR” is not specified for DBESP, then the ESP has a dry PM return

system. WBESPs use wet PM return systems.

1. Particulate Matter from Recovery Furnaces

The current NSPS PM limit for new, modified, and reconstructed recovery furnaces is

0.044 grain per dry standard cubic foot (gr/dscf) at 8 percent O 2



## . The NSPS PM limit is

equivalent to the PM limit for existing recovery furnaces under NESHAP subpart MM.

However, the subpart MM limit for new and reconstructed recov ery furnaces is 0.015 gr/dscf at 8

percent O 2



## . In addition to the ICR data base, p ermit limits, information from the RBLC

, European Commission and STAPPA/ALAPCO guidance document s, and stack test data were

reviewed in order to evaluate this recovery fur nace NSPS PM limit. The results of these reviews

are summarized in the paragraphs below.

Recovery f urnace PM permit l imits

. As discussed in a separate memorandum, permit

limits for 151 recovery fur naces were reviewed. (EPA 2013 a) The majority of the units (7 4 ) are

permitted to meet the NSPS and existing source NESHAP limit of 0.044 gr/dscf. Three units are

### 17 

## permitted to meet the new source NESHAP limit of 0.015 gr/dscf, and three units not subject to

the NSPS are permitted higher than the NSPS and NESHAP limit because they are debit sources

in the PM bubble compliance alternative. The remaining 71 units are permitted between 0.02 and

0.043 gr/dscf, with 3 3 of these units being located at facilities that utilize the PM bubble

compliance alternative. The review of the permits of PM from recovery furnaces show s that

some units can be expected to perform better than the limit because they are credit sources in the

PM bubble c ompliance alternative.

RBLC

. According to the RBLC, r ecovery furnaces at nine mills have filterable PM

emission limits below the NSPS limit of 0.044 gr/dscf

, ranging from 0.02 to 0.036 gr/dscf at 8

percent O 2



## . All but one of the recovery furnaces control PM emissions using just an ESP; the

other recovery furnace uses an ESP in conjunction with limits on its recovery furnace firing rate

and pulp production. Thus, the RBLC did not reveal any new control measures for recovery

furnaces. (RTI 2012)

E C BAT document

. The 20 1 0 European C ommission (EC) best available t echniques

(BAT) document was reviewed . (EC 2010) Excerpts of BAT from EC 2010 included the

following PM control measures relevant to the NSPS review for kraft recovery furnaces:

• Reduce the emissio ns of dust (PM) from recovery furnaces using ESPs (used by

modern systems); sufficiently dimensioned ESPs together with good gas flow

distribution into the ESP and an optimized ESP cleaning regime can reduce levels

down to 15 to 20 milligrams per Normal cubic meter (mg/Nm 3 

## ) on a daily average

(dry gas, 273°K, 6 percent O 2 

## ) (converts to 0.0057 to 0.0076 gr/dscf at 8 percent O 2 

## ).

• Reduce the emissions of dust (PM) from recovery furnaces using two

- stage dust

removal facilities

-- ESP and wet scrubber (used by o lder systems); two

- stage dust

removal facilities achieve dust (PM) concen trations in the clean gas of 10 to 30

mg/Nm 3 

## as a daily average (dry gas, 273°K, 5 percent O 2 

## ) (converts to 0.0035 to

0.011 gr/dscf at 8 percent O 2 

## ).

Although the limits suggested in the BAT document convert to 0.011 gr/dscf at 8 percent O 2 

## or

lower , it is notable that these limits are daily averages and the control technologies suggested in

the BAT document are the same as the controls used on U.S. recovery furnaces.

STAPPA /ALAPCO guidanc e document

. The STAPPA/ALAPCO issued a document in

2006 (STAPPA 2006) to help state and local governments determin e the most effective ways to

control emissions of fine particles (PM 2.5 

## ) and PM 2.5 

## precursors from sources in their areas as the

gover nments prepare d their State Implementation Plans (SIPs) for attaining or maintaining the

PM 2.5 

## standard at that time

. The document noted that r ecovery furnaces currently rely on an ESP

or a combination of an ESP and wet scrubber to control PM emissions and that o pportunities

may exist to reduce current PM emissions levels by upgrading or replacing older ESPs or wet

scrubbers

. For example, the STAPPA document noted that, on recovery furnaces, older model

ESPs have collection efficiencies close to 90 perc ent, while newer model ESPs have collection

efficiencies greater than 99 percent . T he document further stated that t he cost of retrofitting a

recovery furnace with an ESP is heavily influenced by site

- specific factors. (STAPPA 2006)

### 18 

## Recovery f urnace PM s tack test d ata

. 4 

## Stack test dat a received with the 2011 ICR

responses were extracted from test reports and compiled for analysis. ( RTI 2013a ) Data from 211

filterable PM stack tests, including some repeat tests, on 133 recovery furnaces in the U.S. were

compiled and analyzed. 5 

## Most of the test data were obtained using EPA Method 5. Oregon

Department of Environmental Quality Method 5 (ORDEQ5) was used for a few of the tests. Test

dates ranged from 200 1 to 2011. Test data were reviewed for DCE and NDCE recovery furnaces

using a variety of PM emission controls (ESP, ESP and wet scrubber co mbinations, and wet

scrubbers). Table 6 presents a breakout of the number of PM tests analyzed by recovery furnace

type and control system. Multiple tests of the same recovery furnace were included in the tests

data set analyzed: (1) if the recovery furnace had multiple stacks (each with its own PM

concentration test result), (2) if multiple tests were conducted at different conditions, or (3) if

multiple tests were conducted at different times. 6 

## Additional data from one NDCE with a dry

bottom ESP and scrubber combination were also considered.

Table 6

. Number of Recovery Furnace PM Emissions Tests Included in Analysis

(Includes multiple tests of the same recovery furnace)

Recovery Furnace Control Type DCE NDCE Total

DBESP 18 95 113

DBESP/SCBR 1 7 8

DBESP

- WPR 4 18 22

DBESP

- WPR/DBESP/DBESP NA 1 1

DB

- WBESP [2

- sided dry and wet] NA 1 1

SCBR NA 1 1

WBESP 36 22 58

WBESP/SCBR 7 NA 7

Total 66 145 211

DBESP = dry

- bottom ESP, WBESP = wet

- bottom ESP, SCBR = scrubber, and

WPR = wet PM return. If “WPR” is not specified then the ESP ha s a dry PM return system.

Appendix A presents graphs of the recovery furnace test data and Appendix E contains

data tables associated with the graphs

. All 211 of the reco very furnace tests are shown in Figure

A

- 1 grouped by DCE or NDCE systems. As shown in Figure A

- 1, t he PM stack test data

revealed little or no distinction between DCE and NDCE recovery furnaces for PM emissions.

Nearly all of the recovery furnaces tested met the current NSPS and existing source NESHAP

(subpart MM) limit (0.044 gr/dscf), and many met the subpart MM new source l imit of 0.015

gr/dscf

.

4 

### All of the recovery fu rnace PM concentrations in this section are filterable P M concentrations corrected

to 8 percent O 2



### . 5 

### It is noted that additional PM stack test data were received with the 2011 ICR, but all of the data were

not compiled due to time constraints. Generally, t he most recent data for each recovery furnace were

compiled in order to ensure coverage of the population of recovery furnaces. Additional data were

compiled for recovery furnaces with controls of interest (e.g., ESP

- scrubber combinations) in order to

und erstand emissions variability and determine the performance of these systems.

6 

### Ibid.

### 19 

## In Figures A

- 2 through A

- 7, PM emissions data are shown for individual recovery

furnaces on each vertical line. If multiple tests were available and tabulated for a recovery

furnace, then multiple points (on e for each 3

- run test average) are shown on the vertical line.

Appendix E contains data tables corresponding to each graph

, where the graph sort order can be

used to identify each specific mill and recovery furnace tested.

Figures A

- 2 and A

- 3 depict PM emissions from DCE recovery furnaces by control type.

Figure A

- 2 shows t hat a ll DCE recovery furnaces with wet

- bottom ESP ( WBESP ) control meet

the NSPS, and many meet the MACT new limit. Direct contact evaporator recovery furnaces

with controls other than WBESP are shown in Figure A

- 3. All of the DCE furnace control

systems me t the current NSPS limit and most DCE furnaces with dry

- bottom ESP (DBESP) or

DBESP

- scrubber control met the MACT new limit. However, the furnaces with DBESPs and a

wet PM return (DBESP

- WPR) did not meet the MACT new limit, nor did the WBESP

- scrubber

combination controls. The DBESP

- WPR and WBESP

- scrubber systems are not subject to the

lower limit of 0.015 gr/dscf, but demonstrated compliance with the 0.044 gr/dscf limit. After

initially finding that the WBESP

- scrubber systems were performing above the MACT new limit,

additional data for the WBESP

- scrubber controlled furnaces were reviewed and added to the

graph, revealing that one of these systems consistently performs between 0.015 and 0.044 gr/dscf

while the other system exhibited variability above an d below 0.015 gr/dscf. No additional PM

data were available for the DBESP

- scrubber controlled DCE furnace.

Figures A

- 4 and A

- 5 show PM emission s from ND C E recovery furnaces with DBESP

control. Figure A

- 4 shows all 95 of the tabulated emissions tests for 63 NDCE furnaces with a

DBESP, and Figure A

- 5 shows only the furnaces for which multiple PM test results were

tabulated. Approximately 2/3 of the tests show n in Figure A

- 4 (66 to be exact) met 0.015 gr/dscf

, suggesting that a limit of 0.015 gr/dscf has been achieved in practice

. Figure A

- 5 shows the

variability in performance for 23 of the NDCE recovery furnaces equipped with a DBESP.

Twelve of the DBESP

- controlled NDCE furnaces were below 0.015 gr/dscf i n all tests, seven

were at or above 0.015 gr/dscf, and four had tests both above and below 0.015 gr/dscf. Only two

of the NDCE recovery furnaces shown in Figures A

- 4 and A

- 5 have limits of 0.015 gr/dscf, the

lowest PM permit limit observed for any recovery furnace. (EP A 2013a) Recovery furnace

600.GO806 is subject to a limit of 0.015 gr/dscf and achieved 0.008 gr/dscf in a 2010 emissions

test shown i n Figure A

- 4. 7 

## Recovery furnace 108. RB3 is subject to a limit of 0.015 gr/dscf and

achieved 0.0025 gr/dscf in a 2008 test and 0.024 in a 2010 test. No other PM test data are

available for 108. RB3. No test data are available for a third recovery furnace permitted at 0.015

gr/dscf (104.EUG D6), so this furnace does not appear in Figures A

- 4 and A

- 5. Overall, the test

results fo r the existing recovery furnaces shown in Figures A

- 4 and A

- 5 are indicative of the

variability in performance experienced by existing NDCE recovery furnaces with DBESPs.

Figure A

- 6 presents PM data for 14 NDCE recovery furnaces with WBESP control. Six

of the furnaces had all test results below 0.015 gr/dscf, six had all test results above 0.015

gr/dscf, and two furnaces had test results both abo ve and below 0.015 gr/dscf. None o f the

NDCE recovery furnaces with WBESP are currently subject to the lower limit of 0.015 gr/dscf.

7 

### Although not shown in Figure A

- 4, one additional test report for recovery furnace 600.GO806 is available

following upgrade of the furnace in 2005. The 2005 test result was 0.007 gr/dscf @ 8% O 2 

### compared to a permit

limit of 0.015 gr/dscf.

### 20 

## While 0.015 gr/dscf has been achieved in practice by WBESP

- controlled NDCE recovery

furnaces, the data in Figure A

- 6 are indicative of the variability in performance experienced by

existing NDCE recovery furnaces with WBESPs.

Sixteen NDCE recovery furnace s with various control systems are shown in Figure A

- 7

. All of the DBESP

- WPR tests were below 0.015 gr/dscf, although one of these systems had

repeated results between 0.015 and 0.044 gr/dscf. The two

- sided dry

- bottom and wet

- bottom

ESP ( DB

- WBESP ) achieved 0.021 gr/dscf. The scrubber

- controlled NDCE furnace achieved

0.032 gr/dscf. Finally, an ND C E furnace with three parallel ESPs (a DBESP

- WPR and two

DBESPs) achieved 0.015 gr/dscf in a retest following a test result of 0.076 gr/dscf.

The NDCE furnace with a DBESP

- scrubber combination shown in Figure A

- 7 had

multiple test results above 0.015 gr/dscf. Monthly PM test data are available for this particu lar

recovery furnace and are shown in Figure A

- 8. Thi s NDCE furnace is an existing source subject

to a permit limit of 0.033 gr/dscf. From 2001 to 2009, monthly test results varied from below

0.015 gr/dscf up to the furnace’s 0.033 gr/dscf permit limit. Th e scrubber on th is NDCE furnace

was installed in 1984 and may be approachi ng the end of its useful life. The DBESP was

upgraded in 1998 , which may explain why PM test results shown in Figure A

- 8 were generally

lower (often achieving 0.015 gr/dscf) through about 2006. The recovery furnace depicted in

Figure A

- 8 was one of the units used in determining the performance of DBESP

- scrubber

systems during subpart MM development, but was not the single best

- performing “MACT new”

unit.

Overall, the graphs on PM dat a in Appendix A indicate that DCE and NDCE recovery

furnaces have adequately demonstrated achievement of 0.044 gr/dscf, the current NSPS limit and

existing source limit under the NESHAP ( subpart MM ). Many recovery furnaces have also

achieved 0.015 gr/dscf, the new source limit under subpart MM. However, some recovery

furnaces equipped with a wet scrubber alone or with a wet scrubber in combination with an ESP

exhibited PM emissions above 0.015 gr/dscf (but below the 0.044 gr/dscf). This suggests that

wet scrubbing of recovery furnace exhaust gases (either alone or in conjunction with an ESP)

does not necessarily improve filterable PM removal

. The wet scrubbers installed following

recovery furnace ESPs are typically designed for SO 2 

## removal rather than for removal of PM

.

Regulatory o ptions for r ecov ery f urnace PM

. Review of ICR data, permit limits, the

RBLC, and the EC and STAPPA/ALAPCO guidance documents reflected predominant use of

ESP control systems and a few ESP

- scrubber control combinations for rec overy furnaces and did

not reveal use of any new control systems other than those considered in the prior NSPS and

NESHAP rulemakings. Emissions test data were reviewed to determine if the performance of

ESP and ESP

- scrubber control systems has evolved sin ce promulgation of the 1 986 NSPS

review and 200 1 NESHAP (subpart MM) to justify a lower PM limit. The stack test data showed

little distinction in recovery furnace design (DCE vs NDCE) and control system relative to the

current PM limit of 0.044 gr/dscf. Performance of 0.015 gr/dscf has been achieved in practice

and is already required under the subpart MM NESHAP for new and reconstructed recovery

furnaces. However, a number of existing recovery furnaces had PM stack test results above

0.015 gr/dscf but be low 0.044 gr/dscf, and , if modified triggering the NSPS, could have

difficulty achieving a limit of 0.015 gr/dscf without an ESP upgrade or replacement. It is

### 21 

## recommended that EPA evaluate the cost effectiveness and environmental impacts of emission

limits between 0.015 and 0.044 gr/dscf for modified recovery furnaces. A limit of 0.015 gr/dscf

is the logical regulatory option for new and reconstructed recovery furnaces (because 0.015

gr/dscf is already required under subpart MM). Based on a review of permit s, three recovery

furnaces are required to meet a limit of 0.015 gr/dscf to date and no limits lower than 0.015

gr/dscf were revealed.

2. Opacity from ESP

- controlled Recovery Furnaces

Ongoing compliance with the subpart BB PM concentration limit is demonstrated by

continuously monitoring opacity. The recovery furnace opacity limit under subpart BB is 35

percent opacity with a monitoring allowance that allows 6 percent of the 6

- minute opacity

averages during a quarter (excluding periods of startup, sh utdown and malfunction and periods

when the facility is not operating) to exceed 35 percent without being considered a violation.

Review of permits revealed 40 recovery furnaces with state permit limits of 20 percent opacity.

(EPA 2013a) A separate memoran dum presents recovery furnace opacity data and recommends

that the NSPS recovery furnace opacity limit be revised to 20 percent opacity with a 2 percent

monitoring allowance for new, modified, and reconstructed recovery furnaces

. Parameter

monitoring for ESP voltage and current is recommended to show compliance during the

monitoring allowance. ( EPA 2013b)

3. TRS from Straig h t Recovery Furnaces

Straight recovery furnaces including DCE and NDCE recovery furnaces at kraft mills are

de fined in the NSPS as, “ a furnace used to recover chemicals consisting primarily of sodium and

sulfur compounds by burning black liquor which on a quarterly basis contains 7 weight percent

or less of the total pulp solids from the neutral sulfite semichemic al process or has green liquor

sulfidity of 28 percent or less

. ”

The current kraft NSPS limits TRS emissions from straight recovery furnaces (including

both DCE and NDCE recovery furnaces) to 5 ppmdv at 8 percent O 2



## . A monitoring all owance of

1 percent of the TRS 12

- hour averages in a quarter is included under the NSPS. The CAA 111(d)

TRS emission guidelines (44 FR 29828) generally limit TRS to 5 ppmdv for existing NDCE

recovery furnaces and 20 ppmdv for existing DCE recovery furnaces. Informati on from the

RBLC and EC BACT document, along with TRS CEMS data were used to review the NSPS

TRS limit for straight recovery furnaces.

TRS emissions in recovery furnaces are reduced through use of black liquor oxidation

prior to the DCE, or by use of an NDCE recovery furnace which avoids contact of the hot flue

gases with incoming black liquor, thereby eliminating the need for a BLO system and the

potential for TRS emissions from the final evaporation step. Over the past few decades, a

number of DCE recov ery furnaces have been converted to NDCE designs, which are often

referred to as a “low

- odor” conversion due to the reduced emissions of odorous TRS compounds

. Based on the 2011 ICR data, 108 of the 149 currently operating rec overy furnaces (72 percent)

us e NDCEs, which are expected to emit less TRS than the 41 recovery furnaces (28 percent) that

use DCEs. The last installation of a new DCE recovery furnace occurred in 1989. Many of the

### 22 

## remaining DCE furnaces are approaching the end of their useful life and would be expected to be

replaced with a new NDCE as opposed to being modified or reconstructed as an NDCE furnace.

No new DCE recovery furnaces are projected for the pulp and paper industry . (RTI 2013c )

Use of a dry

- bottom ESP is potentially another method of reducing recovery furnace TRS

emissions. When hot recovery furnace flue gases come in contact with ESP control systems, TRS

may be stripped from any black liquor present in the system and emitted to the atmosphere. Dry

bottom ESPs elimina te the use of black liquor in the bottom of the ESP, and dry PM return

systems eliminate the use of black liquor in the PM return system, so that the captured PM does

not contact any black liquor until it reaches the salt cake mix tank. (EPA 1996) Use of o xidized

black liquor that has passed through the BLO as opposed to unoxidized liquor in the wet

- bottom

ESPs of DCE recovery furnaces reduces the potential for stripping of TRS compounds. ( EPA

1983 A) According to the 2011 ICR results, of the 108 NDCE recove ry furnaces, 7 8 use dry

bottom ESPs with dry PM return systems, which are expected to emit less TRS than the 13

NDCE recovery furnaces that use wet

- bottom ESPs, the 1 3 NDCE recovery furnaces that use

dry

- bottom ESPs with wet PM return systems, and the 1 NDCE recovery furnace that uses a two

sided dry

- and wet

- bottom ESP

.

Burning of NCGs in the recovery furnace could also potentially affect TRS emissions if

the NCGs are not properly combusted. The 2011 ICR results indicate that 26 of the 149 reco very

furn aces burn NCGs as primary or backup control . None of the NCGs are pre

- scrubbed with a

white liquor scrubber (for sulfur removal) prior to i ncineration in the recovery furnace.

Straight recovery f urnace TRS permit l imits

. As discussed in a separate memorandum,

permit limits for TRS from recovery furnaces were reviewe d. (EPA 2013a) Most furnaces ( 101 )

are permitted to meet the current limit of 5 ppm ; however 4 units are permitted for a TRS limit

more stringent than the existing NSPS. Two units are permitted to meet a limit of 3 ppm (one

based on a 3

- hour average and one based on a 12

- hour average). Two additional units are

permitted to meet a TRS limi t of 4 ppm (one based on a 12

- hour average and one based on a 24

- hour average). Regardless of the general emission guideline limit of 5 ppm for existing NDCEs,

many units were permitted above 5 ppm due to the statu t e that allows states and EPA to set less

stringent standards for sources where it may not be technologically or economically feasible to

reduce their emissions to the 5 ppm limit.

RBLC . The RBLC did not reveal any new emission reduction methodologies for straight

recovery furnace TRS that would be applicable for other mills. The RBLC noted that two mills’

recovery furnaces have TRS limits below the NSPS limit of 5 ppm dv at 8 percen t O 2 

## includ ing:

(1) a limit of 3 ppm dv at 8 percent O 2 

## based on proper boiler design and operation, and (2) a

limit of 4 ppm dv at 8 percent O 2 

## based on use of an NDCE recovery furnace

, good combustion

practice s, and limits on recover y furnace firing rate and pulp p roduction

. (RTI 2012)

E C BAT document

. The EC BAT document did not reveal any new emission reduction

methodologies that have been demonstrated in practice beyond those considered previously in

evaluation of NSPS. The document noted that a higher dry solids content leads to a high

temperature in the recovery furnace and thus lower emissions of H 2 

## S and higher emission s of

sodium . According to EC 2010, mills could increase the dry solids content of black liquor by

### 23 

## installing a super

- concentrator to achieve a dry solids content of up t o 80 percent, although the

achievable dry solids content would depend on the wood species . The document noted that mills

may need to install a more efficient ESP to compensate for the increase in PM e missions that

would result from the higher dry solids content; and at very high dry solids content (greater than

80 percent ), the mill would need to collect and incinerate the considerable sulfur compounds

released from the last evaporator stage. (EC 2010)

Straight recovery furnace TRS e missions d ata

. As discu ssed in a separate memorandum,

a year of TRS CEMS data for 129 recovery furnaces were analyzed as part of the NSPS review.

(EPA 2013b) The r eview of TRS data focused on CEMS data as opposed to stack test data

because rel atively few TRS stack test reports (for recovery furnaces) were submitted in response

to the EPA’s 2011 ICR as compared to the number of available TRS CEMS data sets.

The TRS CEMS data analyzed showed that recovery furnace type (DCE vs. NDCE) and

NSPS ap plicability are more relevant than control device type in distinguishing between the best

performing recovery furnaces for TRS. Reco very furnaces with combined ESP

- scrubber controls

did not achieve lower TRS emissions than recovery furnaces with ESP system s alone. Contrary

to the expectation noted above regarding the TRS performance of dry

- bottom ESPs versus wet

bottom ESPs (and ESPs with wet PM return systems), little difference in the annual average of

continuously monitored TRS emissions was observed for the different control systems already

subject to the NSPS. Thus, process control factors appear to play a larger role in recovery

furnace TRS emissions than APCD type. Nearly all DCE furnaces had TRS emissions above 5

ppmdv (and usually below 20 ppmdv) wh ile the majority of NDCE furnaces achieved 5 ppmdv

consistently. Multi

- staged black liquor oxidation was previously reported to reduce TRS

emissions from DCE recovery furnaces. H owever, the TRS CEMS data for single

- versus

multiple

- stage BLO systems are in conclusive as to whether multiple

- stage BLO systems reduce

TRS emissions better than single

- stage systems. Most of the DCEs did not achieve the 5 ppmdv

NSPS limit regardless of the number of BLO stages. As mentioned previously, the trend over the

past seve ral decades has been towards installation of NDCE recovery furnaces or “low

- odor”

conversions of DCE recovery furnaces to NDCE technology. Also, burning NCGs does not

appear to significantly increase recovery furnace TRS emissions according to the CEMS dat a

analyzed, likely because the TRS emissions are thoroughly combusted. (EPA 2013b)

Regulatory options for straight recovery f urnace TRS

. Based on analysis of the recovery

furnaces TRS CEMS data, it is recommended in a separate memorandum that the NSPS 5 ppmdv

TRS limit for straight recovery furnaces and the 1 percent monitoring allowance be retained. 8



## (EPA 2013b) Review of the technologies used to reduce TRS suggests that use of good

combustion control and NDCE technology which is capable of processing b lack liquor at a

higher solids percentage continues to be the most reliable method for reducing TRS emissions.

4. TRS from Cross Recovery Furnaces

Cross recovery furnaces are defined under the NSPS as a furnace used to burn black

liquor “ which on a quarterly basis contains more than 7 weight percent of the total pulp solids

from the neutral sulfite semichemical process and has a green liquor sulfidity of more than 28

8 

### See Table 11 below.

### 24 

## pe r cent

. ” Cross recovery furnaces have higher TRS limits under the NSPS and emissions

guidelines because the semichemical pulping liquor adds additional sulfur to the black liquor. No

existing cross recovery furnaces were identified in the 2011 ICR data. The ICR data were further

reviewed for additio nal recovery furnaces that are not yet subject to NSPS that could possibly be

classified as cross recovery furnaces if modified or reconstructed. Four non

- NSPS furnaces at

kraft mills with co

- located semi

- chemical pulping were identified. Information on th e weight

percent of total pulp solids from semichemical pulping or green liquor sulfidity is not readily

available to classify non

- NSPS recovery furnaces a s cross or straight furnaces . Most (seven) of

the recovery furnaces at co

- located kraft and semichemi cal pulp mills that have become subject

to the NSPS combust black liquor and are classified as straight recovery furnaces. One of the

“straight” recovery furnaces ( RTI Emission Unit ID 116.003) subject to the NSPS 5 ppmdv TRS

limit combusts a mixture of kraft black liquor and semichem ical brown liquor . The TRS CEMS

data for this recovery furnace reflected a maximum TRS block average of 5 ppm, 99 th 

## percentile

of 1 ppm, and no exceedances of the 5 ppmdv limit during the year for which CEMS data were

provide d.

P ermit limits and TRS emissions data were examined for the four furnaces that are not

yet classified as straight or cross recovery furnaces under the NSPS definition. Table 7 presents

the permit limits and available emissions data for the four recovery furnaces. Two of the

recovery furnaces ( at mills 190 and 226) ar e subject to 5 ppmdv TRS limits (which suggests that

these furnaces may not meet the definition of a cross recovery furnace). One furnace at mill 181

is subjec t to a 2 0 ppmdv TRS permit limit . Because this is an NDCE furnace (that was originally

installed as an NDCE, not converted from a DCE) with an emissions limit above the 5 ppm

emission guideline for NDCE furnaces

, but below the 25 ppm guideline limit for cross recovery

furnaces, it is unc lear whether this furnace w ould be a straight or cross recovery furnace if

classified under the NSPS. This furnace had TRS emissions of 4.6 ppmdv a ccording to a 2001

test report, but the test report is suspect as noted below the tabl e . The final mill (188) has two

DCE recovery furnaces that are subject to a permit limit of 10 ppmdv based on a 24

- hour

average. This mill had TRS emissions approaching their 10 ppmdv limit. DCE recovery furnaces

are challenged to meet a 5 ppmdv TRS limit (unless multi

- staged bl ack liquor oxidation is used).

However, no information is available to clarify whether the recovery furnaces perform near 10

ppmdv because of DCE technology or because of the green liquor sulfidity. A lower TRS limit

(e.g., 5 ppm) based on a 12

- hour avera ge block could be difficult for this recovery furnace to

meet if modif ied or reconstructed as a DCE. However, if modified or re constructed as NDCE or

wi th a DBESP then TRS emissions f r o m t hese furnace s would be reduced.

### 25 

## Table 7 . Kraft

- semichemical Co

- located Recovery Furnaces Not Yet Designated as Cross or

Straight Recovery Furnaces for NSPS Applicability

Possible cross

RF ID Description Installed Liquor type

reported in the

ICR data base TRS permit

limit at 8% O 2 

### Emission data at

8% O 2



### 181.09/10 NDCE with

WBESP [No. 4

recovery boiler

stacks A and B] 1976 black 20 ppmdv 4.6 ppmdv based

on a 2001 stack

test 1



### 188.014RB1 DCE with WBESP 1958;

modified

1996 2 

### mixture of kraft

black liquor and

semi

- chem green

liquor 10 ppmdv (24

- hr avg) Max 24

- hr CEMS

block was 9.1

ppm. The 99 th



### percentile was 8.0

ppm.

188.016RB2 DCE with WBESP 1962

modified

1996 2 

### mixture of kraft

black liquor and

semi

- chem green

liquor 10 ppmdv (24

- hr avg) Max 24

- hr CEMS

block was 9.4

ppm. The 99 th



### percentile was 8.2

ppm.

190.R402 NDCE with

DBESP. Has 2

stacks. 1974 mixture of kraft

black liquor and

semi

- chem green

liquor 5 ppmdv (12

- hr

avg) Max 12

- hr CEMS

blocks were 8.2

and 3.9 ppm.

Corresponding

99 th 

### percentiles

were 1.3 and 0.93

ppmdv for each

stack.

226.RECB1 NDCE with

WBESP 1973 black 5 ppmdv (12

- hr

avg) No CEMS data

provided

1. Test data are suspect. A half

- run was conducted in each of the two stacks to make a whole test run that accounted

for concentration from both stacks. No other emissions test data or CEMS data are available for this unit.

2. Although this unit was upgraded in 1996, it did not trigger NSPS.



## Regulatory o ptions for c ross recovery f urnace TRS

. Given the fact that no existing cross

recovery furnaces were identified, the potential for existing kraft/semichemical co

- located

recovery furnaces to be designated as cross recovery furnaces in the future, and the fact that

some of these recovery furnaces are not curren tly meeting a TRS limit as low as 5 ppm, it is

recommended that EPA retain the current cross recovery furnace TRS standard of 25 ppmdv

based on conclusions from the original NSPS . This standard can be reevaluated in a future NSPS

review if actual cross rec overy furnace data become available.

C. Lime K ilns

In k raft pulp mills , the lime kiln is part of the causticizing process, the process in which

green liquor from the SD T is converted to white liquor. The function of the lime kiln is to

oxidize lime mud ( calcium carbonate, CaCO 3 

## ) to reburned lime ( calcium oxide, CaO , known as

“quicklime” ) in a process known as calcining. T he CaO produced in the lime kiln is used in the

causticizing reactions that take place in the green liquor slaker and causticizers to p roduce the

NaOH used in the kraft white liquor.

### 26 

## Prior to calcining, lime mud from the causticizing tanks is washed and dewatered. Lime

mud washers reduce the sodium and sulfide content of the lime mud, which lowers TRS

emissions from the lime kiln. The lime mud is typically dewatered to about 70 to 85 percent

solids using a rotary vacuum precoat drum filter. Rotary lime kilns are commonly used in kraft

pulp mills. According to the 2011 ICR, 131 lime kilns are currently operating in the U.S.,

including 13 0 rotary lime kilns and 1 calciner (with an additional lime kiln operating as a backup

and using the same control device as one of these kilns). Sixty

- two lime kilns are subject to the

NSPS. In a rotary lime kiln, lime mud from the precoat filter is introd uced at the feed end (cold

end) and flows downward towards the discharge end (hot end). Natural gas or residual or

distillate fuel oil , either alone or in combin ation, are the most common fuels used in lime kilns.

Solid p etroleum coke, waste oil, turpentine, tall oil, and rectified methanol are also burned in

some lime kilns as ancillary fuels. In addition, th e majority of lime kilns at kraft pulp mills (98 of

131) also burn NCGs from various process vents.

The majority of existing lime kilns ope rate with wet scrubber controls , most of which are

venturi scrubbers. The ICR data indicate that 9 1 lime kilns have wet scrubbers, 29 have ESPs

, and 10 have ESP

- scrubber combinations

. The 62 lime kilns subject to the NSPS use the same

types of controls (25 NSPS kilns have ESPs, 30 have scrubbers, and 7 operate ESP

- scrubber

combinations).

1. Particulate Matter from Lime Kilns

Particulate matter in the exhaust gas from lime kilns is mainly sodium salts, CaCO 3 

## (lime

mud), and CaO (lime). (EPA 2001) The current NSPS limits for new, modified, and

reconstructed lime kilns are 0.066 gr/dscf for gas

- fired kilns and 0.13 gr/dscf for oil

- fired kilns

(both at 10 percent O 2 

## ). The NSPS limits are higher than the PM limits for lime kilns under

NESHAP subpart MM whi ch requires 0.064 gr/dscf at 10 percent O 2 

## for existin g lime kilns and

0.010 gr/dscf at 10 percent O 2 

## for new and reconstructed lime kilns. In addition to the 2011 ICR

database, permit limits, information from the RBLC, EC BAT document, and

STAPPA/ALAPCO g uidance documents, and stack test data were reviewed in order to evaluate

the lime kiln PM limits. The results of these reviews are summarized in the paragraphs below.

Lime kiln PM permit limits

. As discussed in a separate memorandum, permit limits for

PM from 130 lime kilns were re viewed. (EPA 2013a) Over half of the kilns (72) are permitted to

meet the NESHAP PM limit of 0.064 gr/dscf for existing sources. Five kiln s are permitted for

limits higher than the NS PS limit, and four of these kiln s are located at facilities that utilize the

PM bubble compliance alternative. Even though the NESHAP removed the distinction between

kiln fu e l types, 18 kilns are permitted with separate limits for periods of gas

- fired and liquid fuel

fired b urning. An additional eight kiln s are permitted at the higher liquid fuel

- fired limit of 0.13

gr/dscf. Two kiln s are permitted at the new source li mit of 0.01 gr/dscf, and 15 kiln s are

permitted between 0.0125 and 0.056 gr/dscf, with 3 being located at facilities that utilize the PM

bubble compliance alternative.

RBLC . The RBLC search results found that four lime kilns at three mills have filterable

PM emission limits below the NSPS limits ranging from 0.01 to 0.05 gr/ dscf at 10 percent O 2 

## based on use of a wet scrubber (0.05 gr/dscf limit), ESP (0.01 and 0.03 gr/dscf limits), and

### 27 

## combination ESP

- scrubber (0.033 gr/dscf limit). The RBLC search did not identify any new

control technologies beyond those noted in the ICR r esponses. (RTI 2012)

EC BAT document . Excerpts of BAT from EC 2010 included the following PM control

considerations relevant to the NSPS review for kraft lime kilns:

• Consider p rocess

- integrated measures before installing a dust removal facility (e.g.,

pro per design of the lime kiln will minimize dust formation; proper adjustment of

flame shape and position can control the extent of vaporization).

• Consider f uel use; the use of different fuels also affects dust emissions (e.g., an oil

flame results in high s odium vaporization from the lime).

• Install ESP (prior to scrubber, if there is also a scrubber); dust emissions of less than

25 mg/Nm 3 

## as a daily average (dry gas, 273°K, 5 to 6 percent O 2 

## ) (converts to less

than 0.0075 gr/dscf at 10 percent O 2 

## ) can be achieved by well

- designed, dimensioned,

and maintained ESPs.

The emission reduction associated with the process measures noted in the BAT document is

qualitative and unquantified. The control technology suggested in the BAT document (ESP) is

the same as t hat identified as the basis for new source MACT in the U.S. based on a limit of

0.010 gr/dscf at 10 percent O 2 

## . Although the limit suggested in the BAT document converts to

slightly less than 0.010 gr/dscf at 10 percent O 2 

## , it is notable that the BAT value is a daily

average.

STAPPA /ALAPCO guidanc e document . STAPPA 2006 noted that m ost PM emissions

from lime kilns a re controlled with wet scrubbers

— typically, venturi scrubbers

— but that l ime

kilns installed in the past 10 years are likely to have an ESP con trol system . The document

indicated that e missions from older units can be reduced by replacing wet scrubbers with ESPs.

The capital and annual costs to replac e lime kiln scrubbers with ESPs to meet the 0.01 0 gr/dscf

limit for new sources set in subpart MM were estimated to be $3.4 million and $0.2 million,

respectively. (STAPPA 2006)

Lime kiln PM stack test d ata

. 9 

## Lime kiln PM s tack test dat a received with the 2011 ICR

responses were compiled for analysis. ( RTI 2013a ) Data from 259 filterable PM stack tests,

including several repeat tests, on 116 lime kilns in the U.S. were compiled and analyzed. 10 

## Test

dates ranged from 2001 to 2011

. The majority of the tests were performed using EPA Method 5

though a few were based on ORDEQ5. Test data were reviewed for lime kilns combusting

multiple fuels with a variety of PM emission controls. The sample of test results included 1 20

tests of wet scrubbers

, 113 tests of ESP s

, and 26 tests of ESP

- scrubber co mbinations. The PM

tests included 112 tests of gas

- fired kilns , 58 tests of oil

- fired kilns, 9 tests of gas and oil

combined, 13 tests of petroleum coke and gas combined, and 67 additional tests where the kiln

fuel type was unspecified.

9 

### All of the lime kiln PM concentrations in this section are filterable PM concentrations corrected to 10

percent O 2



### . 10 

### It is noted that additional PM stack test data were received with the 2011 ICR, but not all of the data

were com piled due to time constraints. Generally, t he most recent data for each lime kiln were compiled

in order to ensure coverage of the population of lime kilns . Additional data were compiled for lime kilns

with controls of interest (e.g., ESPs and ESP

- scrubber combinations) to understand emissions variability

and determine th e performance of these systems.

### 28 

## Appendix B presents graphs of the lime kiln test data. Al l of the lime kiln tests are

shown in Figure B

- 1 grouped by control system

. 11 

## Figure B

- 1 shows that ESP and ESP

- scrubber

combinations often out

- perform scrubbers, and that scrubbers would not be expected to meet the

MACT new limit of 0.01 0 gr/dscf. It also shows that ESP

- scrubber combinations do not

necessarily out

- perform ESPs on PM. Figures B

- 2 through B

- 4 provide additional resolution of

lime kiln PM emissions by emission unit and control device type.

Figure B

- 2 presents the 113 PM stack test resul ts tabulated for 27 ESP

- controlled kilns.

Test averages (e.g., average of 3 test runs) for each kiln are represented on a separate vertical

line, and the x

- axis provides a numerical reference for the kiln data table in Appendix E. All of

the ESP

- controlled kilns achieved compliance with the current NSPS limit and MACT limit for

existing sources

. Several of the ESP systems consistently achieved the MACT new source limit

of 0.01 0 gr/dscf

. However, some existing ESP systems performed above or both above and

below 0.01 0 gr/dscf in multiple tests. Existing lime kilns are not currently subject to the lower

limit of 0.010 gr/dscf.

Filterable PM test results (26 tests) for nine lime kilns with ESP

- scrubber combination

controls are presented in Figure B

- 3. Like for the ESP

- controlled kilns, all of the ESP

- scrubber

controlled kilns met the current NSPS limit and MACT limit for existing sources. While several

kilns repeatedly achieved 0.010 gr/dscf, there were three kilns that performed both above and

below 0.010 gr/dscf. One of these kilns performed below 0.010 gr/dscf when operating both an

ESP and scrubber, but performed above 0.010 when operating the scrubber only.

Figure B

- 4 presents 120 PM test results for 80 scrubber

- controlled lime kilns. Most of the

scrubber

- controlled kilns achieved the existing source MACT limit (0.064 gr/dscf) and the NSPS

limit for gas

- fired kilns (0.066 gr/dscf). There were some results above the MACT limit; several

lime kilns participate in the PM bubble compliance alternative. All but two kilns were well

below the NSPS limit for oil

- firing (0.13 gr/dscf). Based on the data in Figure B

- 4, scrubber

controlled kilns would not be expected to meet a new source limit of 0.010 gr/dscf.

Figures B

- 5 through B

- 9 contain th e same PM emissions data show n in Figure B

- 1, and

repeated in Figures B

- 2 through B

- 4, but show lime kiln PM emissions by both control device

and by fuel type. It was necessary to use multiple graphs for a given control system to fit the data

on the charts . Some kilns were tested using different fuels and appear in more than one series on

the graphs.

Figure s B

- 5 and B

- 6 show no discernible distinction by fuel type for ESP

- controlled kilns

firing gas

, oil , combinations of gas and oil or gas and petroleum coke, or for unspecified fuels.

The oil

- fired kilns (and all other kilns) in Figure s B

- 5 and B

- 6 perform far below the NSPS limit

of 0.13 gr/dscf for oil firing. The kilns co

- firing petroleum coke had emissions in the same range

of the gas and oil

- fired kilns . Similarly, in Figure B

- 7 , there appears to be little (if any)

difference in the PM emissions by fuel type for kilns with ESP

- scrubber combination controls.

11 

### No data table o r labels are provided in Figure B

- 1 because they would be difficult to read with so many

data points. The graphs discussed in the remain d e r of this section show the same data with greater

resolution.

### 29 

## The emissions test data for the two kilns permitted at 0.01 gr/dscf were reviewed. Kiln

114 .U800 operates with an ESP and achieved 0.0011 to 0.0039 in four tests (two firing gas, and

two firing oil). Kiln 243.LG07 operates with an ESP

- scrubber system and achieved 0.002 to

0.007 in three tests (two firing gas and one firing oil). In a separate te st with only the scrubber in

operation, kiln 243.LG07 performed at 0.026 gr/dscf (above the 0.01 gr/dscf permitted limit).

Figures B

- 8 and B

- 9 present PM emissions by fuel type for scrubber

- controlled kilns

. The

PM emissions from some oil

- fired kilns d o appear to be slightly higher than for gas

- fired kilns in

Figure B

- 8. The kilns c o

- firing pet roleum coke with gas do not reflect PM emissions any higher

than the kilns firing gas only

. The kilns firing unspecified fuels during emissions testing

generally emitted less than the MACT existing source limit of 0.064 gr/dscf.

Table 8 contains PM test data for individual lime kilns that were tested under separate

conditions using either gas or oil. E missions from oil

- firing exceeded those from gas firing in

three tests of ESP

- controlled kilns. No difference in the emissions from gas or oil firing was

observed in a test of an ESP

- scrubb er controlled kiln. Emissions from gas firing exceeded those

from oil

- firing for a scrubber

- controlled kiln. Considering al l of the data in Table 8 along with

the data presented in Figures B

- 5 through B

- 9, it appears that control device type has a more

significant impact on PM emissions than fuel type combusted. The data are somewhat

inconclusive as to whether fuel type plays a significant role in PM emissions.

### 30 

## Table 8 . Comparison of Method 5 PM Test Results for Individual Kilns Tested Using Separate Fuels (Gas and Oil)

Description Test Date PM, gr/dscf

at 10 O 2 

### Duplicate Test Notes RTI+EUID Control Percent difference

(oil

- gas/gas)

Lime Kiln

- Cond II 8/6/2009 0.0055 Separate conditions: Cond 2 = gas

Lime Kiln

- Cond. I 8/4/2009 0.0119 Separate conditions: Cond 1 = fuel oil 111.G

- 35 ESP 116%

Lime Kiln 12/13/2005 0.0039 Separate conditions: No. 6 fuel oil

Lime Kiln 12/14/2005 0.0033 Separate conditions: Natural Gas 114.U800 ESP 18%

Lime Kiln 12/16/2008 0.0011 Separate conditions: gas

Lime Kiln 12/16/2008 0.0018 Separate conditions: oil 114.U800 ESP 64%

No. 3 Lime Kiln 10/20/2009 0.034 Separate conditions: gas

No. 3 Lime Kiln 10/21/2009 0.028 Separate conditions: oil 172.LK03 SCBR

- 21%

Lime Kiln (Scrubber

Outlet)

- Firing Gas 5/27/2010 0.005 Separate conditions: gas

Lime Kiln (Scrubber

Outlet)

- Firing Oil 5/26/2010 0.005 Separate conditions: oil 178.09P037 ESP/SCBR no difference

### 31 

## R egulatory options for l ime kiln PM

. Several ESP and ESP

- scrubber

- controlled kilns

consistently achieved 0.010 gr/dscf at 10 percent O 2 

## , the new and reconstructed source PM limit

for lime kilns under subpart MM

. Thus, 0.010 gr/dscf is an obvious regulatory option for new

and reconstructed lime kilns. The ESP

- scrubber systems did not necessarily perform bette r on

filterable PM than the ESPs alone so there is no technological justifica tion for considering limits

lower than 0.010 gr/dscf. Consistent with the limits for new and existing lime kilns under subpart

MM, the emissions data do not support a distinction among fuel types for purposes of

establishing a PM limit in subpart BBa. For existing lime kilns that are modified, which could

trigger the NSPS without triggering new source MACT, EPA could e xplore the cost

effectiveness and environmental impacts of limits ranging from 0.010 gr/dscf to 0.064 gr/dscf

, the existing source MACT limit under subpart MM. The 0.064 gr/dscf limit has been

demonstrated to be achieved by lime kilns with scrubbers as well as lime kilns with ESPs or

ESP

- scrubber combinations.

2. Opacity from ESP

- controlled Lime Kilns

The current kraft pulp mill NSPS does not contain an opacity limit or any other

monitoring requirements for ESP

- controlled lime kilns because scrubbers were the dominant

technology in 197 8 and 1986 when the NSPS were originally promulga ted and revised,

respectively. Opacity is not meaningful for lime kilns with wet scrubbers so scrubber operating

parameters are required to be monitored under the NSPS for scrubber

- controlled lime kilns.

Howe ver, subpart MM requires continuous opacity monitoring for ESP

- controlled lime kilns as

an indicator of PM emissions and specifies 20 percent as the opacity limit for both new and

existing kilns with ESPs. A review of permit limits revealed no ESP

- controll ed lime kilns with

opacity limits lower than 20 percent. (EPA 2013a) Opacity monitoring data for lime kilns are

documented in a separate memorandum, where it is recommended that a 20 percent opacity limit

for ESP

- controlled lime kilns with a 1 percent monitoring allowance is adequately demonstrated

for new, modified, and reconstructed lime kilns

. Parameter monitoring for ESP voltage and

current is recommended to show compliance during the monitoring allowance for ESP

controlled kilns. ( EPA 2013b) Parame ter monitoring for both the ESP and scrubber may be used

for combined ESP

- scrubber systems instead of opacity monitoring.

3. TRS from Lime Kilns

The kraft pulp mill NSPS limits lime kiln TRS emissions to 8 ppmdv at 10 percent O 2 

## based on a combination of go od process controls, adequate mud washing, and use of caustic in

the lime kiln scrubber (if necessary), which was considered the best de m onstrated technology in

1978 and 1986 when the NSPS was originally developed and reviewed, respectively

. A higher

limit of 20 ppmdv as H 2 

## S at 10 percent O 2 

## is allowed under the emission guidelines. To evaluate

the NSPS limit, information from recent N CASI technical bulletins, permits, responses to the

2011 ICR, RBLC, and EC BAT document was reviewed and lime kiln TRS CEMS data were

anal yzed. The results of these reviews are summarized in the paragraphs below.

Lime mud is the primary source of TRS emissions in the lime kiln. Lime kiln TRS

emissions depend on the soluble sulfide content in the lime mud, which in turn depends on the

### 32 

## efficiency of lime mud washing. TRS emissions (primarily H 2 

## S) are released when the CO 2



## - rich

flue gases in the cold end of the kiln come into contact with the sodium sulfide in the lime mud.

Lime kiln scrubber makeup water can also be a source of TRS emission if the scrubber

uses process water (e.g., process condensates) contaminated with reduced sulfur compounds.

Reduced sulfur compounds can be stripped from the scrubber makeup wa ter as the hot kiln flue

gases pass through the scrubber. Caustic is sometimes added to the scrubbing solution to reduce

H 2 

## S emissions from lime kilns. (NCASI 2002a) Weak wash or caustic may also be used to

reduce SO 2 

## emissions from the kiln. However, acco rding to the 2011 ICR responses,

approximately half of the scrubber

- controlled kilns in the U.S. are using fresh water in their lime

kiln scrubbers without the addition of caustic.

NCG burning could also affect lime kiln TRS emissions if the TRS

- laden NCG s are not

properly combusted. However, data show that the practice of NCG burning does not have to

result in an increase in TRS emissions from the lime kiln. (NCASI 2002a) The practice of NCG

pre

- scrubbing is discussed below.

Other factors previously reported (in EPA 1983 and EPA 1979 ) to potentially affect TRS

emissions include the oxygen content of the exhaust, the kiln length

- to

- diameter ratio, and cold

end exit gas temperature

. However , the role of O 2 

## in kiln vent gases is not quantified because

stack O 2 

## levels may not correlate with kiln O 2 

## levels. NCASI observed only a weak correlation

between TRS emissions and stack gas O 2 

## content. (NCASI 2002a) Maintaining sufficient excess

O 2 

## in the flue gases to ensure H 2 

## S is oxidized to SO 2 

## has been mentioned as a potential

alternative to reduce TRS emissions. (NCASI 2002a) No information was identified to confirm

or refute the effects of kiln length

- to

- diameter ratio or cold

- end exit gas temperature.

Lime k iln TRS permit l imits . As discussed in a separate memorandum, permit limits for

TRS from 130 lime kilns were reviewed. (EPA 2013a) Many kilns (57) are permitted to meet the

8 ppm NSPS limit. Four kilns are permitted to meet a more stringent limit. Two of these kilns

must meet 5 ppm, two must meet 7 ppm. One kiln must meet 7.5 ppm based on a 24

- hour

average, with a 10 ppm hourly average limit. Fifty kilns are permitted to meet the 20 ppm limit

derived from the emission guidelines. Twelve kilns are permitted for 40 ppm or higher due to the

statute that allows states and EPA to set less stringent standards for sources where it may not be

technologically or economically feasible to reduce their emissions to the 20 ppm limit. Five kilns

had no apparent TRS limit s in their permits, and one kiln had a mass

- based limit (tons per year)

instead of concentration.

RBLC . The RBLC did not reveal any new emission reduction methodologies for lime

kiln TRS. It noted that one mill’s lime kiln, which controls TRS with a wet s crubber using fresh

water, has a TRS emission limit of 6.5 ppmdv which is below the NSPS limit of 8 ppmdv at 10

percent O 2 

## for lime kilns. (RTI 2012)

EC BAT document . The EC BAT document did not reveal any new emission reduction

methodologies. The documen t noted that more efficient washing reduces the concentration of

sulfide in the lime mud, thus reducing the formation of H 2 

## S in the lime kiln during the reburning

process.

### 33 

## Lime k iln TRS e mis sions d ata

. As discussed in a separate memorandum, 1 year of TRS

CEMS data for 111 lime kilns were analyze d for the NSPS review. (EPA 2013b) Review of TRS

data focused on CEMS data as opposed to stack test data because relatively few TRS stack test

reports for lime ki lns were submitted in response to the ICR as compared to the number of

available TRS CEMS data sets. The TRS CEMS data did not show any significant distinction in

lime kiln TRS performance for the different types of controls systems (i.e., ESP

- scrubber

sys tems fell within the scatter of the ESP

- only and scrubber

- only systems), suggesting that

process factors (e.g., mud washing, use of uncontaminated scrubber water, and NCG burning)

have a greater effect on lime kiln TRS emissions than control device type. B ecause NCGs can

contribute to lime kiln TRS emissions (if not properly combusted), the TRS CEMS data were

used to compare the performance of lime kilns that burn NCGs with lime ki lns that do not burn

NCGs. No clear distinction in the TRS performance of NCG

- burning kilns versus non

- NCG

burning kilns was observed. Similarly, the TRS CEMS data were compared for NCG

- burning

kilns with and without NCG white

- liquor pre

- scrubbers, but the kilns with pre

- scrubbers did not

out

- perform the kilns without pre

- scrubbers

. Based on review of the TRS CEMS data, it is

recommended (in a separate memorandum) that the current 8 ppmdv TRS limit based on a 12

- hour average with a 1 percent monitoring allowance is the lime kiln TRS standard that has been

demonstrated to be achieved in practice. (EPA 2013b)

NCG pre

- scrubbing . NCG pre

- scrubbers can be installed to reduce the potential for SO 2 

## emissions from lime kilns (by reducing th e sulfur content and volume of the N CG stream), and

thereby reduce the potenti al for like kiln TRS emissions that may occur if the NCGs are not

properly combusted

. The ICR data indicate that 32 lime kilns incinerate NCGs that are pre

scrubbed. Caustic or w hite liquor are typically used in NCG pre

- scrubbers. The spent scrubbing

liquor can be return ed to the white liquor system after useful sulfur is recovered from the NCG

stream. (Springer 2000) The NCG pre

- scrubbers use an alkaline solution to scrub the aci dic TRS

compounds (H 2 

## S and methyl mercaptan) prior to incineration. Dimethyl sulfide and dimethyl

disulfide are neutral compounds that cannot be removed with alkaline scrubbing. Inlet and outlet

NCG pre

- scrubber TRS data from NCASI Technical Bulletin 849 were reviewed to determine

the effectiveness of NCG pre

- scrubbers

. ( NCASI 2002a ) Average removal efficiencies were 98

to 100 percent removal of H 2 

## S and methyl mercaptan from the NCG stream, but were either poor

or negative for dimethyl sulfide or dimethyl disulfide. One scrubber had a negative removal

efficiency for methyl mercaptan , which suggest s stripping of TRS compounds from the

scrubbing solution

. As noted above, CEMS data for multiple lime kilns provided no conclusive

evidence that NCG pre

- scrubbing results in lower TRS emissions from kiln to kiln. (EPA 2013b)

Whether lime kiln TRS emissions would be reduced as a result of NCG pre

- scrubbing depen ds

on the degree of combustion of the NCGs in the kiln (e.g., if the incoming NCGs would be

thoroughly combusted regardless of NCG pre

- scrubbing). While there may be some site

- specific

benefits to NCG pre

- scrubbing for some kilns (depending on combustion conditions and TRS

speciation wi thin the incoming NCG streams), it does not appear that this practice is broadly

applicable or capable of resulting in predictable TRS reductions for all kilns.

Lime kiln TRS regulatory option

. Based on analysis of the lime kiln TRS CEMS data, it

is r ecommended i n a separate memorandum that the NSPS 8 ppmdv TRS limit be retained and a

### 34 

## 1 percent monitoring allowance be added for lime kilns. 12 

## (EPA 2013b) Very few kilns (4) are

permitted for limits lower than 8 ppmdv. Lime kilns with scrub bers, ESPs, and combination

ESP

- scrubber systems exhibited similar performance on TRS emissions, most likely because

process factors such as mud washing and good combustion on NCGs are critical factors in

reducing lime kiln TRS emissions. Lime kilns subject to the NSPS ar e likely to use scrubbing

liquid that is not contaminated with reduced sulfur compounds to reduce the potential for kiln

scrubbing liquid to generate TRS emissions. Caustic or weak wash may be used in scrubbers but

is not necessary to meet the 8 ppmdv TRS standard. (EPA 1983) Combustion of NCGs was not

found to substantially increase TRS emissions from lime kilns. Although white

- liquor scrubbers

are used on NCG streams entering some lime kilns, no conclusive evidence that these kilns

perform better on TRS e missions was observed.

Review of lime kiln TRS emissions data and the technologies used to reduce TRS

emissions from lime kilns s uggests that use of process controls such as good lime mud washing

and avoidance of scrubbing liquid contaminated with reduced sulfur compounds continues to be

adequately demonstrated as the best system of emission reduction.

12 

### See Table 11 below.

### 35 

## D. Smelt Dissolving Tanks

Molten smelt is on e of the main products from the combustion of black liquor. Smelt,

which is predominantly Na 2 

## S and Na 2 

## CO 3 

## , is formed in the bottom of the recovery furnace.

Smelt, at approximately 1900 °  to 2100 ° F, filters through the char bed and is continuously

discharged through water

- cooled smelt spouts into the SDT. In the SDT, smelt is mixed with

weak wash water from the reca usticizing area to form green liquor, an aqueous solution of

Na 2 

## CO 3 

## and Na 2 

## S. The green liquor is subsequently transferred to the recausticizing area for

reprocessing into pulping liquor (i.e., white liquor).

The SDT is a large, covered vessel loca ted be low the recovery furnace. Green liquor is

maintained in the tank at a level of about half the depth of the tank. Smelt exiting the recovery

furnace is shattered by high

- pressure steam or shatter sprays of recirculated green liquor. The

steam or shat ter spr ays break the smelt flow into small droplets and cool the smelt before it falls

into and reacts with the liquid in the SDT to form green liquor. Large volumes of steam are

generated when the molten smelt and liquid mix. The vapor space above the liquid lev el provides

an opportunity f or water vapor and PM resulting from the quenching of smelt to settle out of

suspension into the green liquor. An induced

- draft fan constantly draws the vapor and entrained

PM through an add

- on PM control device, generally a wet scrubber. Scrubber water is sprayed

into the scrubber and allowed to drain directly into the SDT, where it reacts w ith smelt to form

green liquor. (EPA 2001)

The 2011 ICR indicates that there are 16 4 SDTs in the U.S. , 70 of which are subject to

NSPS subpart BB. Nearly all of the existing SDTs operate with various wet scrubber controls.

The ICR data indicate that 156 SDTs have wet scrubbers, and 5 SDTs have mist eliminators

(demisters)

. Th e remaining three SDTs have vent gases routinely routed through the recovery

furnace for incineration control of gaseous pollutants prior to exhausting through the recovery

furnace ESP. Two of these three SDTs maintain a wet scrubber exhaust vent as an alternative

recovery furnace bypass (backup) control method. No emissions test data are available for the

SDTs controlled by recovery furnaces because emissions from the SDT and recovery furnace are

comingled. Controls used by the 70 SDTs subject to the NSPS include wet scrub bers (type

unspecified), venturi scrubbers, packed

- bed scrubbers, combination venturi/packed

- bed

scrubbers, various other types of wet scrubbers (e.g., dynamic, impingement, spray tower, wetted

fan), and routing to the recovery furnace.

1. Particulate Matte r from SDTs

The current NSPS filterable PM limit for SDTs ( 0.2 lb/ton BLS ) was established in 1976

based on use of a low

- energy water scrubber or a combination demister/low

- energy water

scrubber

. Wire mesh demister pads were determined not to be as effective as low energy wet

scrubbers when the NSPS was originally proposed in 1976

. The 1986 NSPS review concluded

that no new control technology for SDTs had emerged since the original NSPS. The subpar t MM

PM emission limit (surrogate for HAP metals) for existing SDTs is equivalent to the NSPS limit

of 0.2 lb/ton BLS. The subpart MM PM limit for new sources with initial startup in 2001 or later

is 0.12 lb /ton BLS based on use o f a high

- efficiency wet sc rubber

. Ac cording to subpart MM

§63.860, a n SDT is only considered to be new or reconstructed under the NESHAP (subpart

### 36 

## MM) if the associated recovery furnace is also new or reconstructed. Permit limits, information

from the RBLC and recent stack test data were reviewed to evaluate the SDT PM limit under the

current NSPS review. The results of these reviews are summarized in the paragraphs below.

SDT PM p ermit l imits

. As discussed in a separate memorandum, permit limits for PM

from 160 SDTs were reviewed. (EPA 2013a) The NSPS and the existing source NESHAP

require SDTs to limit their PM emissions to 0.2 lb/ton BLS. Of the 160 SDTs for which permits

were reviewed, 117 are pe rmitted to meet 0.2 lb/ton BLS

. Fourteen SDTs that are not currently

subject to the N SPS and are located at facilities that utilize the PM bubble compliance alternative

under subpart MM have higher permit limits. Nineteen SDTs are permitted to meet the new

source NESHAP limit of 0.12 lb/ton BLS. Ten additional SDTs are permitted with PM li mits

between 0.12 and 0.2 lb/ton BLS, and three of these are located at facilities that utilize the PM

bubble compliance alternative.

RBLC

. Filterable PM limits lower than the NSPS limit of 0.2 lb/ton BLS were identified

in the RBLC for SDTs at three of t he six mills with SDTs listed. These permit limits were

associated with wet scrubber controls and ranged from 0.133 to 0.199 lb/ton BLS. (RTI 2012)

S DT PM s tack t est d ata

. A sample of 175 SDT filterable PM stack tests performed on

133 SDTs from 2001 to 2011 were reviewed to assess the performance of SDTs for the NSPS

review

. (RTI 2013a) Most of the filterable PM test s reviewed were conducted using EPA

Method 5. A few of the tests reviewed were conducted using ORDEQ5

. The sample of PM stack

t ests reviewed included tests of 5 mist eliminator s

, 21 packed bed scrubber s , and 14 8 scrubber s.

The test results are presented in Figures C

- 1 and C

- 2 in Appendix C. Figure C

- 1 shows all of the

PM stack tests reviewed broken out by control device type and F i gure C

- 2 shows only those

SDT s for which mu ltiple tests were available and tabulated

. Based on Figure C

- 1 (and consistent

with prior regulatory conclusions), it is apparent that mist eliminators are challenged to meet the

current NSPS limit of 0.2 lb/ton BLS and are unable to meet the subpart MM new source limit of

0.12 lb/ton BLS. Packed b ed scrubbers performed within the range of performance for other

types of scrubbers and achieved 0.12 lb/ton BLS in most cases. As shown in Figure C

- 2, most

scrubber

- controlled SDTs achieved 0.2 lb/ton BLS with the exception of a few SDTs that are

either i ncluded in the subpart MM PM bubble compliance approach or were tested or retested

under different conditions. Many SDTs with scrubbers or packed

- bed scrubbers also achieved

the new source MACT limit of 0.12 lb/ton BLS. Some of the scrubber

- controlled SDTs ach i e ved

less than 0.12 lb/ton BLS but did so inconsistently (e.g., in some tests but not in others). It should

be noted that m ost of the SDTs depicted in the figures are not currently subject to limits lower

than 0.2 lb/ton BLS.

Regulatory options for SDT PM

. Wet scrubbers remain the most

- utilized control system

for SDTs. A regulatory option of 0.12 lb/ton BLS identical to the current new source subpart

MM limit is recommended for consid eration under the NSPS review for new SDTs

. There does

not appear to be any new technology basis for considering other options

. The practice of routing

SDT emissions through the recovery furnace currently has an un quantified effect on PM

emissions because no emission test data are available to differentiate SDT emissions from the

recovery furnace emissions in systems where the SDT vents through the recovery furnace

. Because some existing SDTs that may become modified or reconstructed under the NSPS

### 37 

## provisions exhibit emissions between 0.12 and 0.2 lb/ton BLS, it is recomm ended that EPA

examine the cost effectiveness and environmental impacts of both of these regulatory options.

2. TRS from SDTs

The current NSPS limit for TRS emissions from SDTs is 0.033 lb as H 2 

## S/ton BLS. The

original 1976 SDT TRS limit of 0.0168 lb/ton BLS was raised to 0.033 lb/ton BLS during the

1986 NSPS review because some SDTs with wet scrubbers could not meet the original limit. In

addition, during the 1986 NSPS review the units of the SDT TRS standard were changed to

specify that TRS emissi ons are to be reported “as H 2 

## S” to permit use of Method 16A as an

alternative to Method 16 to demonstrate compliance. Method 16A was determined to be

equivalent to and less expensive than Method 16. Today additional methods (Methods 16B and

16C) are availa ble and may also be used to measure and report TRS as H 2 

## S. The technology

basis for the current NSPS limit is use of water that is not highly contaminated with dissolved

sulfides for dissolving the smelt and for scrubbing. Permit limits, the RBLC, NCASI te chnical

bulletins, and recent TRS stack test data collected through the ICR were use d to review the

NSPS TRS limit. The results of these reviews are summarized in the paragraphs below.

SDT TRS p ermit l imits

. As discussed in a separate memorandum, permit limits for TRS

from 160 SDTs were reviewed. (EPA 2013a) Approximately half of SDT s for which permits

were reviewed (82 of 160) are permitted to meet the revised NSPS limit of 0.033 lb/ton BLS. An

additional 34 units are permitted to meet the original NSPS limit and emission guideline limit of

0.0168 lb/ton BLS. Twenty units are permitted to meet limits between 0.0168 and 0.033 lb/ton

BLS. Five units are permitted higher than the NSPS limit, ranging from 0.0336 t o 0.066 lb/ton

BLS, due to the statu t e that allows state s and EPA to set less stringent standards for sources

where it may not be technologically or economically feasible to reduce their emissions to the

0.033 lb/ton BLS limit. Twelve units had no apparent TRS limit specified in their permit, and

seven units had a site

- specific concentration or a mass limit specified.

RBLC . SDTs at two mills have TRS emission limits of 0.032 and 0.03 lb/ton BLS,

respectively, which appear to be nearly identical to the NSPS limit of 0.033 lb/ton BLS for

SDTs. The RBLC did not clarify whether the TRS limits were presented in terms of “as H 2 

## S.”

(RTI 2012)

NCASI Technical Bulletin 895 . In 2005, NCASI summarized available information to

date on emissions of TRS from SDTs, including information from p ublished literature, previous

NCASI investigations, and unpublished mill studies. Conclusions from NCASI’s review are as

follows: 13



## • H 2 

## S is generated primarily during the steam shattering and dissolution of molten smelt

within the SDT

.

• L owering the amount of steam used to shatter the smelt, either by lowering the steam

pressure or by using more efficient shatter jets, would lower H 2 

## S emis sions from the SDT

itself

.

13 

### Taken from the abstract for TB 895, available at http://www.ncasi.org//Publications/Detail.aspx?id=2712

.

### 38 

## • Emissions of the three o rganic reduced sulfur compounds

- methyl mercaptan, dimethyl

sulfide, and dimethyl disulfide

- originate primarily in the water or solution (weak wash,

white l iquor) used to scrub the SDT vent gases or to dissolve the smelt. Being mostly

neutral, organic reduced sulfur compounds are not easily removed in an alkaline

scrubber, and minimization of their emissions is related to minimizing their input to the

entire SDT and scrubber system. Thus, unless condensates containing organic reduced

sulfur compounds have been introduced into the system, H 2 

## S is the only reduced sulfur

compound expected to be present in SDT vent gases.

• Fresh water is incapable of scrubbing H 2 

## S from smelt tank vent gases. A scrubbin g

solution with pH of at least 11.5 is needed to ensure efficient scrubbing of H 2 

## S in the

smelt tank scrubber.

• Salt cake or black liquor mix tanks that are vented to the SDT vent gas scrubber could

contribute significant levels of organic reduced sulfur co mpounds that are not easily

removed by scrubbing.

• The use of unoxidized white liquor in the SDT vent gas scrubber could lead to increased

TRS emissions due to stripping of H 2 

## S from white liquor.

• For SDT s with mesh pad control, soluble sulfides trapped in t he pads could generate H 2 

## S

emissions, especially as the pH of the scrubbing solution is lowered due to reaction with

carbon dioxide ( CO 2 

## )

.

• Levels of H 2 

## S in uncontrolled gases within a n SDT appear to be positively correlated

with smelt dissolution rates and gas temperatures.

Technical Bulletin (TB) 895 summarized the emissions test data used as the basis for the

originally promulgated NSPS , additional data considered in the 1986 NSPS review, data from 22

emissions test s performed in the 1990 s , and experiences of eight companies that underwent

research projects between 1990 and 2005 to identify and troubleshoot site

- specific factors

leading to elevated SDT TRS emissions.

Nine of the 22 emissions tests performed in the 1990 s contained all fou r of the NSPS

TRS compounds. H 2 

## S emissions were estimated for the 13 tests that did not contain an H 2 

## S

measurement. The range of SDT TRS emissions from the nine tests where H 2 

## S was measured

was 0.0011 to 0.39 lb/ton BLS as S (equivalent to 0.0012 to 0.41 l b as H 2 

## S /ton BLS). The NSPS

limit of 0.033 lb as H 2 

## S /ton BLS was exceeded in four of the nine tests where H 2 

## S was

measured, and the originally promulgated NSPS limit of 0.0168 lb/ton BLS as H 2 

## S was exceeded

in eight of the nine tests. Five additional tests where H 2 

## S was not measured exceeded the 0.0168

l b/ton BLS level. Thus, the 1990 s emissions test data summarized in TB 895 suggest that the

current NSPS emission limit of 0.033 lb/ton BLS is sometimes exceeded, and that a lower limit

of 0.0168 lb/ton BLS can be difficult to achieve for a number of existing SDTs

.

The mill experiences described in TB 895 revealed a variety of site

- specific process

related factors that can affect SDT TRS emissions. The mills described generally responded to

elevated lev els of TRS emissions ( i.e., levels well above historical levels at the mill or levels

above permit limits

- some of which were 0.0168 lb/ton BLS)

. As a corrective action, the mills

performed repeated trial

- and

- error emissions tests while varying process parameters thought to

affect SDT TRS emissions. For some of the mills , TRS emissions had changed as a result of the

concentration of reduced sulfur compounds building up over time in the proce ss or because of

### 39 

## condensate use in the weak wash. In some cases, SDT TRS emissions appeared to be elevated

because vent gases from s alt cake or black liquor mix tanks were vented into the SDT , but in

other cases venting additional equipment into the SDT wa s determined not to be the root cause

for the elevated emissions. Also, liquor properties (e.g., sulfidity, oxidation) and smelt flow were

found to relate to SDT TRS emissions at some mills

.

For purposes of the 2013 NSPS review, t he k ey take

- away points from the mill

experiences described in TB 895 are that variability in SDT TRS emissions can be attributed to

process factors unique to individual facilities , that no one specific process factor alone dictate s

TRS emissions from mill to mill, and that control of SDT TRS emissions depends on more than

scrubbing alone (i.e., the scrubbing solution, scrubber variables, and site

- specific process

parameters all play a role). (NCASI 2005a)

Recent SDT TRS s tack t est d ata

. Building on the work done by NCASI, EPA collected

recent SDT TRS stack tests through the 2011 ICR. A total of 106 TRS stack tests (on 90 SDTs)

performed between 1987 and 2011 were reviewed for purposes of the NSPS review. All but

seven of the tests were perfo r m ed as recently as 2004. The test methods used incl uded EPA

Methods 16, 16A, 16B, and 16C. Mass e missions were converted to an “as H 2 

## S” basis for

comparison to the current NSPS limit . The control systems tested included 9 7 scrubber s , 6

packed

- bed scrubber s , and 3 mist elimi nator s (some tested more than once)

. No stack test data

were available for SDTs venting through recover y furnaces because emissions from the SDT and

recovery furnace are comingled.

Figure D

- 1 in Appendix D presents all the TRS stack data analyzed for SDTs

. As shown

in the figure, all of the SDTs met the current NSPS limit of 0.033 lb/ton BLS. However, the

former 0.0168 lb/ton BLS limit was not met by all SDTs

. Mist eliminators, packed bed

scrubbers, and other types of scrubbers exhibited overlapping performance. Only packed

- bed

scrubbers had emissions below 0.0168 lb/ton BLS in all tests, though only a few (6) test results

were available for packed

- bed scrubber s compared to other types of scrubbers (97)

. Figure D

- 2

shows SDTs for which repeat test data were reviewed. All of the SDTs met the 0.033 lb/ton BLS

limit but, some of the SDTs were repeatedly unable to achieve TRS emissions as low as to

0.0168 lb/ton BLS

.

Appendix E provides tables of the emissions data presented in Figures D

- 1 and D

- 2.

Information on the type of scrubbing solution used during TRS emissions testing was limited in

the stack test reports. However, r eview of the ICR data base indicated th at the vast majority of

SDTs in the U.S. are using weak wash or a combination of fresh water and caustic as the

scrubbing medium.

Regulatory options for SDT TRS

. The baseline level of SDT TRS emission s of 0.033

lb/ton BLS has been achieved in pra ctice. The technological basis for this limit (use of water in

the smelt tank and scrubber with low sulfide content) has not changed since the 1986 NSPS

review

. However, becaus e many SDTs have achieved l evels below 0.0168 lb/ton BLS, EPA

could explore the cost ef fectiveness and environmental impacts of reducing the NSPS limit for

new, modified, and reconstructed SDTs to the original NSPS and emissions guidelines level of

0. 0168 lb/ton BLS under the assumption that new, modified, or reconstructed sources would not

### 40 

## suffer from the process

- related issues that have plagued some existing sources. The EPA might

also consider repeat testing for TRS from SDTs due to the potential for a variety of process

related factors that can affect emissions (e.g., build

- up of TRS compounds in the system that can

lead to elevated TRS emissions from SDTs over time).

E. Extension of NSPS to Other Processes and Pollutants

The 2013 NSPS review focuse s on the PM and TRS emission standards in subpart BB

that are due for review under CAA se ction 11 1 ( b )( 1 ) (B)

. Additional research beyond the scope

and timeline established for review of the PM and TRS standards in subpart BB would be

required to determine the degree of emission limitation achievable through application of best

system of emissio n reduction in order to establish new emission standards for emission sources

or pollutants not currently regulated under subpart BB.

Pulp and paper combustion sources emit NOx, SO 2 

## , and CO in addition to PM and TRS.

No standards were established for NOx, SO 2 

## , and CO emissions from recovery furnaces and lime

kilns in the original kraft pulping NSPS or through the 1986 NSPS review because no

demonstrated control techniques, considering costs, were identified for these p ollutants and

sources in the kraft pulping industry. (EPA 1976, EPA 1983) Since that time permitting

authorities have implemented permit limits for these pollutants based on site

- specific process

measures that may or may not be transferrable from mill to m ill. The pollutants NOx and SO 2 

## are

of particular interest because these pollutants can react in the atmosphere to form secondary

emissions of PM with an aerodynamic diameter less than or equal to 2.5 micrometers ( PM 2.5 

## )

. Additio nal research would be needed to determine the technological basis for these permit limits,

analyze emissions test data, and weigh the benefits, trade

- offs, and costs of further reductions in

these pollutants. For example, measures taken to reduce one of th ese pollutants may increase

another pollutant (e.g., a common theme in decisions pertaining to control of CO versus NOx).

Similarly, firing more concentrated black liquor in a kraft recovery furnace may reduce SO 2 

## emissions, but increase emissions of NOx a nd PM

. ( NCASI 2009 ) While a few recovery

furnaces in the U.S. operate with ESPs followed by wet scrubbers that could potentially reduce

SO 2 

## emissions, the performance data for PM emissio ns from these furnaces does not indicate

superior performance on PM em issions. Control technologies such as f lue gas recirculation,

selective catalytic reduction (SCR) and selective non

- catalytic reduction (SNCR) have not been

demonstrated on recovery furnaces or lime kilns. Combustion burner and combustion air

characteristi cs may be optimized in site

- specific specific circumstances, but it is not clear how

transferrable successful modifications made at one mill would be to furnaces at other mills.

Additional research is needed to evaluate the mechanisms for reducing NOx, SO 2 

## and CO

emissions from kraft pulp mills.

As shown in Table 9 , p ower boilers are by far the largest source of NOx and SO 2 

## emissions at kraft pulp and paper mills. ( NCASI 2009 and NCASI 2012 ) Kraft recovery furnaces

are the second largest source of SO 2 

## and NOx after power boilers. Together, power boilers and

recovery furnaces account for approximately 98 and 92 percent of the industry’s SO 2 

## a nd NOx

emissions, respectively. Sulfur dioxide emissions fr om power boilers are more than six times the

SO 2 

## emiss ions from kraft pulp mill sources

, and NOx emissions from power boilers are

approximately double the NOx emissions from kraft pulp mill sources. Power boiler emissions of

### 41 

## PM, NOx, and SO 2 

## are regulated under separate NSPS ( e.g., 40 CFR part 60, s ubparts Db and

Dc) , and therefore are not part of the subpart BB NSPS review

.

Filterable PM emissions from kraft recovery furnaces, SDTs, and lime kilns combined

(all regulated under the kraft pulp mill NSPS) exceed the filterable PM emissions from power

boilers. The NCASI estimate of filterable PM emissions from kraft recovery furn aces, SDTs, and

lime kilns (22,000 tpy) shown in Table 9 correlates well with the filterable PM emissions

estimated in the NSPS review analysis (21,600 tpy). (RTI 2013b ) Table 9 also shows that

filterable PM emissions from sulfite and stand

- alone semi

- chem ical pulp mills are very low

compared to emissio ns from kraft pulp mills which, in addition to the declining trend in the

number of soda, sulfite and stand

- alone semichemical mills, supports continued exclusion of

sulfite and stand

- alone semichemical pulp mills from NSPS. (RTI 2013c )

The pulp and paper industry has continually reduced emissions of NOx and SO 2 

## over

time in response to site

- specific regulatory limits, equipment modernization, improved operating

and energy efficiency, alternative fuel selection, and industry restructuring. Increased use of

NDCE recovery furnaces over the past three decades (as opposed to DCE furnaces) is one reason

SO 2 

## emissions have declined in the kraft pulping sector. These trends are observed in Table 10

. (NCASI 2012) The NOx and SO 2 

## emission reductions occurred while pulp and paper production

increased, peaked (in 1995 for pulp and in 2000 for paper), and then gradually declined over the

past decade. ( NCASI 2012) Historical totals and trends like those sho wn in Tables 9 and 10 are

not available for CO.

Table 9 . 2010 Nationwide SO 2 

## , NOx, and PM Emissions from Pulp and Paper Mills

(10 3 

## tons) Reported in NCASI 2012

Source SO 2 

## , tpy NOx, tpy Filterable PM, tpy

Boilers 205 124 17

Gas Turbines

- 2

-

Kraft recovery

furnaces* 29 55 12

Kraft SDTs* 1

- 6

Kraft lime kilns* 2 8 4

Kraft thermal

oxidizers 1 1 <1

Sulfite pulp mills 1 3 <1

Semi

- chemical pulp

mills <1 1 <1

Total 239 194 39

Source: NCASI 2012 *Includes units at one soda pulp mill.

### 42 

## Table 10 . Trends in Nationwide SO 2 

## and NOx Emissions from Pulp and Paper Mills

(10 3 

## tons) Reported in NCASI 2012

Emission Source 1980 1985 1990 1995 2000 2005 2010

SO 2 

## , tpy

Boilers 730 523 461 393 351 293 205

Kraft pulping 122 153 96 86 57 44 33

NOx, tpy

Boilers 207 231 231 233 199 156 126

Kraft pulping 66 73 69 76 76 69 63

Source: NCASI 2012

The PM concentration limits in the subpart BB NSPS and subpart MM NESHAP are

based on filterable PM measured by EPA Method 5. Filterable PM consists of particles directly

emitted by a source as a solid or liquid at the stack (or similar release conditions) and captur ed

on the filter of a stack sampling train. A fraction of the PM emitted from recovery furnaces,

SDTs and lime kilns is PM 2.5



## . Available emissions test data for PM 2.5 

## are limited because the

measurement method for PM 2.5 

## (EPA Method 201A) does not apply for wet scrubber stacks.

Generally, the same PM controls that remove filterable PM also reduce filterable PM 2.5



## emissions.

Con densable PM is also emitted from recovery furnaces, SDTs and lime kilns.

Condensable PM is material that is in vapor phase at stack conditions that condenses and/or

reacts upon cooling and dilution in the ambient air to form solid or liquid PM after discha rge

from the stack. For purposes of implementing the NAAQS, Appendix A to subpart A of 40 CFR

part 51 defines PM 2.5 

## as including both filterable and condensable fractions of PM. Emissions of

condensable PM are measured using EPA Method 202, which can be ad ded as the “back half” to

a Method 5 sampling train. Work to date suggests that condensable PM emissions may not

correlate with filterable PM emissions, and there is some indication that SO 2 

## present in the stack

gas from pulp and paper combustion sources m ay affect the accuracy of the condensable PM

measurement. (NCASI 2002 b , NCASI 2005 b ) Additional data and research are needed to

develop a broader understanding of condensable PM emissions from pulp and paper combustion

sources and to determine mechanisms f or reducing condensable PM.

A dditional research would also be required to quantitatively evaluate TRS emissions

from wastewater treatment systems. Water treatment systems were not included in the original

Subpart BB NSPS or with the 1986 NSPS review because methods of measuring TRS emissions

from open treatment ponds were not available at that time. The Subpart S MACT standards

promulgated in 1998 require reductions in HAP emissions from kraft condensate systems and the

control measures (such as steam stripping systems or biological treatment) used to reduce HAP

emissions from condensates also reduce TRS emissions from wastewater treatment systems.

However, there is currently no EPA met hod for measur ing TRS emission from open wastewater

treatment syste ms. The NCASI has investigated methods for measuring and modeling TRS

emissions from water treatment systems over the past few years. 14 

## Additional research is needed

14 

### Technical bulletins from National Council for Air and Stream Improvement, Research Triangle Park, NC :

1) Technical Bulletin No. 0956. Emissions of Reduced Sulfur Compounds and Methane from Kraft Mill

Wastewater Treatment Plants

. September 2008.

### 43 

## to evaluate the applicability of NCASI’s work for regulatory purposes of measuring TRS

emis sions and developing a better understanding of measures that could potentially be used to

further reduce emissions from wastewater treatment ponds.

IV. Summary of Regulatory Options for the 2013 Kraft Pulp Mill NSPS Review

Recent information from EPA’s 2011 ICR and other information sources such as RBLC

a nd NCASI technical bulletins were reviewed in order to perform the 2013 technology review

for subpart BB, which will be proposed in a revised subpart BBa. The ICR data reviewed

included comprehensive equipmen t and control counts, process characteristics, stack test data

extracted from test reports, and continuous monitoring data. Table 11 summarizes the regulatory

options that emerged from the technology review for further analysis of cost, environmental, and

energy impacts

. A separate memorandum provides the impact analyses. (RTI 2013b )

2) Technical Bulletin No. 0957. Spatial Ambient Air Sampling and Analysis Methods for Quantifying Reduced

Sulfur Compound and Methane Emissions From Kraft Mill Wastewater Treatment Plants

. N ovember 2008.

3) Technical Bulletin No. 1000. Mechanistic Approach for Estimating Hydrogen Sulfide Emissions from

Wastewater Treatment Plants. December 2012.

### 44 

## Table 11

. Summary of Baseline Technologies and Regulatory Options for the NSPS Review

Affected

source Pollutant Baseline technology and

NSPS subpart BB

standard 1 

### Regulatory option s for N SPS review (s ubpart BBa) 1,2



### New sources Existing sources

that are

reconstructed Existing sources

that are modified

Recovery

furnace PM ESP with collection

efficiency of 99.5%

meeting 0.044 gr/dscf MACT new source

limit of 0.015 gr/dscf MACT new source

limit of 0.015 gr/dscf Explore impacts of

limits ranging from

0.015 to 0.044

gr/dscf

TRS

(straight) NDCE recovery furnace

with good combustion

control or DCE recovery

furnace with BLO

meeting 5 ppmdv Maintain TRS limit at 5 ppmdv and restrict the 1 percent

monitoring allowance to 45 ppmdv as recommended in EPA

2013b

.

TRS

(cross) Same as above, except 25

ppmdv for cross recovery

furnaces No change to the cross recovery furnace limit.

Opacity 35% opacity with 6%

allowance Decrease opacity limit to 20 percent opacity and reduce the

monitoring allowance to 2 percent of averaging periods. Add

ESP parameter monitoring (voltage and current) to indicate

compliance during the monitoring allowance as recommended in

EPA 2013b

. Lime kiln PM Venturi scrubber with 30

in. H 2 

### O pressure drop

meeting 0.066 gr/dscf for

gas

- fired kilns, 0.13

gr/dscf for oil

- fired kilns MACT new source

limit of 0.010 gr/dscf MACT new source

limit of 0.010 gr/dscf Explore impacts of

limits ranging from

0.010 to 0.06 4

gr/dscf

TRS More efficient process

controls and use of

caustic solution in

scrubber to meet 8 ppm Maintain current limit of 8 ppmdv and add a 1 percent

monitoring allowance restricted to an upper limit of 22 ppmdv as

recommended in EPA 2013b

.

Opacity No NSPS requirement;

MACT limit of 20%

opacity with 6%

allowance Add MACT limit of 20 percent opacity to NSPS with a 1 percent

monitoring allowance. Add ESP parameter monitoring (voltage

and current) to indicate compliance during the monitoring

al lowance as recommended in EPA 2013b

. Smelt

dissolving

tank PM Wet scru bber or a

combination

demister/ wet scrubber

meeting 0.2 lb/ton BLS MACT new source

limit of 0.12 lb/ton

BLS Explore impacts of

limits ranging from

0.12 to 0.2 lb/ton

BLS Expl ore impacts of

limits ranging from

0.12 to 0.2 lb/ton

BLS

TRS Using water not highly

contaminated with

dissolved sulfides for

dissolving the smelt and

scrubbing to meet 0.033

lb/ton BLS as H 2 

### S Explore impacts of limits ranging from the original 1976 NSPS

limit of 0.0168 lb/ton BLS to the current limit of 0.033 lb/ton

BLS.

1. Concentration limits for recovery furnaces are at 8 percent oxygen (O 2 

### ), while concentration limits for lime kilns

are at 10 percent O 2



### . 2. “MACT” refers to th e 40 CFR part 63 subpart MM NESHAP based on maximum achievable control technology

.

### 45 

## V. References

EC 20 1 0 European Commission

. Integrated Pollution Prevention and Control:

Reference Document on Best Available Techniques in the Pulp and Paper

Industry

. April 20 1 0

.

EPA 1976 U.S. Environmental Protection Agency. Standards Support and

Environmental Impact Statement Volume I : Proposed Standards of

Performance for Kraft Pulp Mills

. Publication No. EPA

- 450/2

- 76

- 014a.

September 1976.

EPA 1977 U.S. Environmental Protection Agency. Standards Support and

Environmental Impact Statement Volume II : Promulgated Standards of

Performance for Kraft Pulp Mills

. Publication No. EPA

- 450/2

- 76

- 014b.

December 1977.

EPA 1979 U.S. Environmental Protection Agency. Kraft Pulping: Control of TRS

Emissions from Existing Mills

. Publication No. EPA

- 450/2

- 78

- 003b.

March 1979.

EPA 1983 U.S. Environmental Protection Agency. Review of New Source

Performance Standards for Kraft Pulp Mills

. Publication No. EPA

- 450/3

-

8 3

- 017. September 1983.

EPA 1996 U.S. Environmental Protection Agency

. Technical Support Document:

Chemical Recovery Combustion Sources at Kraft and Soda Pulp Mills.

Publication No. EPA

- 453/R

- 96

- 012

. October 1996

.

EPA 1997 U.S. Environmental Protection Agency. Pulp, Paper, and Paperboard

Industry

– Bac kground Information for Promulgated Air Emission

Standards; Manufacturing Process es at Kraft, Sulfite, Soda, Semi

Chemical , Mechanical, and Secondary and Non

- wood Fiber Mills.

Document No. EPA

- 453/R

- 93

- 050b . Research Tria ngle Park, NC. October

1997

.

EPA 2001 U.S. Environmental Protection Agency. Pulp and Paper Combustion

Sources NESHAP: A Plain English Description. EPA

- 456/R

- 01

- 003.

September 2001.

EPA 2011 Bradfield , J. and K

. Spence, U.S. Environmental Protection Agency

. Summary of Clean Condensate Alternative Technology Review. October

20, 2011.

EPA 201 3 a Bradfield , J. and K

. Spence, U.S. Environmental Protection Agency

. Review of the Air Permits for Kraft Pulp Mills

. Memorandum to Docket

ID No. E PA

- HQ

- OAR

- 2012

- 0640

. April 26, 2013.

### 46 

## EPA 2013 b Spence

, K., U.S. Environmental Protection Agency. Review of the

Continuous Emission Monitoring and Continuous Opacity Monitoring

Data from the Pulp and Paper Information Collectio n Request Responses

Pertaining to Subpart BB Sources . Memorandum to Docket ID No. E PA

HQ

- OAR

- 2012

- 0640 . April 5, 2013.

NCASI 2002a National Council for Air and St ream Improvement, Inc. Compilation of

Speciated Reduced Sulfur Compound and Total Reduced Sulfur Emissions

Data for Kraft Mill Sources. Technical Bulletin No. 08 49. Research

Triangle Park, NC. August 2002.

NCASI 2002 b National Council for Air and Stream Improvement, Inc. Performance of

EPA tack sampling Methods for PM 10 

## , PM 2.5 

## and Condensible Particulate

Matter on Sources Equipped with Electrostatic Precipitators

. Technical

Bulletin No. 0852 . Research Triangle Park, NC

. September 2002

.

NCASI 2005 a National Council for Air and Stream Improvement, Inc. Smelt Dissolving

Tank TRS Emissions: A Review of the Impact of Operating Variables and

Scrubber Characteristics. Technical Bulletin No. 0895. Research Triangle

Park, NC

. February 2005.

NCASI 2005b National Council for Air and Stream Improvement, Inc. Condens i ble

Particulate Matter Emissions fr om Sources Equipped with Wet Scrubbers.

Technical Bulletin No. 0898 . Research Triangle Park, NC

. March 2005.

NCASI 2009 Environmen tal Footprint Comparison Tool. Trade

- offs and Co

- benefits

Accompanying SOx and NOx Control

. 2009.

http://www.paperenvironment.org/PDF/SOxNOx/SOxNOx_Full_Text.pdf

NCASI 2012 National Council for Air and St ream Improvement, Inc. Pulp and Paper

Mill Emissions of SO 2 

## , NOx, and Particulate Matter in 2010

. Special

Report No. 12

- 03 . Research Triangle Park, NC

. June 20 12

.

Springer 2000 Springer, A

. , Industrial Environmental Control

– Pulp and Paper Industry

3 rd 

## Edition . TAPPI Press. 2000.

RTI 2012 Holloway

, T. RTI International. Summary of RBLC and Other Findings to

Support Section 111(b) Review of Kraft Pulp Mill NSPS

. Memorandum to

K

. Spence, N

. Swanson, J

. Bradfield, and B

. Schrock , U .S. Environmental

Protection Agency . October 18, 2012.

RTI 2013a Hanks, K.

, RTI International. Emissions Test Data for the Kraft Pulp Mill

NSPS Review . Memorandum to K

. Spence and B

. Schrock , U .S.

Environmental Protection Agency . April 22, 2013.

### 47 

## RTI 2013b Holloway , T. and K. Hanks, RTI International. Emissions Inventory for

Kraft Pulp Mills and Costs/Impacts of the Section 111(b) Review of the

Kraft Pulp Mills NSPS. Memorandum to K. Spence and B. Schrock, U.S.

EPA. February 4, 2013.

RTI 2013c Hanks, K., T. Holloway, and C. Gooden, RTI International. Projections of

the Number of New, Modified, and Reconstructed Emission Units for the

Kraft Pulp Mill NSPS Review . Memorandum to K. Spence, U.S.

Environmental Protection Agency. February 4, 2013.

STAPPA 2006 State and Territorial Air Pollution Program Administrators and the

Association of Local Air Pollution Control Offi cials

(STAPPA/ALAPCO). Controlling Fine Parti culate Matter Under the

Clean Air Act: A Menu of Options. March 2006

.

## Appendix A

Recovery Furnace PM Emissions Data

List of Figures

Figure A

- 1. All Recovery Furnace Stack Tests

- DCE vs NDCE

Figure A

- 2. DCE WBESP PM Stack Tests, gr/dscf @ 8% O2 *

Figure A

- 3. DCE PM Stack Tests, gr/dscf @ 8% O2 (various controls) *

Figure A

- 4. NDCE DBESP PM Stack Tests, gr/dscf @ 8% O2 (single and multiple tests) *

Figure A

- 5. NDCE DBESP PM Stack Tests, gr/dscf @ 8% O2 (NDCEs with multiple tests

only) *

Figure A

- 6. NDCE PM Stack Tests, gr/dscf @ 8% O2 (WBESP) *

Figure A

- 7. NDCE PM Stack Tests, gr/dscf @ 8% O2 (various controls) *

Figure A

- 8. Stack Tests for one NDCE with DBESP/SCBR

(43 tests conducted from 2001 to 2009) *

*A data table for thi s figure is provided in Appendix E.A‐1A‐2Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.A‐3Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.A‐4Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.A‐5Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.A‐6Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.A‐7Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.A‐82001‐‐‐>2009

## Appendix B

Lime Kiln PM Emissions Data

List of Figures

Figure B

- 1. PM Stack Tests for Lime Kilns

Figure B

- 2. PM Stack Tests for ESP

- Controlled Lime Kilns *

Figure B

- 3. PM Stack Tests for ESP/Scrubber

- Controlled Lime Kilns *

Figure B

- 4. PM Stack Tests for Scrubber

- Controlled Lime Kilns *

Figure B

- 5. PM Stack Tests for ESP

- Controlled Lime Kilns Firing Gas or Oil *

Figure B

- 6. PM Stack Tests for ESP

- Controlled Lime Kilns Firing Gas/Coke or Unspecified

Fuel *

Figure B

- 7. PM Stack Tests for Lime Kilns With Combined ESP/Scrubber Control *

Figure B

- 8. PM Stack Tests for Scrubber

- Controlled Lime Kilns Firing Gas and Oil *

Figure B

- 9. PM Tests for Scrubber

- Controlled Lime Kilns Firing Gas/Coke or Unspecified

Fuels *

*A data table for this figure is provided in Appendix E.B‐1B‐2Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.B‐3Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.B‐4Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.B‐5Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.B‐6Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.B‐7Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.Note that the same kiln may berepresented on multiple vertical lines in FigureB-7 (e.g., separate vertical lines for different fuels).B‐8Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.B‐9Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.

## Appendix C

Smelt Dissolving Tank PM Emissions Data

List of Figures

Figure C

- 1. SDT PM Stack Tests, gr/dscf *

Figure C

- 2. SDTs With Multiple PM Stack Tests, gr/dscf *

*A data table for this figure is provided in Appendix E.C‐1C‐2Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.

## Appendix D

Smelt Dissolving Tank TRS Emissions Data

List of Figures

Figure D

- 1. SDT TRS Stack Tests, lb as H 2 

## S/ton BLS *

Figure D

- 2. SDTs with Multiple TRS Stack Tests, lb as H 2 

## S/ton BLS *

*A data table for this figure is provided in Appendix E.D‐1Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.D‐2Note: Each vertical line represents one emission unit. Eachdata point represents each test average (e.g., average of 3 test runs). See Appendix E for a data table.

## Appendix E

Data Tables for Selected Figures in Appendices A through D

### E

- 1 

## Data Table for Figure A

- 2

. PM Emissions Test Data for DCE Recovery Furnaces with Wet Bottom ESP (WBESP)

Description Test Date Test

Method Out let Average Conc

. gr/dscf @ 8% O 2 No.

Run s No.

Runs

B DL Duplicate Emission Unit

N otes RTI+EUID Graph

order

RB2

- 2A South stack 11/4/2010 M5 0.0195 3 0 Separate stacks 124.019 1

RB2

- 2B North stack 11/4/2010 M5 0.0304 3 0 Separate stacks 124.019 1

No. 1 RF North stack 6/23 /2011 M5 0.0154 3 0 Separate stacks 130.1 2

No. 1 RF South stack 6/23 /2011 M5 0.0172 3 0 Separate stacks 130.1 2

No. 2 RF North stack 6/22 /2011 M5 0.0115 3 0 Separate stacks 130.2 3

No. 2 RF South stack 6/22 /2011 M5 0.0115 3 0 Separate stacks 130.2 3

No. 1 RB 11/3/2009 M5 0.007 3 0 143.7000 4

No. 2 Recovery Furnace 11/3/2009 M5 0.003 3 0 143.7010 5

No. 3 Recovery Furnace 11/4/2009 M5 0.007 3 0 143.7020 6

No. 2 Recovery Boiler 4/22/2009 M5 0.0029 3 0 145.54 7

No. 3 Recovery Boiler 4/22/2009 M5 0.0072 3 0 145.55 8

No. 1 Recovery Furnace Upriver

Stack 4/13/2011 M5 0.0218 3 0 separate stacks 146.8 9

No. 1 Recovery Furnace

Downriver Stack 4/13/2011 M5 0.0091 3 0 separate stacks 146.8 9

RB North 7/21/2010 M5 0.012 3 0 Separate stacks 205.009 10

RB South 7/21/2010 M5 0.012 3 0 Separate stacks 205.009 10

# 3 Recovery Boiler 2/ 21/2008 M5 0.0099 3 0 105.EU445A 11

Recovery Boiler 2 9/16/2009 M5 0.0147 4 0 154.P36

- Recovery

Furnace 2 12

Recovery Boiler 1 6/21 /2011 M5 0.0076 3 0 154.P39

- Recovery

Furnace 1 13

### E

- 2 Description Test Date Test

Method Out let Average Conc

. gr/dscf @ 8% O 2 No.

Run s No.

Runs

B DL Duplicate Emission Unit

N otes RTI+EUID Graph

order

RB 1 and RB 3 Common Stack 3/16/2010 M5 0.0159 3 0 Common stack (represents 2

RFs) 154.P39 and P37

- Recovery Furnace 1 and

Recovery Furnace 3 14

Recovery Furnace 18 3/4/2010 M5 0.0011 3 0 different dates w/in same year 156.RF18 15

Recovery Furnace 18 7/28/2010 M5 0.0036 3 0 different dates w/in same year 156.RF18 15

Recovery Furnace 19 5/12/2010 M5 0.0017 3 0 different dates w/in same year 156.RF19 16

Recovery Furnace 19 9/22/2010 M5 0.0056 3 0 different dates w/in same year 156.RF19 16

Recovery Furnace 19 11/4/2010 M5 0.0022 3 0 Two 3

- run tests on same day

- reason unspecified 156.RF19 16

Recovery Furnace 19 11/4/2010 M5 0.0029 3 0 Two 3

- run tests on same day

- reason unspecified 156.RF19 16

No. 1 Recovery Furnace 6/1/2011 M5 0.0055 3 0 163.RF1901 17

No. 1 Recovery Furnace Stack A 7/14/2009 M5 0.0175 3 0 separate stacks 166.RB01 18

No. 1 Recovery Furnace Stack B 7/14/2009 M5 0.0094 3 0 separate stacks 166.RB01 18

Recovery Furnace North ESP

(Wet bottom) 1/18/2011 M5 0.013 3 0 Separate stacks 167.005RB 19

Recovery Furnace South ESP

(Wet bottom) 1/18/2011 M5 0.033 3 0 Separate stacks 167.005RB 19

Recovery Boiler 1 6/9/2011 M5 0.006 3 0 188.014RB1 20

Recovery Boiler 2 9/14/2010 M5 0.012 3 0 Separate methods (M5) 188.016RB2 21

Recovery Boiler 2 9/14/2010 OR DEQ

M5 0.013 3 0 Separate methods (ORDEQ5) 188.016RB2 21

Recovery Boiler 10 11/14/2007 M5 0.011 3 0 206.G

- 31 22

Recovery Boiler 11 11/15/2007 M5 0.013 3 0 206.G

- 32 23

No. 2 Recovery Furnace 11/2/2010 M5 0.013 3 0 600.G0803 24

### E

- 3 

## Data Table for Figure A

- 3

. PM Emissions Test Data for DCE Recovery Furnaces with Various Controls

Description Test Date Test

Method Out let Average Conc

. gr/dscf @ 8% O 2 No.

Run s No.

Runs

B DL Duplicate Emission Unit N otes RTI+EUID Control Graph

order

No. 1 Recovery

Furnace 10/29 /2002 M5 0.015 3 0 121.000013 DBESP 1

No. 1 Recovery

Furnace 8/23 /2004 M5 0.008 3 0 different years 121.000013 DBESP 1

No. 2 Recovery

Furnace 10/30 /2002 M5 0.012 3 0 121.000014 DBESP 2

No. 2 Recovery

Furnace 8/19 /2004 M5 0.006 3 0 different years 121.000014 DBESP 2

No. 1 Recovery

Boiler (South 1A) 11/3/2010 M5 0.0 0 14 3 0 separate stacks 124.001 DBESP 3

No. 1 Recovery

Boiler (North 1B) 11/3/2010 M5 0.0019 3 0 separate stacks 124.001 DBESP 3

Recovery Furnace 4

(two chambers

operating) (Condition

#1) 12/2/2003 M5 0.004 3 0 Separate conditions: Recovery

Furnace 4 (both ESP chambers

and all fields operating)

(Condition #1) 131.5 DBESP 4

Recovery Furnace 4

(one chamber

operating) (Condition

#2 and #3) 12/3/2003 M5 0.008 3 0 Separate conditions: Recovery

Furnace 4 (1

- 2 fields out of

service) (Condition #2 and #3) 131.5 DBESP 4

Recovery Furnace 4 12/5/2003 M5 0.019 4 0 Separate conditions: Recovery

Furnace 4 131.5 DBESP 4

No. 20 Recovery

Boiler 12/1/2010 M5 0.0107 3 0 119.EQT008 DBESP 5

No. 2 Recovery

Boiler 6/26/2003 M5 0.004 3 0 142.CU7214 DBESP 6

No 2 Recovery Boiler 6/9/2009 M5 0.01 3 0 175.RB2A DBESP 7

Recovery Boiler 3 10/25/2010 M5 0.0285 3 0 Separate conditions 606.RB3 DBESP 8

Recovery Boiler 3 10/26/2010 M5 0.0037 3 0 Separate conditions 606.RB3 DBESP 8

No. 1 RB ESP

- Left

Side ESP 10/28/2009 M5 0.019 3 0 Separate stacks 613.001L DBESP 9

No. 1 RB ESP

- Right

Side ESP 10/28/2009 M5 0.022 3 0 Separate stacks 613.001R DBESP 9

No. 2 RB ESP

- Left

Side 10/27/2009 M5 0.0109 3 0 Separate stacks 613.002L DBESP 10

No. 2 RB ESP

- Right

Side 10/27/2009 M5 0.0058 3 0 Separate stacks 613.002R DBESP 10

Recovery Boiler 2 7/8 /2009 M5 0.025 3 0 171.002 DBESP

- WPR 11

Recovery Boiler 3 7/9 /2009 M5 0.02 3 0 171.003 DBESP

- WPR 12

Recovery Boiler

-

East 12/16/2010 M5 0.018 3 0 Separate stacks 171.004 DBESP

- WPR 13

### E

- 4 Description Test Date Test

Method Out let Average Conc

. gr/dscf @ 8% O 2 No.

Run s No.

Runs

B DL Duplicate Emission Unit N otes RTI+EUID Control Graph

order

Recovery Boiler

-

West 12/16/2010 M5 0.017 3 0 Separate stacks 171.004 DBESP

- WPR 13

Recovery Boiler 9/19/2008 M5 0.0126 3 0 197.2 DBESP/SCBR 14

Recovery Furnace

-

Condition 1

(Operating 5 ESPs) 3/7/2007 M5 0.0373 3 0 Separate conditions: Recovery

Furnace

- Condition 1

(Operating 5 ESPs) 152.03 WBESP/SCBR 15

Recovery Furnace

-

Condition 2

(Operating 6 ESPs) 3/9/2007 M5 0.03 3 0 Separate conditions: Recovery

Furnace

- Condition 2

(Operating 6 ESPs) 152.03 WBESP/SCBR 15

Recovery furnace

scrubber inlet and

outlet 3/29/2001 M5 0.019 3 0 different dates 152.03 WBESP/SCBR 15

Recovery furnace 9/1/2004 M5 0.0308 3 0 different dates 152.03 WBESP/SCBR 15

Recovery furnace 9/24/2002 M5 0.0313 3 0 different dates 152.03 WBESP/SCBR 15

No. 2 Recovery

Furnace 6/15/2004 M5 0.011 3 0 different dates 166.RB02 WBESP/SCBR 16

No. 2 Recovery

Furnace 7/16/2009 M5 0.0294 3 0 166.RB02 WBESP/SCBR 16

### E

- 5 

## Data Table for Figure A

- 4

. PM Emissions Test Data for N DCE Recovery Furnaces with Dry Bottom ESPs (DBESP)

Description Test Date Test

Method Outlet Average Conc.

gr/dscf @ 8% O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

No. 3 Recovery Furnace 6/21/2011 M5 0.00295 3 0 130.3 1

Recovery Furnace 5 12/9/2003 M5 0.011 3 0 131.6 2

RFEU 1/27 /2011 M5 0.012 3 0 140.55 3

No. 3 Recovery Furnace

- North 4/30/2008 M5 0.0127 3 0 separate stacks 147.14 4

No. 3 Recovery Furnace

- South 4/30/2008 M5 0.0117 3 0 separate stacks 147.14 4

No. 4 Recovery Furnace 7/17/2008 M5 0.0108 3 0 different years 147.5 5

No. 4 Recovery Furnace

- Front Half 1/28/2009 M5 0.00967 3 0 different years 147.5 5

No. 1 Recovery Furnace 7/21/2010 M5 0.0147 3 0 148.001 6

No. 2 Recovery Furnace 7/26/2010 M5 0.0128 3 0 148.007 7

No. 2 Recovery Furnace

- East Stack 7/21/2004 M5 0.02 3 0 separate stacks 165.000006 8

No. 2 Recovery Furnace

- West Stack 7/21/2004 M5 0.0 15 3 0 separate stacks 165.000006 8

No. 1 Recovery Furnace

- North Stack 7/24/2004 M5 0.023 3 0 separate stacks 165.000013 9

No. 1 Recovery Furnace

- South Stack 7/24/2004 M5 0.029 3 0 separate stacks 165.000013 9

No. 5 Recovery Boiler

- North Stack 2/17/2009 M5 0.0186 3 0 Same emission unit as 181.50

(separate stacks) 181.49 10

No. 5 Recovery Boiler

- South Stack 2/17/2009 M5 0.0108 3 0 Same emission unit as 181.49

(separate stacks) 181.50 10

Recovery Boiler No. 3 8/24/2009 M5 0.0027 3 0 182.037 11

Recovery Furnace 3 7/27/2004 M5 0.01 3 0 198.019 12

No. 3 Recovery Furnace 6/15/2011 M5 0.0109 3 0 199.002 13

#3 Recovery Boiler

- West Exhaust

Stack 4/22/2008 M5 0.013 3 0 separate stacks 207.038 14

#3 Recovery Boiler

- East Exhaust Stack 4/22/2008 M5 0.0137 3 0 separate stacks 207.038 14

Recovery Boiler, SN

- 05A 6/22/2005 M5 0.0239 3 0 340.005 15

Chemical Recovery Furnace

- West

Stack Front Half 2/23/2011 M5 0.0163 3 0 Separate stacks/separate methods:

Chemical Recovery Furnace

- West

Stack Front Half 615.24 16

Chemical Recovery Furnace

- East

Stack Front Half 2/23/2011 M5 0.0246 3 0 Separate stacks/separate methods:

Chemical Recovery Furnace

- East

Stack Front Half 615.24 16

Chemical Recovery Furnace

- West

Stack ODEQ 5 2/23/2011 ODEQ5 0.0198 3 0 Separate stacks/separate methods:

Chemical Recovery Furnace

- West

Stack ODEQ 5 615.24 16

Chemical Recovery Furnace

- East

Stack ODEQ 5 2/23/2011 ODEQ5 0.0282 3 0 Separate stacks/separate methods:

Chemical Recovery Furnace

- East

Stack ODEQ 5 615.24 16

### E

- 6 Description Test Date Test

Method Outlet Average Conc.

gr/dscf @ 8% O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

Chemical Recovery Furnace 6/15/2004 M5 0.014 3 0 100.037A 17

No. 5 Recovery Boiler 4/30/2009 M5 0.0099 3 0 103.G

- 158 18

Recovery Furnace 7/21/2009 M5 0.0045 3 0 107.08

- P1 19

Recovery Boiler No. 3 8/18/2010 M5 0.0025 3 0 108.RB3 20

Recovery Boiler # 3 7/30/2008 M5 0.024 3 0 109.RB3 20

No. 4 Recovery Boiler 06/02/2004 M5 0.0287 3 0 different years 109.RB4 21

Recovery Boiler No. 4 8/12/2008 M5 0.018 3 0 different years 109.RB4 21

Recovery Furnace (low load) 12/17/2008 M5 0.0138 3 0 Separate conditions: RF (low load;

2 chambers) 114.U500 22

Recovery Furnace (high load) 12/18/2008 M5 0.0143 3 0 Separate conditions: RF (high load;

3 chambers) 114.U500 22

No. 3 Recovery Boiler (West stack) 9/9/2010 M5 0.0020 3 0 separate stacks 115.RE01 23

No. 3 Recovery Boiler (East stack) 9/9/2010 M5 0.0055 3 0 separate stacks 115.RE01 23

#14 Recovery Boiler 7/17/2007 M5 0.0131 3 0 117.B21 24

No. 21 Recovery Furnace 1/5/2010 M5 0.02844 3 0 different dates w/in same year 119.EQT010 25

No. 21 Recovery Boiler 11/30/2010 M5 0.017 3 0 different dates w/in same year 119.EQT010 25

Recovery Furnace 5 7/15/2010 M5 0.01 3 0 120.F7 26

Recovery Boiler (three ESP chamber in

Operation) 2/16/2011 M5 0.013 3 0 Separate conditions: Recovery

Boiler (three ESP chambers in

Operation) 135.003

- 1 27

Recovery Boiler (two ESP chambers in

Operation) 2/17/2011 M5 0.009 3 0 Separate conditions: Recovery

Boiler (two ESP chambers in

Operation) 135.003

- 1 27

Recovery Boiler #10 5/18/2010 M5 0.008 3 0 136.EU 005 28

No. 10 Recovery Furnace 9/2/2004 M5 0.0229 3 0 155.RECOVERY

FURNACE 29

### E

- 7 Description Test Date Test

Method Outlet Average Conc.

gr/dscf @ 8% O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

Recovery Furnace 22 2/16/2010 M5 0.0014 3 0 different dates w/in same year 156.RF22 30

Recovery Furnace 22 4/28/2010 M5 0.0013 3 0 different dates w/in same year 156.RF22 30

Recovery Furnace 22 9/14/2010 M5 0.0025 3 0 different dates w/in same year 156.RF22 30

Recovery Furnace 22 12/1/2010 M5 0.0003 3 0 different dates w/in same year 156.RF22 30

No. 1 Recovery Furnace 8/6/2008 M5 0.007 3 0 different dates w/in same year 162.381A 31

No. 1 Recovery Furnace 12/3/2008 M5 0.009 3 0 different dates w/in same year 162.381A 31

No. 2 Recovery Furnace 5/23/2007 M5 0.0083 3 0 162.382A 32

Recovery Boiler 8 & 10 ESP side B 6/8/2008 M5 0.0262 3 0 separate stacks and different years.

Flue gasses from B08 and B10

recovery furnaces combine and then

split off to the two 3 field ESPs,

C03 and C04. 164.B08,B10

combined 33

Recovery Boiler 8 & 10 ESP side A 6/8/2008 M5 0.0167 3 0 separate stacks and different years.

Flue gasses from B08 and B10

recovery furnaces combine and then

split off to the two 3 field ESPs,

C03 and C04. 164.B08,B10

combined 33

Recovery Boiler 8 & 10 ESP side B 11/10/2010 M5 0.0373 3 0 separate stacks and different years.

Flue gasses from B08 and B10

recovery furnaces combine and then

split off to the two 3 field ESPs,

C03 and C04. 164.B08,B10

combined 33

Recovery Boiler 8 & 10 ESP side A 11/10/2010 M5 0.0216 3 0 separate stacks and different years.

Flue gasses from B08 and B10

recovery furnaces combine and then

split off to the two 3 field ESPs,

C03 and C04. 164.B08,B10

combined 33

Recovery Boiler

- Old Stack 9/30/2004 M5 0.0134 3 0 Separate stacks 173.RECOVB 34

Recovery Boiler

- New Stack 9/30/2004 M5 0.00296 3 0 Separate stacks 173.RECOVB 34

No. 5 Recovery Furnace 10/20/2004 M5 0.0052 3 0 174.G

- 32 35

No. 3 Recovery Boiler 3/22/2010 M5 0.0166 3 0 175.RB3A 36

### E

- 8 Description Test Date Test

Method Outlet Average Conc.

gr/dscf @ 8% O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

No. 7 Recovery Boiler 7/27/2010 M5 0.0038 3 0 176.RB7 37

Recovery Boiler 3/24/2011 M5 0.0093 3 0 177.EU0804 38

No. 1 Recovery Furnace 09/07/2004 M5 0.013 3 0 different years 178.08P012 39

Recovery Furnace No. 1 6/21/2011 M5 0.017 3 0 different years 178.08P012 39

No. 2 Recovery Furnace 9/8/2004 M5 0.023 3 0 different years 178.08P013 40

Recovery Furnace No. 2 6/22/2011 M5 0.014 4 0 different years 178.08P013 40

No. 3 Recovery Furnace 6/2/2010 M5 0.009 3 0 179.RF3 41

No. 3 Recovery Furnace 3/24/2010 M5 0.005 3 0 180.D001 42

No. 4 Recovery Furnace 7/13/2009 M5 0.0042 3 0 186.RB15 43

No. 2 Recovery Furnace 10/1/2010 M5 0.007 3 0 190.R401 44

No. 3 Recovery Furnace

- North 9/21/2010 M5 0.006 3 0 separate stacks 190.R402 45

No. 3 Recovery Furnace

- South 9/21/2010 M5 0.005 3 0 separate stacks 190.R402 45

No. 2 Recovery Furnace 9/7/2004 M5 0.0073 3 0 different years 196.SN

- 06 46

No. 2 Recovery Furnace 4/20/2010 M5 0.0082 3 0 different years 196.SN

- 06 46

No. 3 Recovery Furnace 9/2/2004 M5 0.0051 3 0 196.SN

- 14 47

Recovery Furnace No. 2 3/31/2010 M5 0.001 3 0 200.007RF2 48

Recovery Boiler 10/26/2010 M5 0.0164 3 0 201.SR0001 49

Recovery Furnace EU320 7/20/2011 M5 0.0058 3 0 202.Recovery

Furnace EU320 50

#2 Recovery Furnace 8/25/2009 M5 0.0074 3 0 203.RF#2 51

Recovery Furnace #3 8/5/2009 M5 0.0017 3 0 203.RF#3 52

### E

- 9 Description Test Date Test

Method Outlet Average Conc.

gr/dscf @ 8% O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

No. 5 Recovery Furnace 5/25/2010 M5 0.004 3 0 240.RF01 53

No. 6 Recovery Furnace 7/27/2010 M5 0.0064 3 0 240.RF04 54

Recovery Furnace 9/15/2010 M5 0.0101 3 0 242.AA

- 011 55

#5 Recovery Boiler (R401)

- North 11/3/2009 M5 0.004 3 0 separate stacks 243.R401 56

#5 Recovery Boiler (R401)

- South 11/3/2009 M5 0.003 3 0 separate stacks 243.R401 56

#6 Recovery Boiler (R407) 10/27/2009 M5 0.016 3 0 243.R407 57

No. 15 Recovery Boiler 5/4/2011 M5 0.0098 3 0 531.RF15 58

No. 3 Recovery Furnace 6/8/2010 M5 0.008 3 0 600.G0806 59

Recovery Boiler 2

- Scenario 1 4/5/2011 M5 0.0162 4 0 Separate conditions 606.RB2 60

Recovery Boiler 2

- Scenario 2 4/5/2011 M5 0.0235 3 0 Separate conditions 606.RB2 60

Recovery Boiler 4 10/25/2010 M5 0.0258 3 0 606.RB4 61

Combined Recovery Boiler Stack

-

Condition 4: One ESP Side Down

Maximum Liquor Rec. Boiler 2, Oil Fire

Rec. Boiler 1 11/10/2008 M5 0.033 3 0 Combined stacks and separate

conditions 610.4, 5 62

Combined Recovery Boiler Stack

-

Condition 1: Max Liquor Rec. Boilers 1

& 2 11/11/2008 M5 0.011 3 0 Combined stacks and separate

conditions 610.4, 5 62

Combined Recovery Boiler Stack

-

Condition 2: 1 ESP Bank down,

Maximum Liquor Rec. Boilers 1 & 2

One ESP Side Down Max Liquor Rec.

Boiler 2, Oil Fire Rec. Boiler 1 11/12/2008 M5 0.013 3 0 Combined stacks and separate

conditions 610.4, 5 62

Combined Recovery Boiler Stack

-

Condition 3: 2 ESP Banks Down,

Controlled Liquor Firing Rec. Boilers 1

& 2 11/15/2008 M5 0.017 3 0 Combined stacks and separate

conditions 610.4, 5 62

Recovery Boiler (S20) 3/15/2011 M5 0.0054 3 0 617.B14 63

### E

- 10 

## Data Table for Figure A

- 5

. PM Emissions Test Data for N DCE Recovery Furnaces with DB ESPs and Multiple Emissions Tests

Description Test Date Test

Method Outlet Average Conc.

gr/dscf @ 8% O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

No. 3 Recovery Furnace

- North 4/30/2008 M5 0.0127 3 0 separate stacks 147.14 1

No. 3 Recovery Furnace

- South 4/30/2008 M5 0.0117 3 0 separate stacks 147.14 1

No. 4 Recovery Furnace 7/17/2008 M5 0.0108 3 0 different years 147.5 2

No. 4 Recovery Furnace

- Front Half 1/28/2009 M5 0.00967 3 0 different years 147.5 2

No. 2 Recovery Furnace

- East Stack 7/21/2004 M5 0.02 3 0 separate stacks 165.000006 3

No. 2 Recovery Furnace

- West Stack 7/21/2004 M5 0. 015 3 0 separate stacks 165.000006 3

No. 1 Recovery Furnace

- North Stack 7/24/2004 M5 0.023 3 0 separate stacks 165.000013 4

No. 1 Recovery Furnace

- South Stack 7/24/2004 M5 0.029 3 0 separate stacks 165.000013 4

#3 Recovery Boiler

- West Exhaust

Stack 4/22/2008 M5 0.013 3 0 separate stacks 207.038 5

#3 Recovery Boiler

- East Exhaust Stack 4/22/2008 M5 0.0137 3 0 separate stacks 207.038 5

Chemical Recovery Furnace

- West

Stack Front Half 2/23/2011 M5 0.0163 3 0 Separate stacks/separate methods:

Chemical Recovery Furnace

- West

Stack Front Half 615.24 6

Chemical Recovery Furnace

- East

Stack Front Half 2/23/2011 M5 0.0246 3 0 Separate stacks/separate methods:

Chemical Recovery Furnace

- East

Stack Front Half 615.24 6

Chemical Recovery Furnace

- West

Stack ODEQ 5 2/23/2011 ODEQ5 0.0198 3 0 Separate stacks/separate methods:

Chemical Recovery Furnace

- West

Stack ODEQ 5 615.24 6

Chemical Recovery Furnace

- East

Stack ODEQ 5 2/23/2011 ODEQ5 0.0282 3 0 Separate stacks/separate methods:

Chemical Recovery Furnace

- East

Stack ODEQ 5 615.24 6

Recovery Boiler No. 3 8/18/2010 M5 0.0025 3 0 108.RB3 7

Recovery Boiler # 3 7/30/2008 M5 0.024 3 0 109.RB3 7

No. 4 Recovery Boiler 06/02/2004 M5 0.0287 3 0 different years 109.RB4 8

Recovery Boiler No. 4 8/12/2008 M5 0.018 3 0 different years 109.RB4 8

Recovery Furnace (low load) 12/17/2008 M5 0.0138 3 0 Separate conditions: RF (low load; 2

chambers) 114.U500 9

Recovery Furnace (high load) 12/18/2008 M5 0.0143 3 0 Separate conditions: RF (high load;

3 chambers) 114.U500 9

No. 3 Recovery Boiler (West stack) 9/9/2010 M5 0.0020 3 0 separate stacks 115.RE01 10

No. 3 Recovery Boiler (East stack) 9/9/2010 M5 0.0055 3 0 separate stacks 115.RE01 10

No. 21 Recovery Furnace 1/5/2010 M5 0.02844 3 0 different dates w/in same year 119.EQT010 11

No. 21 Recovery Boiler 11/30/2010 M5 0.017 3 0 different dates w/in same year 119.EQT010 11

Recovery Boiler (three ESP chamber in

Operation) 2/16/2011 M5 0.013 3 0 Separate conditions: Recovery

Boiler (three ESP chambers in

Operation) 135.003

- 1 12

Recovery Boiler (two ESP chambers in

Operation) 2/17/2011 M5 0.009 3 0 Separate conditions: Recovery

Boiler (two ESP chambers in

Operation) 135.003

- 1 12

Recovery Furnace 22 2/16/2010 M5 0.0014 3 0 different dates w/in same year 156.RF22 13

### E

- 11 Description Test Date Test

Method Outlet Average Conc.

gr/dscf @ 8% O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

Recovery Furnace 22 4/28/2010 M5 0.0013 3 0 different dates w/in same year 156.RF22 13

Recovery Furnace 22 9/14/2010 M5 0.0025 3 0 different dates w/in same year 156.RF22 13

Recovery Furnace 22 12/1/2010 M5 0.0003 3 0 different dates w/in same year 156.RF22 13

No. 1 Recovery Furnace 8/6/2008 M5 0.007 3 0 different dates w/in same year 162.381A 14

No. 1 Recovery Furnace 12/3/2008 M5 0.009 3 0 different dates w/in same year 162.381A 14

Recovery Boiler 8 & 10 ESP side B 6/8/2008 M5 0.0262 3 0 separate stacks and different years.

Flue gasses from B08 and B10

recovery furnaces combine and then

split off to the two 3 field ESPs, C03

and C04. 164.B08,B10

combined 15

Recovery Boiler 8 & 10 ESP side A 6/8/2008 M5 0.0167 3 0 separate stacks and different years.

Flue gasses from B08 and B10

recovery furnaces combine and then

split off to the two 3 field ESPs, C03

and C04. 164.B08,B10

combined 15

Recovery Boiler 8 & 10 ESP side B 11/10/2010 M5 0.0373 3 0 separate stacks and different years.

Flue gasses from B08 and B10

recovery furnaces combine and then

split off to the two 3 field ESPs, C03

and C04. 164.B08,B10

combined 15

Recovery Boiler 8 & 10 ESP side A 11/10/2010 M5 0.0216 3 0 separate stacks and different years.

Flue gasses from B08 and B10

recovery furnaces combine and then

split off to the two 3 field ESPs, C03

and C04. 164.B08,B10

combined 15

Recovery Boiler

- Old Stack 9/30/2004 M5 0.0134 3 0 Separate stacks 173.RECOVB 16

Recovery Boiler

- New Stack 9/30/2004 M5 0.00296 3 0 Separate stacks 173.RECOVB 16

No. 1 Recovery Furnace 09/07/2004 M5 0.013 3 0 different years 178.08P012 17

Recovery Furnace No. 1 6/21/2011 M5 0.017 3 0 different years 178.08P012 17

No. 2 Recovery Furnace 9/8/2004 M5 0.023 3 0 different years 178.08P013 18

Recovery Furnace No. 2 6/22/2011 M5 0.014 4 0 different years 178.08P013 18

No. 3 Recovery Furnace

- North 9/21/2010 M5 0.006 3 0 separate stacks 190.R402 19

No. 3 Recovery Furnace

- South 9/21/2010 M5 0.005 3 0 separate stacks 190.R402 19

No. 2 Recovery Furnace 9/7/2004 M5 0.0073 3 0 different years 196.SN

- 06 20

No. 2 Recovery Furnace 4/20/2010 M5 0.0082 3 0 different years 196.SN

- 06 20

#5 Recovery Boiler (R401)

- North 11/3/2009 M5 0.004 3 0 separate stacks 243.R401 21

#5 Recovery Boiler (R401)

- South 11/3/2009 M5 0.003 3 0 separate stacks 243.R401 21

Recovery Boiler 2

- Scenario 1 4/5/2011 M5 0.0162 4 0 Separate conditions 606.RB2 22

Recovery Boiler 2

- Scenario 2 4/5/2011 M5 0.0235 3 0 Separate conditions 606.RB2 22

Combined Recovery Boiler Stack

-

Condition 4: One ESP Side Down

Maximum Liquor Rec. Boiler 2, Oil Fire

Rec. Boiler 1 11/10/2008 M5 0.033 3 0 Combined stacks and separate

conditions 610.4, 5 23

### E

- 12 Description Test Date Test

Method Outlet Average Conc.

gr/dscf @ 8% O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

Combined Recovery Boiler Stack

-

Condition 1: Max Liquor Rec. Boilers 1

& 2 11/11/2008 M5 0.011 3 0 Combined stacks and separate

conditions 610.4, 5 23

Combined Recovery Boiler Stack

-

Condition 2: 1 ESP Bank down,

Maximum Liquor Rec. Boilers 1 & 2

One ESP Side Down Max Liquor Rec.

Boiler 2, Oil Fire Rec. Boiler 1 11/12/2008 M5 0.013 3 0 Combined stacks and separate

conditions 610.4, 5 23

Combined Recovery Boiler Stack

-

Condition 3: 2 ESP Banks Down,

Controlled Liquor Firing Rec. Boilers 1

& 2 11/15/2008 M5 0.017 3 0 Combined stacks and separate

conditions 610.4, 5 23

### E

- 13 

## Figure A

- 6 Data Table

. PM Emissions Test Data for N DCE Recovery Furnaces with W BESPs

Description Test Date Test

Method Outlet Average Conc.

gr/dscf @ 8% O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

No. 2 Recovery Boiler 9/2/2010 M5 0.01 3 0 116.003 1

No. 1 Recovery Boiler 9/21/2010 M5 0.0072 3 0 169.04 2

No. 2 Recovery Boiler 9/22/2010 M5 0.0095 3 0 169.05 3

No. 4 Recovery Boiler

- South Stack 2/25/2009 M5 0.0294 3 0 Same emission unit as 181.9

(separate stacks) 181.10 4

No. 4 Recovery Boiler

- North Stack 2/25/2009 M5 0.0227 3 0 Same emission unit as 181.10

(separate stacks) 181.9 4

Recovery Furnace West Stack 1st Set 12/10/2009 M5 0.0245 3 0 Separate conditions: Recovery

Furnace West Stack 1st Set 126.RECOV 6

Recovery Furnace East Stack 1st Set 12/10/2009 M5 0.0132 3 0 Separate conditions: Recovery

Furnace East Stack 1st Set 126.RECOV 6

Recovery Furnace West Stack 2nd Set 12/10/2009 M5 0.0177 3 0 Separate stacks/conditions:

Recovery Furnace West Stack 2nd

Set. A second set of particulate tests

(3 one

- hour runs) was run on the

recovery furnace with the west side

inlet slide gates closed slightly to

balance flue gas flow between the

east and west sides. 126.RECOV 6

Recovery Furnace East Stack 2nd Set 12/10/2009 M5 0.0114 3 0 Separate stacks/conditions:

Recovery Furnace East Stack 2nd

Set. A second set of particulate tests

(3 one

- hour runs) was run on the

recovery furnace with the west side

inlet slide gates closed slightly to

balance flue gas flow between the

east and west sides. 126.RECOV 6

Recovery Boiler North 4/6/2011 M5 0.0065 3 0 separate stacks 127.REC1N 7

Recovery Boiler South 4/6/2011 M5 0.0121 3 0 separate stacks 127.REC1N 7

Recovery Boiler West Stack 10/9/2007 M5 0.038 3 0 Separate stacks 157.RB2 8

Recovery Boiler East Stack 10/9/2007 M5 0.048 3 0 Separate stacks 157.RB2 8

No. 2 Recovery Furnace

- North Duct 6/2/2011 M5 0.017 3 0 separate stacks 163.RF2904 9

No. 2 Recovery Furnace

- South Duct 6/2/2011 M5 0.016 3 0 separate stacks 163.RF2904 9

No. 1 Recovery Boiler 10/26/2010 M5 0.0192 3 0 172.RB01 10

No. 2 Recovery Boiler 10/25/2010 M5 0.016 3 0 172.RB02 11

No. 4 Recovery Furnace North Stack 10/25/2004 M5 0.0238 3 0 separate stacks 174.G

- 92 12

No. 4 Recovery Furnace

- South Stack 10/25/2004 M5 0.0206 3 0 separate stacks 174.G

- 92 12

8R Recovery Furnace 2/23/2011 M5 0.0067 3 0 189.SN26 13

#2 Recovery Furnace

- South Stack 11/30/2010 M5 0.0111 3 0 separate stacks 226.RECB1 14

#2 Recovery Furnace

- North Stack 11/30/2010 M5 0.003 3 0 separate stacks 226.RECB1 14

### E

- 14 

## Data Table for Figure A

- 7

. PM Emissions Test Data for N DCE Recovery Furnaces with Various Controls

Description Test Date Test Method Outlet Average

Conc.

, gr/dscf @

8% O 2 No.

Runs No.

Runs

BDL Duplicate

Emission Unit

Notes RTI+EUID Control Graph

order

Recovery Furnace 4 9/16/2010 M5 0.0117 3 0 137.189 DBESP

- WPR 1

Recovery Furnace 5 9/15/2010 M5 0.0037 3 0 137.721 DBESP

- WPR 2

Recovery Furnace

(filterable) 3/6/2009 M5 0.0125 3 0 138.002 DBESP

- WPR 3

Recovery Boiler 2 10/16/2008 M5 0.0040 3 0 146.16 DBESP

- WPR 4

No. 1 Recovery Furnace 9/28/2010 M5 0.0039 3 0 184.72 DBESP

- WPR 5

No. 2 Recovery Furnace 9/29/2010 M5 0.0036 3 0 184.73 DBESP

- WPR 6

#10 Recovery Boiler 1/6/2011 M5 0.0047 3 0 102.RB10 DBESP

- WPR 7

No. 4 Recovery Boiler 05/16/2007 EPA \ ODEQ

M5 0.0175 3 0 105.EU445C DBESP

- WPR 8

No. 4 Recovery Boiler 05/20/2008 EPA \ ODEQ

M5 0.0208 3 0 different dates

within same year 105.EU445C DBESP

- WPR 8

No. 4 Recovery Boiler 10/22/2008 EPA \ ODEQ

M5 0.0165 3 0 different dates

within same year 105.EU445C DBESP

- WPR 8

No. 4 Recovery Boiler 06/03/2009 EPA \ ODEQ

M5 0.0177 3 0 different dates

within same year 105.EU445C DBESP

- WPR 8

No. 4 Recovery Boiler 9/24/2009 EPA \ ODEQ

M5 0.0222 3 0 different dates

within same year 105.EU445C DBESP

- WPR 8

No. 4 Recovery Boiler 10/13/2010 M5 0.0112 3 0 105.EU445C DBESP

- WPR 8

Recovery Furnace 1/28/2011 M5 0.0033 3 0 111.G

- 44 DBESP

- WPR 9

Recovery Boiler 4 5/20/2010 M5 0.0061 3 0 132.4RB DBESP

- WPR 10

#5 Recovery Boiler North

Stack 5/18/2010 M5 0.0079 3 0 separate stacks 132.5RB DBESP

- WPR 11

#5 Recovery Boiler South

Stack 5/18/2010 M5 0.0031 3 0 separate stacks 132.5RB DBESP

- WPR 11

No. 4 Recovery Boiler 4/26/2011 M5 0.004 3 0 525.EU18 DBESP

- WPR 12

Recovery Furnace No. 3 4/7/2010 M5 0.021 3 0 200.007RF3 DB

- WBESP [2

- sided dry and

wet] 13

Recovery Boiler 6/7/2011 M5 0.032 3 0 159.F3 SCBR 15

Recovery furnace 8/18/2004 M5 0.076 3 0 139.02 DBESP

- WPR/DBESP/DBESP omit

Recovery furnace 9/9/2004 M5 0.015 3 0 139.02 DBESP

- WPR/DBESP/DBESP 16

### E

- 15 

## Data Table for Figure A

- 8

. PM Emissions Test Data for One Existing NDCE Recovery Furnace at

Mill 185 with DBESP

- Scrubber Control Tested 43 Times Between 2001 and 2009

Test date

(year.month) PM test result

gr/dscf @ 8% O 2 

## Test date

(year.month) PM test result

gr/dscf @ 8% O 2



## 2001.01 0.011 2009.01 0.0247

2001.02 0.014 2009.04 0.019

2001.03 0.016 2009.07 0.032

2001.04 0.014 2009.08 0.031

2001.05 0.015 2009.10 0.024

2001.06 0.026 2009.11 0.018

2001.07 0.01 2009.12 0.019

2001.08 0.012 Average 0.017

2001.09 0.009 Stdev 0.0057

2001.10 0.012 99th percentile 0.0300

2001.11 0.008 M edian 0.016

2001.12 0.012

2004.01 0.015

2004.02 0.016

2004.03 0.019

2004.04 0.018

2004.05 0.02

2004.08 0.024

2004.09 0.012

2004.12 0.012

2005.03 0.014

2005.06 0.013

2005.09 0.011

2005.12 0.019

2006.03 0.011

2006.06 0.011

2006.09 0.01

2006.12 0.011

2007.03 0.014

2007.05 0.019

2007.08 0.022

2007.11 0.022

2008.01 0.018

2008.05 0.017

2008.07 0.022

2008.10 0.02

### E

- 16 

## Data Table for Figure s B

- 2 , B

- 3, and B

- 4

. PM Emissions Test Data for Lime Kilns

Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

Lime Kiln G 6/17/2004 M5 0.009 3 0 100.115 ESP 1

Lime Kiln (No. 1 South

Stack) G 04/11/2008 M5 0.0006 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 2 North

Stack) G 04/11/2008 M5 0.001 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 1 South

Stack) G 07/07/2008 M5 0.0008 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 2 North

Stack) G 07/08/2008 M5 0.001 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 1 South

Stack) G 07/06/2009 M5 0.0007 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 2 North

Stack) G 07/06/2009 M5 0.0014 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 1 South

Stack) G 01/12/2010 M5 0.0035 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 2 North

Stack) G 01/12/2010 M5 0.0053 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 1 South

Stack) G 05/04/2010 M5 0.00056 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 2 North

Stack) G 05/04/2010 M5 0.0014 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 1 South

Stack) G 08/25/2010 M5 0.00055 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 2 North

Stack) G 08/25/2010 M5 0.0011 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 1 South

Stack) G 10/14/2010 M5 0.00091 3 0 Separate stacks 102.LK ESP 2

Lime Kiln (No. 1 South

Stack) G 10/14/2010 M5 0.0014 3 0 Separate stacks 102.LK ESP 2

#1 Lime Kiln

- South Stack G 1/4/2011 M5 0.0006 3 0 separate stacks 102.LK ESP 2

#1 Lime Kiln

- North Stack G 1/4/2011 M5 0.0008 3 0 separate stacks 102.LK ESP 2

No. 3 Lime Kiln G 05/15/2007 EPA \ ODEQ M5 0.0047 3 0 105.EU455 ESP 3

No. 3 Lime Kiln GC 05/22/2008 EPA \ ODEQ M5 0.021 3 0 different dates within

same year 105.EU455 ESP 3

No. 3 Lime Kiln G 10/21/2008 EPA \ ODEQ M5 0.0014 3 0 different dates within

same year 105.EU455 ESP 3

No. 3 Lime Kiln GC 06/02/2009 EPA \ ODEQ M5 0.0023 3 0 different dates within

same year 105.EU455 ESP 3

No. 3 Lime Kiln G 09/22/2009 EPA \ ODEQ M5 0.0024 3 0 different dates within

same year 105.EU455 ESP 3

Lime Kiln No.3 G 10/12/2010 M5 0.0106 3 0 105.EU455 ESP 3

### E

- 17 Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

Lime Kiln GC 10/11/2007 M5 0.0029 3 0 different years 107.11

- P14 ESP 4

Lime Kiln G 06/17/2008 M5 0.0046 3 0 different years 107.11

- P14 ESP 4

Lime Kiln GC 7/21/2010 M5 0.0025 3 0 107.11

- P14 ESP 4

No. 3 Lime Kiln GC 06/03/2004 M5 0.0066 3 0 different years 109.LK1 ESP 5

No. 3 Lime Kiln G 09/03/2008 M5 0.0049 3 0 different years 109.LK1 ESP 5

Lime Kiln

- Cond. I O 8/4/2009 M5 0.0119 3 0 Separate conditions:

Cond 1 = fuel oil 111.G

- 35 ESP 6

Lime Kiln

- Cond II G 8/6/2009 M5 0.0055 3 0 Separate conditions:

Cond 2 = gas 111.G

- 35 ESP 6

Lime Kiln O 12/13/2005 M5 0.0039 3 0 Separate conditions:

No. 6 fuel oil 114.U800 ESP 7

Lime Kiln G 12/14/2005 M5 0.0033 3 0 Separate conditions:

Natural Gas 114.U800 ESP 7

Lime Kiln G 12/16/2008 M5 0.0011 3 0 Separate conditions: gas 114.U800 ESP 7

Lime Kiln O 12/16/2008 M5 0.0018 3 0 Separate conditions: oil 114.U800 ESP 7

Lime Kiln No. 1 O 02/16/2005 M5 0.011 3 0 different years 127.LK1 ESP 8

Lime Kiln No. 1 O 04/25/2007 M5 0.0109 3 0 different years 127.LK1 ESP 8

Lime Kiln No. 1 O 04/28/2009 M5 0.0079 3 0 different years 127.LK1 ESP 8

Lime Kiln No. 1 O 4/4/2011 M5 0.0016 3 0 different years 127.LK1 ESP 8

Lime Kiln No. 2 O 02/16/2005 M5 0.0061 3 0 different years 127.LK2 ESP 9

Lime Kiln No. 2 O 04/24/2007 M5 0.0138 3 0 different years 127.LK2 ESP 9

Lime Kiln No. 2 O 04/29/2009 M5 0.013 3 0 different years 127.LK2 ESP 9

Lime Kiln No. 2 O 4/5/2011 M5 0.0033 3 0 different years 127.LK2 ESP 9

No. 4 Lime Kiln U 05/22/2001 M5 0.0368 unsp unsp different years 132.21LK4 ESP 10

No. 4 Lime Kiln U 05/21/2002 0.0135 3 0 different years 132.21LK4 ESP 10

No. 4 Lime Kiln U 05/19/2003 0.0033 3 0 different years 132.21LK4 ESP 10

No. 4 Lime Kiln U 05/24/2004 M5 0.0165 3 0 different years 132.21LK4 ESP 10

No. 4 Lime Kiln U 6/2/2005 M5 0.00495 3 0 different years 132.21LK4 ESP 10

No. 4 Lime Kiln O 6/15/2006 M5 0.00456 3 0 different years 132.21LK4 ESP 10

No. 4 Lime Kiln O 5/22/2007 M5 0.0013 3 0 different years 132.21LK4 ESP 10

No. 4 Lime Kiln O 6/19/2008 M5 0.0026 3 0 different years 132.21LK4 ESP 10

No. 4 Lime Kiln O 06/17/2009 M5 0.0143 3 0 different years 132.21LK4 ESP 10

Lime Kiln 4 O 7/27/2010 M5 0.0583 3 0 132.21LK4 ESP 10

Lime Kiln G 01/23/2001 M5 0.0168 3 0 different years 136.EU 033 ESP 11

Lime Kiln U 11/14/2002 M5 0.0258 3 0 different years 136.EU 033 ESP 11

Lime Kiln G 10/28/2004 M5 0.0194 3 0 different years 136.EU 033 ESP 11

Lime Kiln G 07/12/2006 M5 0.0239 3 0 different years 136.EU 033 ESP 11

Lime Kiln U 07/07/2008 M5 0.0296 3 0 different years 136.EU 033 ESP 11

Rotary Lime Kiln G 2/10/2010 M5 0.03 3 0 136.EU 033 ESP 11

No. 3 Lime Kiln G 8/12/2004 M5 0.0004 3 0 different years 137.511 ESP 12

No. 3 Lime Kiln G 6/15/2005 M5 0.0009 3 0 different years 137.511 ESP 12

No. 3 Lime Kiln G 05/14/2008 M5 0.0017 3 0 different years 137.511 ESP 12

### E

- 18 Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

No. 4 Lime Kiln U 07/18/2002 M5 0.00098 3 0 Separate conditions:

Tested ESP only (inlet

and outlet) 137.512 ESP 13

No. 4 Lime Kiln G 08/12/2004 M5 0.0004 3 0 Separate conditions

(tested ESP only);

different years 137.512 ESP 13

No. 4 Lime Kiln G 04/12/2005 M5 0.00105 6 0 Separate conditions

(tested ESP only);

different dates w/in

same year 137.512 ESP 13

No. 4 Lime Kiln G 07/15/2005 M5 0.0011 3 0 Separate conditions

(tested ESP only);

different dates w/in

same year 137.512 ESP 13

No. 4 Lime Kiln U 6/4/2004 M5 0.0044 3 0 143.6063 ESP 14

No. 7 Lime Kiln U 9/23/2010 M5 0.022 3 0 different dates w/in

same year 147.55 ESP 15

No. 7 Lime Kiln U 10/22/2010 M5 0.012 3 0 different dates w/in

same year 147.55 ESP 15

No. 2 Lime Kiln U 10/29/2007 M5 0.00647 3 0 different years 148.009 ESP 16

No. 2 Lime Kiln U 05/14/2008 M5 0.0061 3 0 different years 148.009 ESP 16

No. 2 Lime Kiln U 06/16/2009 M5 0.00588 3 0 different years 148.009 ESP 16

Lime Kiln G 10/30/2003 M5 0.0040 3 0 Separate condition:

only ESP tested.

different years 154.P30

- Lime

Kiln ESP 17

Lime Kiln No. 5

- North G 03/27/2009 M5 0.0003 2 0 Separate stacks 156.LK5 ESP 18

Lime Kiln No. 5

- South G 03/27/2009 M5 0.0001 2 0 Separate stacks 156.LK5 ESP 18

Lime Kiln No. 5

- North G 06/03/2009 M5 0.0014 2 0 Separate stacks 156.LK5 ESP 18

Lime Kiln No. 5

- South G 06/03/2009 M5 0.0011 2 0 Separate stacks 156.LK5 ESP 18

Lime Kiln No. 5

- North G 08/27/2009 M5 0.0317 2 0 Separate stacks 156.LK5 ESP 18

Lime Kiln No. 5

- South G 08/27/2009 M5 0.0039 2 0 Separate stacks 156.LK5 ESP 18

Lime Kiln No. 5

- North G 10/22/2009 M5 0.001 2 0 Separate stacks 156.LK5 ESP 18

Lime Kiln No. 5

- South G 10/22/2009 M5 0.0009 2 0 Separate stacks 156.LK5 ESP 18

Lime Kiln 5

- North Stack G 3/30/2010 M5 0.0019 2 0 separate stacks and

different dates w/in

same year 156.LK5 ESP 18

Lime Kiln 5

- South Stack G 3/30/2010 M5 0.0026 2 0 separate stacks and

different dates w/in

same year 156.LK5 ESP 18

Lime Kiln 5

- North Stack G 6/8/2010 M5 0.0014 2 0 separate stacks and

different dates w/in

same year 156.LK5 ESP 18

### E

- 19 Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

Lime Kiln 5

- South Stack G 6/8/2010 M5 0.0008 2 0 separate stacks and

different dates w/in

same year 156.LK5 ESP 18

Lime Kiln 5

- North Stack G 8/12/2010 M5 0.0019 2 0 separate stacks and

different dates w/in

same year 156.LK5 ESP 18

Lime Kiln 5

- South Stack G 8/12/2010 M5 0.0126 2 0 separate stacks and

different dates w/in

same year 156.LK5 ESP 18

Lime Kiln 5

- North Stack G 10/5/2010 M5 0.0032 2 0 separate stacks and

different dates w/in

same year 156.LK5 ESP 18

Lime Kiln 5

- South Stack G 10/5/2010 M5 0.0016 2 0 separate stacks and

different dates w/in

same year 156.LK5 ESP 18

No. 2 Lime Kiln O 08/03/2006 M5 0.0023 3 0 different years 162.372A ESP 19

No. 2 Lime Kiln O 8/5/2008 M5 0.011 3 0 different years 162.372A ESP 19

No. 3 Lime Kiln O 09/26/2001 M5 0.012 3 0 different years 179.LK3 ESP 20

No. 3 Lime Kiln G 10/12/2010 M5 0.0113 3 0 different years 179.LK3 ESP 20

No. 3 Lime Kiln U 09/01/2004 M5 0.0026 3 0 different years 196.SN

- 02 ESP 21

No. 3 Lime Kiln U 4/23/2010 M5 0.0052 3 0 different years 196.SN

- 02 ESP 21

No. 2 Lime Kiln GO 08/06/2004 M5 0.0056 3 0 different years 200.007_10 ESP 22

No. 2 Lime Kiln G 08/22/2006 M5 0.0049 3 0 different years 200.007_10 ESP 22

No. 2 Lime Kiln G 08/28/2006 M5 0.006 3 0 different years 200.007_10 ESP 22

No. 2 Lime Kiln G 3/30/2010 M5 0.002 3 0 200.007_10 ESP 22

No. 2 Lime Kiln U 05/01/2008 M5 0.011 3 0 different years 208228535.009 ESP 23

No. 2 Lime Kiln O 04/30/2009 M5 0.004 3 0 different years 208228535.009 ESP 23

"D" Lime Kiln U 09/23/2003 M5 0.011 2 0 different years 240.CA81 ESP 24

D Lime Kiln U 3/16/2010 M5 0.0014 3 0 different years 240.CA81 ESP 24

No. 7 Lime Kiln G 5/4/2011 M5 0.0023 3 0 531.LK7 ESP 25

No. 4 Lime Kiln G 05/30/2008 M5 0.0173 3 0 different years 606.LK4 ESP 26

No. 4 Lime Kiln O 04/21/2009 M5 0.0103 3 0 different years 606.LK4 ESP 26

No. 4 Lime Kiln O 04/23/2010 M5 0.0093 3 0 Separate conditions;

different years 606.LK4 ESP 26

No. 4 Lime Kiln O 04/24/2010 M5 0.009 3 0 Separate conditions;

different years 606.LK4 ESP 26

No. 4 Lime Kiln O 04/25/2010 M5 0.0082 3 0 Separate conditions;

different years 606.LK4 ESP 26

Lime Kiln 4 U 4/6/2011 M5 0.0074 3 0 606.LK4 ESP 26

Lime Kiln U 08/08/2006 M5 0.0046 3 0 different years 617.P22 ESP 27

Lime Kiln G 08/21/2007 M5 0.0061 3 0 different years 617.P22 ESP 27

Lime Kiln G 03/17/2010 M5 0.0032 3 0 different years 617.P22 ESP 27

S22 Lime Kiln U 3/17/2011 M5 0.0044 3 0 617.P22 ESP 27

### E

- 20 Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

No. 4 Lime Kiln G 07/18/2002 M5 0.00069 3 0 Separate conditions:

Tested with ESP/SCBR 137.512 ESP/PBSCBR 28

Lime Kiln 4 G 5/13/2008 M5 0.002 3 0 137.512 ESP/PBSCBR 28

Lime Kiln U 2/5/2004 M5 0.00378 3 0 126.LK ESP/SCBR 29

Lime Kiln U 12/11/2009 M5 0.0014 3 0 126.LK ESP/SCBR 29

No. 2 Lime Kiln U 02/18/2004 M5 0.0034 3 0 146.30 ESP/SCBR 30

No. 2 Lime Kiln U 10/15/2008 M5 0.0053 3 0 146.30 ESP/SCBR 30

Lime Kiln G 08/01/2007 M5 0.0015 3 0 different years 154.P30

- Lime

Kiln ESP/SCBR 31

Lime Kiln O 12/04/2008 M5 0.0009 3 0 different years 154.P30

- Lime

Kiln ESP/SCBR 31

Lime Kiln O 12/8/2010 M5 0.0004 3 0 154.P30

- Lime

Kiln ESP/SCBR 31

Lime Kiln G 8/25 /2009 M5 0.0004 3 0 different years 154.P30

- Lime

Kiln ESP/SCBR 31

No. 4 Lime Kiln O 10/27/2004 M5 0.0045 3 0 174.G

- 18 ESP/SCBR 32

Lime Kiln O 09/08/2004 M5 0.057 3 0 Separate conditions:

18.6 ton CaO/hr 178.09P037 ESP/SCBR 33

Lime Kiln

- low load O 09/09/2004 M5 0.006 3 0 Separate conditions: 2.9

ton CaO/hr 178.09P037 ESP/SCBR 33

Lime Kiln

- Retest GO 11/18/2004 M5 0.024 3 0 178.09P037 ESP/SCBR 33

Lime Kiln (Scrubber Outlet)

- Firing Oil O 5/26/2010 M5 0.005 3 0 Separate conditions: oil 178.09P037 ESP/SCBR 33

Lime Kiln (Scrubber Outlet)

- Firing Gas G 5/27/2010 M5 0.005 3 0 Separate conditions: gas 178.09P037 ESP/SCBR 33

No. 3 Lime Kiln GO 11/22/2005 M5 0.0132 3 0 different years 186.LK ESP/SCBR 34

No. 3 Lime Kiln GO 07/26/2006 M5 0.0235 3 0 different years 186.LK ESP/SCBR 34

No. 3 Lime Kiln GO 09/05/2007 M5 0.00986 3 0 different years 186.LK ESP/SCBR 34

Lime Kiln U 10/15/2008 M5 0.050 3 0 different years 186.LK ESP/SCBR 34

No. 3 Lime Kiln GO 7/14/2009 M5 0.0133 3 0 186.LK ESP/SCBR 34

Lime Kiln U 9/1/2010 M5 0.0072 3 0 242.AA

- 013 ESP/SCBR 35

No. 5 Lime Kiln O 11/01/2005 M5 0.007 3 0 different years 243.LG07 ESP/SCBR 36

No. 5 Lime Kiln G 10/30/2007 M5 0.002 3 0 different years 243.LG07 ESP/SCBR 36

No. 5 Lime Kiln

- Condition

I G 10/29/2009 M5 0.003 3 0 Separate conditions:

No. 5 Lime Kiln

-

Condition I

(SCBR/ESP) 243.LG07 ESP/SCBR 36

No. 5 Lime Kiln

- Condition

II G 10/29/2009 M5 0.026 * 3 0 Separate conditions:

No. 5 Lime Kiln

- Condition II (SCBR

only) 243.LG07 ESP/SCBR 36

No. 5 Lime Kiln O 8/28/2008 M5 0.0561 3 0 103.G

- 165 SCBR 37

### E

- 21 Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

Lime Kiln

- Performance

Engineering Test cond. I U 3/9/2004 M5 0.072 3 0 Separate conditions:

Performance

Engineering Test cond.

I (Scrubber P

- drop = 8

in. H2O) 108.LK1 SCBR 38

Lime Kiln

- Performance

Engineering Test cond. II U 3/10/2004 M5 0.045 3 0 Separate conditions:

Performance

Engineering Test cond.

II (Scrubber P

- drop =

9.2 in. H2O) 108.LK1 SCBR 38

Lime Kiln

- MACT II

Compliance Test U 6/19/2004 M5 0.028 6 0 different dates w/in

same year (MACT

compliance test) 108.LK1 SCBR 38

Lime Kiln GC 8/30/2010 M5 0.046 3 0 116.001 SCBR 39

Lime Kiln G 3/13/2001 M5 0.029 3 0 117.P36 SCBR 40

Lime Kiln U 4/3/2008 M5 0.293 3 0 119.EQT006 SCBR 41

Lime Kiln 1A G 7/21/2009 M5 0.013 3 0 120.M18 SCBR 42

Lime Kiln 2A G 7/20/2009 M5 0.041 3 0 120.M19 SCBR 43

Lime Kiln U 1 0/31/2002 M5 0.015 3 0 different years 121.000011 SCBR 44

Lime Kiln U 8/24/2004 M5 0.017 3 0 different years 121.000011 SCBR 44

Lime Kiln GC 11/2/2010 M5 0.0247 3 0 124.004

- 1 SCBR 45

No. 1 Lime Kiln U 06/24/2011 M5 0.033 3 0 130.4 SCBR 46

No. 2 Lime Kiln U 06/24/2011 M5 0.0318 3 0 130.5 SCBR 47

No. 2 Lime Kiln O 12/11/2003 M5 0.09 3 0 Tested on 2 different

days; report did not

specify why (unclear of

separate conditions) 131.16 SCBR 48

No. 2 Lime Kiln O 12/12/2003 M5 0.093 3 0 Tested on 2 different

days; report did not

specify why (unclear of

separate conditions) 131.16 SCBR 48

Lime Kiln 1 O 1/19/2004 M5 0.03 3 0 different dates w/in

same year 131.18 SCBR 49

Lime Kiln 1 O 1/20/2004 M5 0.032 3 0 different dates w/in

same year 131.18 SCBR 49

Lime Kiln 1 O 3/9/2004 M5 0.074 3 0 different dates w/in

same year 131.18 SCBR 49

Lime Kiln 1 O 3/10/2004 M5 0.087 3 0 different dates w/in

same year 131.18 SCBR 49

Lime Kiln O 7/13/2004 M5 0.034 3 0 Separate conditions 135.004

- 1 SCBR 50

Lime Kiln O 7/14/2004 M5 0.037 3 0 Separate conditions 135.004

- 1 SCBR 50

Lime Kiln (SN

- 01) GC 5/23/2007 M5 0.0264 3 0 138.001 SCBR 51

Lime Kiln U 9/9/2004 M5 0.06 3 0 139.04 SCBR 52

Lime Kiln G 10/22/2009 M5 0.0207 3 0 different years 140.32 SCBR 53

### E

- 22 Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

Lime Kiln U 5/16 /2011 Oregon M5 0.024 3 0 different years 140.32 SCBR 53

LIME KILN #2 U 7/14/2003 M5 0.051 3 0 142.P6009 SCBR 54

LIME KILN #1 U 7/30/2003 M5 0.035 3 0 142.P6025 SCBR 55

Lime Kiln

- filterable U 10/23/2002 M5 0.038 3 0 145.001 SCBR 56

No. 1 Lime Kiln U 4/20/2009 M5 0.03 3 0 146.6 SCBR 57

No. 1 Lime Kiln U 6/15/2010 M5 0.0413 3 0 147.3 SCBR 58

No.1 Lime Kiln U 5/25/2010 M5 0.03 4 0 148.003 SCBR 59

Rotary Lime Kiln U 4/2/2009 M5 0.0293 3 0 149.P001 SCBR 60

Lime Kiln G 10/13/2009 M5 0.024 3 0 150.CAU

- 12 SCBR 61

lime kiln U 3/8/2007 mod. M5 (Texas

ACB Procedure

- cyclonic flow) 0.062 3 0 152.08 SCBR 62

Lime Kiln U 2/18/2004 M5 0.0615 3 0 155.LIME

KILN SCBR 63

Lime Kiln 3 G 1/28/2010 M5 0.0137 3 0 different dates w/in

same year 156.143100 SCBR 64

Lime Kiln 3 G 2/9/2010 M5 0.0149 3 0 different dates w/in

same year 156.143100 SCBR 64

Lime Kiln 3 G 11/24/2010 M5 0.0212 3 0 different dates w/in

same year 156.143100 SCBR 64

Lime Kiln 4 G 2/18/2010 M5 0.0183 3 0 different dates w/in

same year 156.145000 SCBR 65

Lime Kiln 4 G 4/22/2010 M5 0.0098 3 0 different dates w/in

same year 156.145000 SCBR 65

Lime Kiln 4 G 9/3/2010 M5 0.0093 3 0 different dates w/in

same year 156.145000 SCBR 65

Lime Kiln 4 G 12/15/2010 M5 0.0134 3 0 different dates w/in

same year 156.145000 SCBR 65

Lime Kiln O 07/18/2007 M5 0.046 3 0 157.KILN SCBR 66

Lime Kiln U 12/3/2010 M5 0.0385 3 0 159.F4 SCBR 67

No. 1 Lime Kiln O 5/20/2009 M5 0.06 3 0 162.371A SCBR 68

No. 1 Lime Kiln G 6/9/2011 M5 0.059 3 0 163.LK1501 SCBR 69

No. 2 Lime Kiln GC 6/8/2011 M5 0.053 3 0 163.LK2502 SCBR 70

Lime Kiln

- Front Half only O 8/17/2010 M5 0.0902 3 0 164.P12 SCBR 71

No. 2 Lime Kiln (LK02) U 7/26/2004 M5 0.028 3 0 165.000002 SCBR 72

No. 1 Lime Kiln (LK01) U 7/23/2004 M5 0.052 3 0 165.000019 SCBR 73

No. 1 Lime Kiln O 7/24/2009 M5 0.1338 3 0 166.LK01 SCBR 74

No. 2 Lime Kiln O 7/23/2009 M5 0.0323 3 0 166.LK02 SCBR 75

Lime Kiln G 1/20 /2011 M5 0.102 3 0 167.004LK SCBR 76

No. 1 Lime Kiln U 7/7/2009 M5 0.0322 3 0 different dates 171.009 SCBR 77

No. 1 Lime Kiln G 7/20/2005 M5 0.0194 3 0 different dates 171.009 SCBR 77

No. 3 Lime Kiln G 10/20/2009 M5 0.034 3 0 Separate conditions: gas 172.LK03 SCBR 78

No. 3 Lime Kiln O 10/21/2009 M5 0.028 3 0 Separate conditions: oil 172.LK03 SCBR 78

### E

- 23 Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

lime kiln O 9/29/2004 M5 0.0533 3 0 173.LK1 SCBR 79

No. 3 Lime Kiln U 6/3/2003 M5 0.055 3 0 174.G

- 95 SCBR 80

No. 1 Lime Kiln

- Shutdown G 2/4/2010 M5 0.0172 3 0 Separate conditions:

No. 1 Lime Kiln

-

Shutdown 175.LK1A SCBR 81

No. 1 Lime Kiln

- Startup G 2/4/2010 M5 0.0145 3 0 Separate conditions:

No. 1 Lime Kiln

- Startup 175.LK1A SCBR 81

No. 1 Lime Kiln G 8/9/2010 M5 0.0109 3 0 different dates w/in

same year (No. 1 Lime

Kiln) 175.LK1A SCBR 81

No. 2 Lime Kiln

- Shutdown G 1/12/2010 M5 0.0383 3 0 Separate conditions:

No. 2 Lime Kiln

-

Shutdown 175.LK2A SCBR 82

No. 2 Lime Kiln

- Startup G 1/14/2010 M5 0.0154 3 0 Separate conditions:

No. 2 Lime Kiln

- Startup 175.LK2A SCBR 82

Lime Kiln GO 9/15/2010 M5 0.064 3 0 176.G

- 5 SCBR 83

Lime Kiln U 3/31/2011 M5 0.0281 3 0 177.EU0905 SCBR 84

No. 1 Lime Kiln O 3/24/2010 M5 0.0673 3 0 180.L001 SCBR 85

No. 2 Lime Kiln O 3/25/2010 M5 0.0585 3 0 180.L002 SCBR 86

No. 1 Lime Kiln U 3/12/2009 M5 0.022 3 0 181.1 SCBR 87

No. 2 Lime Kiln

- W/O

NCGs U 2/10/2009 M5 0.018 3 0 Separate conditions:

Without NCGs 181.14 SCBR 88

No. 2 Lime Kiln

- W/ NCGs U 2/11/2009 M5 0.051 3 0 Separate conditions:

With NCGs 181.14 SCBR 88

No. 1 Lime Kiln

- High CaO

Production GC 3/4/2010 M5 0.0175 3 0 Separate conditions:

No. 1 Lime Kiln

- High

CaO Production 184.LK1 SCBR 89

No. 1 Lime Kiln

- Low CaO

Production GC 3/4/2010 M5 0.0186 3 0 Separate conditions:

No. 1 Lime Kiln

- Low

CaO Production 184.LK1 SCBR 89

No. 2 Lime Kiln

- Condition

I G 10/22/2004 M5 0.0045 3 0 Separate conditions:

No. 2 Lime Kiln

- Condition I (gas) 184.LK2 SCBR 90

No. 4 Lime Kiln G 1/23/2009 M5 0.0172 3 0 different dates w/in

same year 185.07 SCBR 91

No. 4 Lime Kiln G 4/15/2009 M5 0.0217 3 0 different dates w/in

same year 185.07 SCBR 91

No. 4 Lime Kiln G 7/23/2009 M5 0.0105 3 0 different dates w/in

same year 185.07 SCBR 91

No. 4 Lime Kiln G 10/7/2009 M5 0.01055 3 0 different dates w/in

same year 185.07 SCBR 91

### E

- 24 Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

No. 4 Lime Kiln GO 3/22/2011 M5 0.0679 3 0 different dates w/in

same year 189.SN25 SCBR 92

No. 4 Lime Kiln GO 4/1/2011 M5 0.0164 3 0 different dates w/in

same year 189.SN25 SCBR 92

Lime Kiln No. 1 U 2/23/2011 M5 0.037 3 0 190.L600 SCBR 93

Lime Kiln No. 2 U 9/24/2010 M5 0.016 3 0 190.L601 SCBR 94

Lime Kiln U 11/15/2010 M5 0.017 3 0 195.002 SCBR 95

#2 Lime Kiln U 9/12/200 4 M5 0.0538 4 0 196.SN

- 09 SCBR 96

Lime Kiln G 9/16/2008 M5 0.0428 3 0 197.1 SCBR 97

Lime Kiln U 9/9/2005 M5 0.0525 3 0 198.004 SCBR 98

No. 3 Lime Kiln U 7/7/2011 M5 0.0179 3 0 199.011 SCBR 99

Lime Kiln GC 5/8/2007 M5 0.0664 3 0 201.SR0003 SCBR 100

Lime Kiln G 7/21/2011 M5 0.034 3 0 202.Lime Kiln

EU340 SCBR 101

Lime Kiln G 2/8/2011 M5 0.034 3 0 different dates w/in

same year 203.LKScr SCBR 102

Lime Kiln G 3/22/2011 M5 0.029 3 0 different dates w/in

same year 203.LKScr SCBR 102

Lime Kiln G 4/5/2011 M5 0.033 3 0 different dates w/in

same year 203.LKScr SCBR 102

Lime Kiln G 4/22/2011 M5 0.029 3 0 different dates w/in

same year 203.LKScr SCBR 102

Lime Kiln U 1/26/2011 M5 0.03 3 0 205.008 SCBR 103

Lime Kiln #5 U 11/13/2007 M5 0.0334 3 0 206.G

- 38 SCBR 104

Lime Kiln

- Normal

Condition G 6/7/2011 M5 0.058 3 0 Separate conditions:

Lime Kiln

- Normal

Condition 207.103A SCBR 105

Lime Kiln

- Condition I G 6/7/2011 M5 0.058 3 0 Separate conditions:

Lime Kiln

- Condition I

(scrubber p

- drop =18 in

H2O, recirc = 400 gpm) 207.103A SCBR 105

Lime Kiln

- Condition II G 6/8/2011 M5 0.067 3 0 Separate conditions:

Lime Kiln

- Condition

II (scrubber p

- drop =20

in H2O, recirc = 300

gpm) 207.103A SCBR 105

Lime Kiln

- Condition III G 6/8/2011 M5 0.082 3 0 Separate conditions:

Lime Kiln

- Condition

III (scrubber p

- drop =18

in H2O, recirc = 295

gpm) 207.103A SCBR 105

Lime Kiln #1 U 8/10/2004 M5 0.0378 3 0 226.LK1 SCBR 106

Lime Kiln #2 U 1/16/2004 M5 0.0065 3 0 226.LK2 SCBR 107

Lime kiln U 6/23/2005 M5 0.0856 3 0 340.008 SCBR 108

### E

- 25 Description Fuel

Type

Code Test Date Test Method Outlet Average

Conc.

, gr/dscf

@ 10% O 2 No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Control Graph

order

No. 4 Lime Kiln O 4/27/2011 M5 0.0241 3 0 525.EU17 SCBR 109

No. 1 Lime Kiln G 11/3/2010 M5 0.091 3 0 600.G0903 SCBR 110

No. 2 Lime Kiln G 6/9/2010 M5 0.0476 3 0 different years 600.G0905 SCBR 111

No. 2 Lime Kiln G 6/16/2011 M5 0.0344 3 0 different years 600.G0905 SCBR 111

No. 3 Lime Kiln G 11/14/2010 M5 0.014 3 0 600.G0908 SCBR 112

A Lime Kiln O 6/18/2009 M5 0.075 3 0 Separate conditions 610.7 SCBR 113

A Lime Kiln O 6/18/2009 M5 0.089 3 0 Separate conditions 610.7 SCBR 113

A Lime Kiln O 6/22/2009 M5 0.077 3 0 Separate conditions 610.7 SCBR 113

A Lime Kiln O 6/15/2010 M5 0.073 3 0 Separate conditions 610.7 SCBR 113

A Lime Kiln O 6/16/2010 M5 0.073 3 0 Separate conditions 610.7 SCBR 113

B Lime Kiln O 6/17/2009 M5 0.066 3 0 Separate conditions 610.8 SCBR 114

B Lime Kiln O 6/17/2009 M5 0.062 3 0 Separate conditions 610.8 SCBR 114

B Lime Kiln O 6/19/2009 M5 0.062 3 0 Separate conditions 610.8 SCBR 114

Lime Kiln G 12/3/2009 M5 0.0288 3 0 Separate conditions 613.009 SCBR 115

Lime Kiln GC 12/4/2009 M5 0.0317 3 0 Separate conditions 613.009 SCBR 115

Lime Kiln

- Front Half G 10/22/2009 M5 0.0223 3 0 Separate methods: Lime

Kiln

- Front Half 615.21 SCBR 116

Lime Kiln

- ODEQ 5 G 10/22/2009 M5 0.0248 3 0 Separate methods: Lime

Kiln

- ODEQ 5 615.21 SCBR 116



### unsp = unspecified

*Only the scrubber in the ESP/scrubber system was tested.



### Fuel type codes :

G = natural gas

O = fuel oil (no. 2 or no. 6) and/or waste oil

GC = natural gas and pet coke

GO = gas and fuel oil

U = unspecified

### E

- 26 

## Data Table for Figure B

- 5

. PM Emissions Test Data for ESP

- Controlled Lime Kilns Firing Gas or Oil

Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf

@ 10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

Lime Kiln G 6/17/2004 M5 0.009 3 0 100.115 1

Lime Kiln (No. 1 South Stack) G 04/11/2008 M5 0.0006 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 2 North Stack) G 04/11/2008 M5 0.001 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 1 South Stack) G 07/07/2008 M5 0.0008 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 2 North Stack) G 07/08/2008 M5 0.001 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 1 South Stack) G 07/06/2009 M5 0.0007 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 2 North Stack) G 07/06/2009 M5 0.0014 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 1 South Stack) G 01/12/2010 M5 0.0035 3 0 Separate stack s 102.LK 2

Lime Kiln (No. 2 North Stack) G 01/12/2010 M5 0.0053 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 1 South Stack) G 05/04/2010 M5 0.00056 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 2 North Stack) G 05/04/2010 M5 0.0014 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 1 South Stack) G 08/25/2010 M5 0.00055 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 2 North Stack) G 08/25/2010 M5 0.0011 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 1 South Stack) G 10/14/2010 M5 0.00091 3 0 Separate stacks 102.LK 2

Lime Kiln (No. 1 South Stack) G 10/14/2010 M5 0.0014 3 0 Separate stacks 102.LK 2

#1 Lime Kiln

- South Stack G 1/4/2011 M5 0.0006 3 0 separate stacks 102.LK 2

#1 Lime Kiln

- North Stack G 1/4/2011 M5 0.0008 3 0 separate stacks 102.LK 2

No. 3 Lime Kiln G 05/15/2007 EPA \ ODEQ

M5 0.0047 3 0 105.EU455 3

No. 3 Lime Kiln G 10/21/2008 EPA \ ODEQ

M5 0.0014 3 0 different dates within same year 105.EU455 3

No. 3 Lime Kiln G 09/22/2009 EPA \ ODEQ

M5 0.0024 3 0 different dates within same year 105.EU455 3

Lime Kiln No.3 G 10/12/2010 M5 0.0106 3 0 105.EU455 3

Lime Kiln G 06/17/2008 M5 0.0046 3 0 different years 107.11

- P14 4

No. 3 Lime Kiln G 09/03/2008 M5 0.0049 3 0 different years 109.LK1 5

Lime Kiln

- Cond II G 8/6/2009 M5 0.0055 3 0 Separate conditions: Cond 2 = gas 111.G

- 35 6

Lime Kiln G 12/14/2005 M5 0.0033 3 0 Separate conditions: Natural Gas 114.U800 7

Lime Kiln G 12/16/2008 M5 0.0011 3 0 Separate conditions: gas 114.U800 7

Lime Kiln G 01/23/2001 M5 0.017 3 0 different years 136.EU 033 8

Lime Kiln G 10/28/2004 M5 0.019 3 0 different years 136.EU 033 8

Lime Kiln G 07/12/2006 M5 0.024 3 0 different years 136.EU 033 8

Rotary Lime Kiln G 2/10/2010 M5 0.03 3 0 136.EU 033 8

No. 3 Lime Kiln G 8/12/2004 M5 0.0004 3 0 different years 137.511 9

No. 3 Lime Kiln G 6/15/2005 M5 0.0009 3 0 different years 137.511 9

No. 3 Lime Kiln G 05/14/2008 M5 0.0017 3 0 different years 137.511 9

No. 4 Lime Kiln G 08/12/2004 M5 0.0004 3 0 Separate conditions (tested ESP

only); different years 137.512 10

No. 4 Lime Kiln G 04/12/2005 M5 0.00105 6 0 Separate conditions (tested ESP

only); different dates w/in same

year 137.512 10

### E

- 27 Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf

@ 10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

No. 4 Lime Kiln G 07/15/2005 M5 0.0011 3 0 Separate conditions (tested ESP

only); different dates w/in same

year 137.512 10

Lime Kiln G 10/30/2003 M5 0.0040 3 0 Separate condition: only ESP

tested. different years 154.P30

- Lime

Kiln 11

Lime Kiln No. 5

- North G 03/27/2009 M5 0.0003 2 0 Separate stacks 156.LK5 12

Lime Kiln No. 5

- South G 03/27/2009 M5 0.0001 2 0 Separate stacks 156.LK5 12

Lime Kiln No. 5

- North G 06/03/2009 M5 0.0014 2 0 Separate stacks 156.LK5 12

Lime Kiln No. 5

- South G 06/03/2009 M5 0.0011 2 0 Separate stacks 156.LK5 12

Lime Kiln No. 5

- North G 08/27/2009 M5 0.0317 2 0 Separate stacks 156.LK5 12

Lime Kiln No. 5

- South G 08/27/2009 M5 0.0039 2 0 Separate stacks 156.LK5 12

Lime Kiln No. 5

- North G 10/22/2009 M5 0.001 2 0 Separate stacks 156.LK5 12

Lime Kiln No. 5

- South G 10/22/2009 M5 0.0009 2 0 Separate stacks 156.LK5 12

Lime Kiln 5

- North Stack G 3/30/2010 M5 0.0019 2 0 separate stacks and different dates

w/in same year 156.LK5 12

Lime Kiln 5

- South Stack G 3/30/2010 M5 0.0026 2 0 separate stacks and different dates

w/in same year 156.LK5 12

Lime Kiln 5

- North Stack G 6/8/2010 M5 0.0014 2 0 separate stacks and different dates

w/in same year 156.LK5 12

Lime Kiln 5

- South Stack G 6/8/2010 M5 0.0008 2 0 separate stacks and different dates

w/in same year 156.LK5 12

Lime Kiln 5

- North Stack G 8/12/2010 M5 0.0019 2 0 separate stacks and different dates

w/in same year 156.LK5 12

Lime Kiln 5

- South Stack G 8/12/2010 M5 0.0126 2 0 separate stacks and different dates

w/in same year 156.LK5 12

Lime Kiln 5

- North Stack G 10/5/2010 M5 0.0032 2 0 separate stacks and different dates

w/in same year 156.LK5 12

Lime Kiln 5

- South Stack G 10/5/2010 M5 0.0016 2 0 separate stacks and different dates

w/in same year 156.LK5 12

No. 3 Lime Kiln G 10/12/2010 M5 0.0113 3 0 different years 179.LK3 13

No. 2 Lime Kiln G 08/22/2006 M5 0.0049 3 0 different years 200.007_10 14

No. 2 Lime Kiln G 08/28/2006 M5 0.006 3 0 different years 200.007_10 14

No. 2 Lime Kiln G 3/30/2010 M5 0.002 3 0 200.007_10 14

No. 7 Lime Kiln G 5/4/2011 M5 0.0023 3 0 531.LK7 15

No. 4 Lime Kiln G 05/30/2008 M5 0.0173 3 0 different years 606.LK4 16

Lime Kiln G 08/21/2007 M5 0.0061 3 0 different years 617.P22 17

Lime Kiln G 03/17/2010 M5 0.0032 3 0 different years 617.P22 17

Lime Kiln

- Cond. I O 8/4/2009 M5 0.0119 3 0 Separate conditions: Cond 1 = fuel

oil 111.G

- 35 18

Lime Kiln O 12/13/2005 M5 0.0039 3 0 Separate conditions: No. 6 fuel oil 114.U800 19

Lime Kiln O 12/16/2008 M5 0.0018 3 0 Separate conditions: oil 114.U800 19

Lime Kiln No. 1 O 02/16/2005 M5 0.011 3 0 different years 127.LK1 20

Lime Kiln No. 1 O 04/25/2007 M5 0.0109 3 0 different years 127.LK1 20

### E

- 28 Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf

@ 10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

Lime Kiln No. 1 O 04/28/2009 M5 0.0079 3 0 different years 127.LK1 20

Lime Kiln No. 1 O 4/4/2011 M5 0.0016 3 0 different years 127.LK1 20

Lime Kiln No. 2 O 02/16/2005 M5 0.0061 3 0 different years 127.LK2 21

Lime Kiln No. 2 O 04/24/2007 M5 0.0138 3 0 different years 127.LK2 21

Lime Kiln No. 2 O 04/29/2009 M5 0.013 3 0 different years 127.LK2 21

Lime Kiln No. 2 O 4/5/2011 M5 0.0033 3 0 different years 127.LK2 21

No. 4 Lime Kiln O 6/15/2006 M5 0.0046 3 0 different years 132.21LK4 22

No. 4 Lime Kiln O 5/22/2007 M5 0.0013 3 0 different years 132.21LK4 22

No. 4 Lime Kiln O 6/19/2008 M5 0.0026 3 0 different years 132.21LK4 22

No. 4 Lime Kiln O 06/17/2009 M5 0.0143 3 0 different years 132.21LK4 22

Lime Kiln 4 O 7/27/2010 M5 0.0583 3 0 132.21LK4 22

No. 2 Lime Kiln O 08/03/2006 M5 0.0023 3 0 different years 162.372A 23

No. 2 Lime Kiln O 8/5/2008 M5 0.011 3 0 different years 162.372A 23

No. 3 Lime Kiln O 09/26/2001 M5 0.012 3 0 different years 179.LK3 24

No. 2 Lime Kiln O 04/30/2009 M5 0.004 3 0 different years 208228535.009 25

No. 4 Lime Kiln O 04/21/2009 M5 0.0103 3 0 different years 606.LK4 26

No. 4 Lime Kiln O 04/23/2010 M5 0.0093 3 0 Separate conditions; different years 606.LK4 26

No. 4 Lime Kiln O 04/24/2010 M5 0.009 3 0 Separate conditions; different years 606.LK4 26

No. 4 Lime Kiln O 04/25/2010 M5 0.0082 3 0 Separate conditions; different years 606.LK4 26

No. 2 Lime Kiln GO 08/06/2004 M5 0.0056 3 0 different years 200.007_10 27

### E

- 29 

## Data Table for Figure B

- 6

. PM Emissions Test Data for ESP

- Controlled Lime Kilns Firing Gas/Coke or Unspecified Fuel

Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf

@ 10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

No. 3 Lime Kiln GC 05/22/2008 EPA \ ODEQ

M5 0.021 3 0 different dates within same year 105.EU455 1

No. 3 Lime Kiln GC 06/02/2009 EPA \ ODEQ

M5 0.0023 3 0 different dates within same year 105.EU455 1

Lime Kiln GC 10/11/2007 M5 0.0029 3 0 different years 107.11

- P14 2

Lime Kiln GC 7/21/2010 M5 0.0025 3 0 107.11

- P14 2

No. 3 Lime Kiln GC 06/03/2004 M5 0.0066 3 0 different years 109.LK1 3

No. 4 Lime Kiln U 05/22/2001 M5 0.0368 unsp unsp different years 132.21LK4 4

No. 4 Lime Kiln U 05/21/2002 0.0135 3 0 different years 132.21LK4 4

No. 4 Lime Kiln U 05/19/2003 0.0033 3 0 different years 132.21LK4 4

No. 4 Lime Kiln U 05/24/2004 M5 0.0165 3 0 different years 132.21LK4 4

No. 4 Lime Kiln U 6/2/2005 M5 0.0050 3 0 different years 132.21LK4 4

Lime Kiln U 11/14/2002 M5 0.0258 3 0 different years 136.EU 033 5

Lime Kiln U 07/07/2008 M5 0.030 3 0 different years 136.EU 033 5

No. 4 Lime Kiln U 07/18/2002 M5 0.00098 3 0 Separate conditions: Tested ESP

only (inlet and outlet) 137.512 6

No. 4 Lime Kiln U 6/4/2004 M5 0.0044 3 0 143.6063 7

No. 7 Lime Kiln U 9/23/2010 M5 0.022 3 0 different dates w/in same year 147.55 8

No. 7 Lime Kiln U 10/22/2010 M5 0.012 3 0 different dates w/in same year 147.55 8

No. 2 Lime Kiln U 10/29/2007 M5 0.00647 3 0 different years 148.009 9

No. 2 Lime Kiln U 05/14/2008 M5 0.0061 3 0 different years 148.009 9

No. 2 Lime Kiln U 06/16/2009 M5 0.00588 3 0 different years 148.009 9

No. 3 Lime Kiln U 09/01/2004 M5 0.0026 3 0 different years 196.SN

- 02 10

No. 3 Lime Kiln U 4/23/2010 M5 0.0052 3 0 different years 196.SN

- 02 10

No. 2 Lime Kiln U 05/01/2008 M5 0.011 3 0 different years 208228535.009 11

"D" Lime Kiln U 09/23/2003 M5 0.011 2 0 different years 240.CA81 12

D Lime Kiln U 3/16/2010 M5 0.0014 3 0 different years 240.CA81 12

Lime Kiln 4 U 4/6/2011 M5 0.0074 3 0 606.LK4 13

Lime Kiln U 08/08/2006 M5 0.0046 3 0 different years 617.P22 14

S22 Lime Kiln U 3/17/2011 M5 0.0044 3 0 617.P22 14



### unsp = unspecified

### E

- 30 

## Data Table for Figure B

- 7

. PM Emissions Test Data for Lime Kilns w ith Combined ESP/Scrubber Control

Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf @

10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit

Notes RTI+EUID Graph

order

Lime Kiln 4 G 5/13/2008 M5 0.002 3 0 137.512 1

Lime Kiln G 08/01/2007 M5 0.0015 3 0 different years 154.P30

- Lime Kiln 2

Lime Kiln G 8/25 /2009 M5 0.0004 3 0 different years 154.P30

- Lime Kiln 2

Lime Kiln (Scrubber Outlet)

- Firing Gas G 5/27/2010 M5 0.005 3 0 Separate conditions: gas 178.09P037 3

No. 5 Lime Kiln G 10/30/2007 M5 0.002 3 0 different years 243.LG07 4

No. 5 Lime Kiln

- Condition I G 10/29/2009 M5 0.003 3 0 Separate conditions: No. 5

Lime Kiln

- Condition I

(SCBR/ESP) 243.LG07 4

No. 5 Lime Kiln

- Condition II G 10/29/2009 M5 0.026 * 3 0 Separate conditions: No. 5

Lime Kiln

- Condition II

(SCBR only) 243.LG07 4

Lime Kiln O 12/04/2008 M5 0.0009 3 0 different years 154.P30

- Lime Kiln 5

Lime Kiln O 12/8/2010 M5 0.0004 3 0 154.P30

- Lime Kiln 5

No. 4 Lime Kiln O 10/27/2004 M5 0.0045 3 0 174.G

- 18 6

Lime Kiln O 09/08/2004 M5 0.057 3 0 Separate conditions: 18.6 ton

CaO/hr 178.09P037 7

Lime Kiln

- low load O 09/09/2004 M5 0.006 3 0 Separate conditions: 2.9 ton

CaO/hr 178.09P037 7

Lime Kiln (Scrubber Outlet)

- Firing Oil O 5/26/2010 M5 0.005 3 0 Separate conditions: oil 178.09P037 7

No. 5 Lime Kiln O 11/01/2005 M5 0.007 3 0 different years 243.LG07 8

Lime Kiln

- Retest GO 11/18/2004 M5 0.024 3 0 178.09P037 9

No. 3 Lime Kiln GO 11/22/2005 M5 0.0132 3 0 different years 186.LK 10

No. 3 Lime Kiln GO 07/26/2006 M5 0.0235 3 0 different years 186.LK 10

No. 3 Lime Kiln GO 09/05/2007 M5 0.00986 3 0 different years 186.LK 10

No. 3 Lime Kiln GO 7/14/2009 M5 0.0133 3 0 186.LK 10

Lime Kiln U 2/5/2004 M5 0.003779835 3 0 126.LK 11

Lime Kiln U 12/11/2009 M5 0.0014 3 0 126.LK 11

No. 2 Lime Kiln U 02/18/2004 M5 0.0034 3 0 146.30 12

No. 2 Lime Kiln U 10/15/2008 M5 0.0053 3 0 146.30 12

Lime Kiln U 10/15/2008 M5 0.050 3 0 different years 186.LK 13

Lime Kiln U 9/1/2010 M5 0.0072 3 0 242.AA

- 013 14



### Note that the same kiln may be represented on multiple vertical lines in Figure B

- 7 (e.g., separate vertical lines for different fuels)

. *Only the scrubber in the ESP/scrubber system was tested.

### E

- 31 

## Data Table for Figure B

- 8

. PM Emissions Test Data for Scrubber

- Controlled Lime Kilns Firing Gas and Oil

Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf @

10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit

Notes RTI+EUID Graph

order

Lime Kiln G 3/13/2001 M5 0.0294 3 0 117.P36 1

Lime Kiln 1A G 7/21/2009 M5 0.013 3 0 120.M18 2

Lime Kiln 2A G 7/20/2009 M5 0.041 3 0 120.M19 3

Lime Kiln G 10/22/2009 M5 0.0207 3 0 different years 140.32 4

Lime Kiln G 10/13/2009 M5 0.024 3 0 150.CAU

- 12 5

Lime Kiln 3 G 1/28/2010 M5 0.0137 3 0 different dates w/in same year 156.143100 6

Lime Kiln 3 G 2/9/2010 M5 0.0149 3 0 different dates w/in same year 156.143100 6

Lime Kiln 3 G 11/24/2010 M5 0.0212 3 0 different dates w/in same year 156.143100 6

Lime Kiln 4 G 2/18/2010 M5 0.0183 3 0 different dates w/in same year 156.145000 6

Lime Kiln 4 G 4/22/2010 M5 0.0098 3 0 different dates w/in same year 156.145000 6

Lime Kiln 4 G 9/3/2010 M5 0.0093 3 0 different dates w/in same year 156.145000 6

Lime Kiln 4 G 12/15/2010 M5 0.0134 3 0 different dates w/in same year 156.145000 6

No. 1 Lime Kiln G 6/9/2011 M5 0.059 3 0 163.LK1501 7

Lime Kiln G 1/20 /2011 M5 0.102 3 0 167.004LK 8

No. 1 Lime Kiln G 7/20/2005 M5 0.0194 3 0 different dates 171.009 9

No. 3 Lime Kiln G 10/20/2009 M5 0.034 3 0 Separate conditions: gas 172.LK03 10

No. 1 Lime Kiln

- Shutdown G 2/4/2010 M5 0.0172 3 0 Separate conditions: No. 1

Lime Kiln

- Shutdown 175.LK1A 11

No. 1 Lime Kiln

- Startup G 2/4/2010 M5 0.0145 3 0 Separate conditions: No. 1

Lime Kiln

- Startup 175.LK1A 11

No. 1 Lime Kiln G 8/9/2010 M5 0.0109 3 0 different dates w/in same year

(No. 1 Lime Kiln) 175.LK1A 11

No. 2 Lime Kiln

- Shutdown G 1/12/2010 M5 0.0383 3 0 Separate conditions: No. 2

Lime Kiln

- Shutdown 175.LK2A 12

No. 2 Lime Kiln

- Startup G 1/14/2010 M5 0.0154 3 0 Separate conditions: No. 2

Lime Kiln

- Startup 175.LK2A 12

No. 2 Lime Kiln

- Condition I G 10/22/2004 M5 0.0045 3 0 Separate conditions: No. 2

Lime Kiln

- Condition I (gas) 184.LK2 13

No. 4 Lime Kiln G 1/23/2009 M5 0.0172 3 0 different dates w/in same year 185.07 14

No. 4 Lime Kiln G 4/15/2009 M5 0.0217 3 0 different dates w/in same year 185.07 14

No. 4 Lime Kiln G 7/23/2009 M5 0.0105 3 0 different dates w/in same year 185.07 14

No. 4 Lime Kiln G 10/7/2009 M5 0.0106 3 0 different dates w/in same year 185.07 14

Lime Kiln G 9/16/2008 M5 0.0428 3 0 197.1 15

Lime Kiln G 7/21/2011 M5 0.034 3 0 202.Lime Kiln

EU340 16

Lime Kiln G 2/8/2011 M5 0.034 3 0 different dates w/in same year 203.LKScr 17

Lime Kiln G 3/22/2011 M5 0.029 3 0 different dates w/in same year 203.LKScr 17

Lime Kiln G 4/5/2011 M5 0.033 3 0 different dates w/in same year 203.LKScr 17

Lime Kiln G 4/22/2011 M5 0.029 3 0 different dates w/in same year 203.LKScr 17

Lime Kiln

- Normal Condition G 6/7/2011 M5 0.058 3 0 Separate conditions: Lime

Kiln

- Normal Condition 207.103A 18

### E

- 32 Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf @

10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit

Notes RTI+EUID Graph

order

Lime Kiln

- Condition I G 6/7/2011 M5 0.058 3 0 Separate conditions: Lime

Kiln

- Condition I (scrubber p

drop =18 in H2O, recirc = 400

gpm) 207.103A 18

Lime Kiln

- Condition II G 6/8/2011 M5 0.067 3 0 Separate conditions: Lime

Kiln

- Condition II (scrubber

p

- drop =20 in H2O, recirc =

300 gpm) 207.103A 18

Lime Kiln

- Condition III G 6/8/2011 M5 0.082 3 0 Separate conditions: Lime

Kiln

- Condition III (scrubber

p

- drop =18 in H2O, recirc =

295 gpm) 207.103A 18

No. 1 Lime Kiln G 11/3/2010 M5 0.091 3 0 600.G0903 19

No. 2 Lime Kiln G 6/9/2010 M5 0.0476 3 0 different years 600.G0905 20

No. 2 Lime Kiln G 6/16/2011 M5 0.0344 3 0 different years 600.G0905 20

No. 3 Lime Kiln G 11/14/2010 M5 0.014 3 0 600.G0908 21

Lime Kiln G 12/3/2009 M5 0.0288 3 0 Separate conditions 613.009 22

Lime Kiln

- Front Half G 10/22/2009 M5 0.0223 3 0 Separate methods: Lime Kiln

- Front Half 615.21 23

Lime Kiln

- ODEQ 5 G 10/22/2009 M5 0.0248 3 0 Separate methods: Lime Kiln

- ODEQ 5 615.21 23

No. 5 Lime Kiln O 8/28/2008 M5 0.0561 3 0 103.G

- 165 24

No. 2 Lime Kiln O 12/11/2003 M5 0.09 3 0 Tested on 2 different days;

report did not specify why

(unclear of separate

conditions) 131.16 25

No. 2 Lime Kiln O 12/12/2003 M5 0.093 3 0 Tested on 2 different days;

report did not specify why

(unclear of separate

conditions) 131.16 25

Lime Kiln 1 O 1/19/2004 M5 0.03 3 0 different dates w/in same year 131.18 26

Lime Kiln 1 O 1/20/2004 M5 0.032 3 0 different dates w/in same year 131.18 26

Lime Kiln 1 O 3/9/2004 M5 0.074 3 0 different dates w/in same year 131.18 26

Lime Kiln 1 O 3/10/2004 M5 0.087 3 0 different dates w/in same year 131.18 26

Lime Kiln O 7/13/2004 M5 0.034 3 0 Separate conditions 135.004

- 1 27

Lime Kiln O 7/14/2004 M5 0.037 3 0 Separate conditions 135.004

- 1 27

Lime Kiln O 07/18/2007 M5 0.046 3 0 157.KILN 28

No. 1 Lime Kiln O 5/20/2009 M5 0.06 3 0 162.371A 29

Lime Kiln

- Front Half only O 8/17/2010 M5 0.0902 3 0 164.P12 30

No. 1 Lime Kiln O 7/24/2009 M5 0.1338 3 0 166.LK01 31

No. 2 Lime Kiln O 7/23/2009 M5 0.0323 3 0 166.LK02 32

No. 3 Lime Kiln O 10/21/2009 M5 0.028 3 0 Separate conditions: oil 172.LK03 33

lime kiln O 9/29/2004 M5 0.0533 3 0 173.LK1 34

No. 1 Lime Kiln O 3/24/2010 M5 0.0673 3 0 180.L001 35

### E

- 33 Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf @

10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit

Notes RTI+EUID Graph

order

No. 2 Lime Kiln O 3/25/2010 M5 0.0585 3 0 180.L002 36

No. 4 Lime Kiln O 4/27/2011 M5 0.0241 3 0 525.EU17 37

A Lime Kiln O 6/18/2009 M5 0.075 3 0 Separate conditions 610.7 38

A Lime Kiln O 6/18/2009 M5 0.089 3 0 Separate conditions 610.7 38

A Lime Kiln O 6/22/2009 M5 0.077 3 0 Separate conditions 610.7 38

A Lime Kiln O 6/15/2010 M5 0.073 3 0 Separate conditions 610.7 38

A Lime Kiln O 6/16/2010 M5 0.073 3 0 Separate conditions 610.7 38

B Lime Kiln O 6/17/2009 M5 0.066 3 0 Separate conditions 610.8 39

B Lime Kiln O 6/17/2009 M5 0.062 3 0 Separate conditions 610.8 39

B Lime Kiln O 6/19/2009 M5 0.062 3 0 Separate conditions 610.8 39

Lime Kiln GO 9/15/2010 M5 0.064 3 0 176.G

- 5 40

No. 4 Lime Kiln GO 3/22/2011 M5 0.0679 3 0 different dates w/in same year 189.SN25 41

No. 4 Lime Kiln GO 4/1/2011 M5 0.0164 3 0 different dates w/in same year 189.SN25 41

### E

- 34 

## Data Table for Figure B

- 9

. PM Emissions Test Data for Scrubber

- Controlled Lime Kilns Firing Gas/Coke or Unspecified Fuel

Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf

@ 10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

Lime Kiln GC 8/30/2010 M5 0.046 3 0 116.001 1

Lime Kiln GC 11/2/2010 M5 0.0247 3 0 124.004

- 1 2

Lime Kiln (SN

- 01) GC 5/23/2007 M5 0.0264 3 0 138.001 3

No. 2 Lime Kiln GC 6/8/2011 M5 0.053 3 0 163.LK2502 4

No. 1 Lime Kiln

- High CaO

Production GC 3/4/2010 M5 0.0175 3 0 Separate conditions: No. 1 Lime

Kiln

- High CaO Production 184.LK1 5

No. 1 Lime Kiln

- Low CaO

Production GC 3/4/2010 M5 0.0186 3 0 Separate conditions: No. 1 Lime

Kiln

- Low CaO Production 184.LK1 5

Lime Kiln GC 5/8/2007 M5 0.0664 3 0 201.SR0003 6

Lime Kiln GC 12/4/2009 M5 0.0317 3 0 Separate conditions 613.009 7

Lime Kiln

- Performance

Engineering Test cond. I U 3/9/2004 M5 0.072 3 0 Separate conditions:

Performance Engineering Test

cond. I (Scrubber P

- drop = 8 in.

H2O) 108.LK1 8

Lime Kiln

- Performance

Engineering Test cond. II U 3/10/2004 M5 0.045 3 0 Separate conditions:

Performance Engineering Test

cond. II (Scrubber P

- drop = 9.2

in. H2O) 108.LK1 8

Lime Kiln

- MACT II

Compliance Test U 6/19/2004 M5 0.028 6 0 different dates w/in same year

(MACT compliance test) 108.LK1 8

Lime Kiln U 4/3/2008 M5 0.293 3 0 119.EQT006 9

Lime Kiln U 10/31/2002 M5 0.015 3 0 different years 121.000011 10

Lime Kiln U 8/24/2004 M5 0.017 3 0 different years 121.000011 10

Lime Kiln U 9/9/2004 M5 0.06 3 0 139.04 11

Lime Kiln U 5/16 /2011 Oregon M5 0.024 3 0 different years 140.32 12

LIME KILN #2 U 7/14/2003 M5 0.051 3 0 142.P6009 13

LIME KILN #1 U 7/30/2003 M5 0.035 3 0 142.P6025 14

Lime Kiln

- filterable U 10/23/2002 M5 0.038 3 0 145.001 15

No. 1 Lime Kiln U 4/20/2009 M5 0.03 3 0 146.6 16

No. 1 Lime Kiln U 6/15/2010 M5 0.0413 3 0 147.3 17

No.1 Lime Kiln U 5/25/2010 M5 0.03 4 0 148.003 18

Rotary Lime Kiln U 4/2/2009 M5 0.0293 3 0 149.P001 19

lime kiln U 3/8/2007 mod. M5

(Texas

ACB

Procedure

-

cyclonic

flow) 0.062 3 0 152.08 20

Lime Kiln U 2/18/2004 M5 0.0615 3 0 155.LIME KILN 21

Lime Kiln U 12/3/2010 M5 0.0385 3 0 159.F4 22

No. 2 Lime Kiln (LK02) U 7/26/2004 M5 0.028 3 0 165.000002 23

No. 1 Lime Kiln (LK01) U 7/23/2004 M5 0.052 3 0 165.000019 24

### E

- 35 Description Fuel

Type

Code Test Date Test

Method Outlet Average

Conc.

, gr/dscf

@ 10 % O 2 No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Graph

order

No. 3 Lime Kiln U 6/3/2003 M5 0.055 3 0 174.G

- 95 25

Lime Kiln U 3/31/2011 M5 0.0281 3 0 177.EU0905 26

No. 1 Lime Kiln U 3/12/2009 M5 0.022 3 0 181.1 27

No. 2 Lime Kiln

- W/O NCGs U 2/10/2009 M5 0.018 3 0 Separate conditions: Without

NCGs 181.14 28

No. 2 Lime Kiln

- W/ NCGs U 2/11/2009 M5 0.051 3 0 Separate conditions: With NCGs 181.14 28

Lime Kiln No. 1 U 2/23/2011 M5 0.037 3 0 190.L600 29

Lime Kiln No. 2 U 9/24/2010 M5 0.016 3 0 190.L601 30

Lime Kiln U 11/15/2010 M5 0.017 3 0 195.002 31

#2 Lime Kiln U 9/12/200 4 M5 0.0538 4 0 196.SN

- 09 32

Lime Kiln U 9/9/2005 M5 0.0525 3 0 198.004 33

No. 3 Lime Kiln U 7/7/2011 M5 0.0179 3 0 199.011 34

Lime Kiln U 1/26/2011 M5 0.03 3 0 205.008 35

Lime Kiln #5 U 11/13/2007 M5 0.0334 3 0 206.G

- 38 36

Lime Kiln #1 U 8/10/2004 M5 0.0378 3 0 226.LK1 37

Lime Kiln #2 U 1/16/2004 M5 0.0065 3 0 226.LK2 38

Lime kiln U 6/23/2005 M5 0.0856 3 0 340.008 39

No. 1 Lime Kiln U 06/24/2011 M5 0.033 3 0 130.4 40

No. 2 Lime Kiln U 06/24/2011 M5 0.0318 3 0 130.5 41

No. 1 Lime Kiln U 7/7/2009 M5 0.0322 3 0 different dates 171.009 42

### E

- 36 

## Data Table for Figures C

- 1 and C

- 2

. PM Emissions Test Data for Smelt Dissolving Tanks

Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Outlet PM,

lb/ton BLS 1 ,2 Control 3 Graph

order

(Fig

C

- 1) Graph

order

(Fig

C

- 2)

No. 2 RB SDT 10/26/2005 M5 3 0 145.56 0.6360 OTH 1

Smelt Dissolving Tank 08/23/2005 M5 4 0 157.SDT 0.1480 OTH 2

No. 2 Smelt Dissolving

Tank 07/08/2009 M5 3 0 171.006 0.2600 OTH 3

No. 10 Smelt

Dissolving Tank 01/25/2005 M5 3 0 different dates 206.G

- 35 0.1912 OTH 4

No. 10 Smelt

Dissolving Tank 11/17/2005 M5 3 0 different dates 206.G

- 35 unspecified OTH

No. 11 Smelt

Dissolving Tank 01/26/2005 M5 4 0 different dates 206.G

- 36 0.2697 OTH 5

No. 11 Smelt

Dissolving Tank 11/20/2005 M5 3 0 different dates 206.G

- 36 unspecified OTH

Smelt Dissolving Tank 9/23/2010 M5 3 0 138.003 0.0786 PBSCBR 6

Smelt Dissolving Tank 10/06/2010 M5 3 0 Different dates and methods (M5) 140.57 0.0730 PBSCBR 7

Smelt Dissolving Tank 03/31/2011 ODEQ M5 3 0 Different dates and methods

(ORDEQ5) 140.57 0.0790 PBSCBR 8

Smelt Dissolving Tank 3/3/2011 M5 5 0 155.SDT 0.0890 PBSCBR 9

SDT 18 3/17/2010 M5 3 0 different dates within same year 156.SMEL18 0.0889 PBSCBR 10 1

SDT 18 8/4/2010 M5 3 0 different dates within same year 156.SMEL18 0.0901 PBSCBR 10 1

SDT 19 4/6/2010 M5 3 0 different dates within same year 156.SMEL19 0.0572 PBSCBR 11 2

SDT 19 10/27/2010 M5 3 0 different dates within same year 156.SMEL19 0.0954 PBSCBR 11 2

SDT 22 2/11/2010 M5 3 0 different dates within same year 156.SMEL22 0.0501 PBSCBR 12 3

SDT 22 9/10/2010 M5 3 0 different dates within same year 156.SMEL22 0.0483 PBSCBR 12 3

SDT 22 11/18/2010 M5 3 0 different dates within same year 156.SMEL22 0.0564 PBSCBR 12 3

Smelt Dissolving Tank

No. 1 9/21/2010 M5 3 0 169.06 0.1251 PBSCBR 13

Smelt Dissolving Tank

No. 2 9/21/2010 M5 3 0 169.07 0.1651 PBSCBR 14

No. 4 Smelt Dissolver 1/2/2009 M5 3 0 different dates within same year 185.05 0.0567 PBSCBR 15 4

No. 4 Smelt Dissolver 2/4/2009 M5 3 0 different dates within same year 185.05 0.0653 PBSCBR 15 4

No. 4 Smelt Dissolver 3/11/2009 M5 3 0 different dates within same year 185.05 0.0883 PBSCBR 15 4

No. 4 Smelt Dissolver 6/3/2009 M5 3 0 different dates within same year 185.05 0.0773 PBSCBR 15 4

No. 4 Smelt Dissolver 8/26/2009 M5 3 0 different dates within same year 185.05 0.0820 PBSCBR 15 4

No. 4 Smelt Dissolver 11/12/2009 M5 3 0 different dates within same year 185.05 0.0493 PBSCBR 15 4

Smelt Tank 9/24/2003 M5 3 0 207.108 0.0900 PBSCBR 16

S21 SDT 3/16/2011 M5 3 0 617.P21 0.0473 PBSCBR 17

Smelt Dissolving Tank 8/9/2001 M5 3 0 100.109 0.0533 SCBR 18

Smelt Dissolver Tank

Vent 1/5/2011 M5 3 0 102.SDTV10 0.0388 SCBR 19

Smelt dissolving tanks,

#3 East Vent 2/20 /2008 ODEQ M5 3 0 Separate stacks 105.EU445BEast SCBR

### E

- 37 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Outlet PM,

lb/ton BLS 1 ,2 Control 3 Graph

order

(Fig

C

- 1) Graph

order

(Fig

C

- 2)

Smelt dissolving tanks,

#3 West Vent 2/20 /2008 ODEQ M5 3 0 Separate stacks 105.EU445BWest 0.1481 SCBR 20

No. 4 Smelt Dissolving

Tank 05/16/2007 EPA \ ODEQ

M5 3 0 105.EU445D 0.1089 SCBR 21 5

No. 4 Smelt Dissolving

Tank 05/20/2008 EPA \ ODEQ

M5 3 0 different dates within same year 105.EU445D 0.1304 SCBR 21 5

No. 4 Smelt Dissolving

Tank 10/22/2008 EPA \ ODEQ

M5 3 0 different dates within same year 105.EU445D 0. 1147 SCBR 21 5

No. 4 Smelt Dissolving

Tank 06/03/2009 EPA \ ODEQ

M5 3 0 different dates within same year 105.EU445D 0.1126 SCBR 21 5

No. 4 Smelt Dissolving

Tank 09/23/2009 EPA \ ODEQ

M5 3 0 different dates within same year 105.EU445D 0.1065 SCBR 21 5

#4 Smelt Dissolving

Tank 10/13/2010 M5 3 0 105.EU445D 0.1114 SCBR 21 5

Smelt Dissolving

Tanks 6/9/2011 M5 3 0 107.09

- P2 0.1380 SCBR 22

No. 3 Smelt Dissolver 5/12/2006 M5 3 0 different years 109.SDT3 0.0840 SCBR 23 6

Smelt Dissolving Tank

# 3 7/31/2008 M5 3 0 different years 109.SDT3 0.0790 SCBR 23 6

No. 4 Smelt Dissolver 8/13/2008 M5 3 0 109.SDT4 0.0580 SCBR 24

South Smelt Tank 1/29/2011 M5 3 0 111.G

- 127 0.0863 SCBR 25

Smelt Dissolving Tank 3/18/2009 M5 3 0 112.AA

- 101 0.1108 SCBR 26

Smelt Dissolving Tank 12/18/2008 M5 3 0 114.U508 0.1300 SCBR 27

SDT West 9/9/2010 M5 3 0 separate stacks 115.SM01 SCBR

SDT East 9/9/2010 M5 3 0 separate stacks 115.SM01 0.07392 SCBR 28

Smelt Dissolving Tank

Vent 7/20/2004 M5 3 0 different years 116.004 0.0763 SCBR 29 7

Smelt Dissovling Tank

Vent 9/2/2010 M5 3 0 different years 116.004 0.0930 SCBR 29 7

No. 20 SDT 1/3/2007 M5 3 0 119.EQT005 unspecified SCBR

No. 21 SDT 3/21/2007 M5 3 0 119.EQT011 unspecified SCBR

#5 SDT 7/22/2009 M5 3 0 120.M3 0.0500 SCBR 30

No. 1 Smelt Dissolving

Tank 10/29 /2002 M5 3 0 different years 121.000009 0.0641 SCBR 31 8

No. 1 Smelt Dissolving

Tank 8/2 0 /2004 M5 3 0 different years 121.000009 0.1103 SCBR 31 8

No. 2 Smelt Dissolving

Tank 10/30 /2002 M5 3 0 different years 121.000010 0.0965 SCBR 32 9

No. 2 Smelt Dissolving

Tank 8/18 /2004 M5 3 0 different years 121.000010 0.0641 SCBR 32 9

No. 1 Smelt Dissolver 11/3/2010 M5 3 0 124.020 0.0951 SCBR 33

No. 2 Smelt Dissolver 11/4/2010 M5 3 0 124.021 0.0929 SCBR 34

SDT 12/10/2009 M5 3 0 126.SDT 0.1619 SCBR 35

### E

- 38 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Outlet PM,

lb/ton BLS 1 ,2 Control 3 Graph

order

(Fig

C

- 1) Graph

order

(Fig

C

- 2)

SDT Vent 2/15/2005 M5 3 0 127.SDT1 0.0547 SCBR 36

No. 3 Smelt Dissolving

Tank 06/21/2011 M5 4 0 130.11 0.1494 SCBR 37

No. 1 Smelt Dissolving

Tank 06/23/2011 M5 3 0 130.6 0.1505 SCBR 38

No. 2 Smelt Dissolving

Tank 06/22/2011 M5 3 0 130.7 0.2380 SCBR 39

SDT 4N 3/8/2004 M5 3 0 131.SDT4N SCBR

SDT 4S 3/8/2004 M5 3 0 131.SDT4S 0.0944 SCBR 40

SDT 5 12/9/2003 M5 4 0 131.SDT5 0.0604 SCBR 41

4 SDT 5/20/2010 M5 3 0 132.4SDT 0.0328 SCBR 42 10

SDTV No. 4 6/15/2009 M5 3 0 132.4SDT 0.0444 SCBR 42 10

5 SDT 5/18/2010 M5 3 0 132.5SDT 0.1370 SCBR 43

Smelt Dissolving Tank 02/16/2011 M5 3 0 Combined stacks given 135.007

- 1, 007

- 2 0.0400 SCBR 44

SDT 5/19/2010 M5 3 0 136.EU 031 0.1000 SCBR 45

No. 4 Recovery Smelt

Dissolver 08/31/2010 M5 2 0 137.157 0.0370 SCBR 46 11

No. 4 Recovery Smelt

Dissolver 09/16/2010 M5 3 0 appears to be retest 137.157 0.0317 SCBR 46 11

No. 5 SDT 9/15/2010 M5 3 0 137.204 0.1000 SCBR 47

Smelt Dissolving Tank 09/10/2004 M5 3 0 139.03 0.1600 SCBR 48

No. 3 Smelt Dissolving

Tank Vent 06/30/2003 M5 3 0 142.P7236 0.1550 SCBR 49

No. 1 and No. 2 SDTs 7/22/2004 M5 3 0 142.P7413 0.1080 SCBR 50

No. 1 Smelt Dissolving

Tank 11/05/2009 M5 3 0 143.7005 0.0356 SCBR 51

No. 2 Smelt Dissolving

Tank 11/05/2009 M5 3 0 143.7015 0.0400 SCBR 52

No. 3 Smelt Dissolving

Tank 11/04/2009 M5 3 0 143.7025 0.0300 SCBR 53

No. 1 SDT (upriver

vent) 10/16/2008 M5 3 0 separate stacks 146.10 SCBR

No. 1 SDT (downriver

vent) 10/16/2008 M5 3 0 separate stacks 146.10 0.0601 SCBR 54

No. 2 SDT 10/16/2008 M5 3 0 146.17 0.0575 SCBR 55

No. 1 SDT 7/21/2010 M5 3 0 148.002 0.0909 SCBR 56

No. 2 SDT 7/20/2010 M5 4 0 148.008 0.1481 SCBR 57

No. 9 SDT 4/3/2009 M5 3 0 149.P005 0.1024 SCBR 58

### E

- 39 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Outlet PM,

lb/ton BLS 1 ,2 Control 3 Graph

order

(Fig

C

- 1) Graph

order

(Fig

C

- 2)

Smelt Tank West 8/29/2007 M5 3 0 Separate stacks: The smelt

dissolving tank emission unit id

CREC

- 2 has two identical stacks

(CREC

- 2a and CREC

- 2b) and each

stack has an identical scrubber

(SCRBSTa and SCRBSTb). 150.CREC

- 2a SCBR

Smelt Tank East 8/29/2007 M5 3 0 Separate stacks: The smelt

dissolving tank emission unit id

CREC

- 2 has two identical stacks

(CREC

- 2a and CREC

- 2b) and each

stack has an identical scrubber

(SCRBSTa and SCRBSTb). 150.CREC

- 2b 0.096 SCBR 59

Smelt Dissolving Tank 03/07/2007 M5 3 0 152.04 0.2243 SCBR 60

No. 1 Smelt Dissolving

Tank 03/09/2004 M5 3 0 different dates within same year 154.P32

- Smelt

Dissolving Tank 1 0.1000 SCBR 61 12

No. 1 Smelt Dissolving

Tank 05/05/2004 M5 3 0 different dates within same year 154.P32

- Smelt

Dissolving Tank 1 0.1500 SCBR 61 12

No. 2 Smelt Dissolving

Tank 03/10/2004 M5 3 0 different dates within same year 154.P35

- Smelt

Dissolving Tank 2 0.1200 SCBR 62 13

No. 2 Smelt Dissolving

Tank 05/06/2004 M5 3 0 different dates within same year 154.P35

- Smelt

Dissolving Tank 2 0.1800 SCBR 62 13

No. 1 SDT 10/25/2007 M5 3 0 162.381C 0.1435 SCBR 63

No. 2 SDT 5/21/2009 M5 3 0 162.382B 0.1071 SCBR 64

No. 1 SDT South 6/1/2011 M5 3 0 163.SD1902 unspecified SCBR

No. 1 SDT North 6/1/2011 M5 3 0 163.SD1903 unspecified SCBR

No. 2 6/2/2011 M5 3 0 163.SD2906 0.1486 SCBR 65

No. 8 SDT 6/14/2004 M5 3 0 164.P08 unspecified SCBR

No. 10 SDT 6/16/2004 M5 3 0 164.P10 unspecified SCBR

No. 2 Smelt Tank

Scrubber 7/21/2004 M5 3 0 165.000008 0.0945 SCBR 66

No. 1 Smelt Tank

Scrubber 7/27/2004 M5 3 0 165.000014 0.1086 SCBR 67

No. 1 Smelt Dissolving

Tank 7/14/2009 M5 3 0 166.ST01 0.1441 SCBR 68

No. 2 Smelt Dissolving

Tank 7/17/2009 M5 3 0 166.ST02 0.1568 SCBR 69

Smelt Dissolving Tank 01/17/2011 M5 3 0 167.007SDT 0.1337 SCBR 70

No. 3 Smelt Dissolving

Tank 07/07/2009 M5 3 0 171.007 0.0900 SCBR 71

No. 4 Smelt Dissolving

Tank 07/06/2009 M5 3 0 171.008 0.1100 SCBR 72

No. 1 SDT 10/27/2010 unspecified 3 0 172.ST01 unspecified SCBR

Smelt Dissolving Tank 12/19/2000 M5 3 0 different dates 173.SDT 0.2040 SCBR 75 14

### E

- 40 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Outlet PM,

lb/ton BLS 1 ,2 Control 3 Graph

order

(Fig

C

- 1) Graph

order

(Fig

C

- 2)

Smelt Dissolving Tank 09/30/2004 M5 3 0 different dates 173.SDT 0.1800 SCBR 75 14

No. 4 SDT 10/27/2004 M5 3 0 different years 174.G

- 63B 0.2519 SCBR 76 15

No. 4 SDT 2/3/2005 M5 3 0 different years 174.G

- 63B 0.1953 SCBR 76 15

No. 5 SDT

- East Stack 10/22/2004 M5 3 0 separate stacks 174.G

- 63C SCBR

No. 5 SDT

- West

Stack 10/22/2004 M5 3 0 separate stacks 174.G

- 63C 0.0663 SCBR 77 16

No. 5 SDT

- East Stack 2/1/2005 M5 3 0 separate stacks 174.G

- 63C SCBR

No. 5 SDT

- West

Stack 2/1/2005 M5 3 0 separate stacks 174.G

- 63C 0.0717 SCBR 77 16

No. 2 SDT 4/13/2010 M5 4 0 175.ST2A 0.1951 SCBR 78

No. 3 Smelt Dissolving

Tank 03/24/2009 M5 3 0 175.ST3A 0.0686 SCBR 79

SDT 3/29/2011 M5 3 0 177.EU0805 0.0343 SCBR 80

No. 1 Smelt Dissolving

Tank 09/07/2004 M5 3 0 178.08T014 0.0959 SCBR 81 17

Smelt Dissolving Tank

No. 1 6/21/2011 M5 3 0 178.08T014 0.1600 SCBR 81 17

No. 2 Smelt Dissolving

Tank 09/08/2004 M5 3 0 178.08T015 0.0508 SCBR 82 18

Smelt Dissolving Tank

No. 2 6/22/2011 M5 3 0 178.08T015 0.1500 SCBR 82 18

No. 3 SDT Vent 5/27/2009 M5 3 0 different years 179.SDT 0.0756 SCBR 83 19

No. 3 SDT Vent 6/2/2010 M5 3 0 different years 179.SDT 0.0787 SCBR 83 19

No. 3 SDT Vent 3/17/2009 M5 3 0 180.D002, D907 0.0471 SCBR 84

No. 4 RB SDT 1/25/2005 M5 3 0 different year 181.11 0.1080 SCBR 85 20

No. 4 RB SDT

(condition 1: P

- dop =

6.9 in H2O) 11/2/2006 M5 3 0 Separate conditions 181.11 0.1830 SCBR 85 20

No. 4 RB SDT

(condition 3: P

- drop =

7.7 in H2O) 11/3/2006 M5 3 0 Separate conditions 181.11 0.1220 SCBR 85 20

No. 5 RB SDT 1/25/2005 M5 3 0 different year 181.51 0.1090 SCBR 86 20

No. 5 RB SDT

- (condition 1: P

- drop =

5.9 in H2O) 10/31/2006 M5 3 0 Separate conditions 181.51 0.2288 SCBR 86 20

No. 5 RB SDT

- (condition 2: P

- drop =

7.0 in H2O) 11/1/2006 M5 3 0 Separate conditions 181.51 0.1600 SCBR 86 20

No. 5 RB SDT

- (condition 3: P

- drop =

7.1 in H2O) 11/1/2006 M5 3 0 Separate conditions 181.51 0.2140 SCBR 86 20

Smelt Dissolving Tank

Vent 4/12/2005 M5 3 0 182.110 0.0700 SCBR 87

### E

- 41 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Outlet PM,

lb/ton BLS 1 ,2 Control 3 Graph

order

(Fig

C

- 1) Graph

order

(Fig

C

- 2)

Smelt Tank No. 1,

West 08/27/2004 M5 3 0 different dates (test report did not

indicate why each tank was tested

twice) 184.SDT1 0.1647 SCBR 88 21

Smelt Tank No. 1,

West 08/31/2004 M5 3 0 different dates (test report did not

indicate why each tank was tested

twice) 184.SDT1 0.1362 SCBR 88 21

Smelt Tank No. 2, East 08/25/2004 M5 3 0 different dates (test report did not

indicate why each tank was tested

twice) 184.SDT2a 0.2328 SCBR 89 22

Smelt Tank No. 2, East 08/26/2004 M5 3 0 different dates (test report did not

indicate why each tank was tested

twice) 184.SDT2a 0.2454 SCBR 89 22

Smelt Tank No. 2, East 10/26/2004 M5 3 0 different dates 184.SDT2a 0.1720 SCBR 89 22

Smelt Tank No. 2,

West 08/25/2004 M5 3 0 different dates (test report did not

indicate why each tank was tested

twice) 184.SDT2b 0.5337 SCBR 90 23

Smelt Tank No. 2,

West 08/26/2004 M5 3 0 different dates (test report did not

indicate why each tank was tested

twice) 184.SDT2b 0.4009 SCBR 90 23

Smelt Tank No. 2,

West 10/21/2004 M5 3 0 different dates 184.SDT2b 0.1091 SCBR 90 23

No. 4 Smelt Tank 7/22/2008 M5 3 0 different years 186.RB17 0.0900 SCBR 91 24

No. 4 Smelt Tank 7/13/2009 M5 3 0 different years 186.RB17 0.0801 SCBR 91 24

No. 1 Smelt Dissolving

Tank 06/06/2011 M5 3 0 188.015SD1 0.1010 SCBR 92

No. 2 Smelt Dissolving

Tank 06/06/2011 M5 3 0 188.017SD2 0.0950 SCBR 93

SDT East 12/2/2010 M5 3 0 189.SN27 0.0500 SCBR 94

SDT West 11/30/2010 M5 3 0 189.SN28 0.0990 SCBR 95

SDTV NO. 1 9/24/2009 M5 3 0 different years 190.R404 0.0668 SCBR 96 25

No. 1 SDT 4/21/2010 M5 3 0 different years 190.R404 0.0527 SCBR 96 25

Smelt Dissolving Tank

No. 2 10/15/2009 M5 3 0 190.R405 0.0724 SCBR 97

No. 3 SDT 3/23/2010 M5 3 0 190.R406 0.1440 SCBR 98

No. 2 North Smelt

Tank Vent 4/20/2010 M5 3 0 196.SN

- 08North 0.0899 SCBR 99

No. 2 South Smelt

Tank Vents 4/20/2010 M5 3 0 196.SN

- 08South 0.0709 SCBR 100

No. 3 Smelt Dissolving

Tank 09/03/2004 M5 3 0 196.SN

- 15 0.1406 SCBR 101

No. 3 SDT 7/27/2004 M5 3 0 198.020 0.0930 SCBR 102

No. 3 Smelt Dissolving

Tank 06/15/2011 M5 3 0 199.004 0.1613 SCBR 103

### E

- 42 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Outlet PM,

lb/ton BLS 1 ,2 Control 3 Graph

order

(Fig

C

- 1) Graph

order

(Fig

C

- 2)

Nos. 2 and 3 SDT Vent 7/29/2009 M5 3 0 200.007_8, 007_9 0.0548 SCBR 104

Smelt Dissolving Tank 08/19/2004 M5 3 0 201.SR0034 0.1770 SCBR 105

SDT EU322 7/19/2011 M5 3 0 202.Smelt

Dissolving Tank

EU322 0.0790 SCBR 106

No. 2 DT Scrubber

Vent Stack 10/12/2010 M5 1 0 203.2DTScr SCBR

No. 3 SDT 10/26/2010 M5 3 0 203.3DTScr 0.0700 SCBR 107

Smelt Dissolving Tank 07/20/2010 M5 3 0 205.010 0.1110 SCBR 108

No. 1 SDT 4/28/2010 M5 3 0 different years 208228535.002 0.0650 SCBR 109 26

No. 1 SDT 5/27/2011 M5 3 0 different years 208228535.002 0.101 SCBR 109 26

No. 2 SDT 8/19/2010 M5 3 0 208228535.008 0.0720 SCBR 110

No. 2 SDT North 1/19/2004 M5 3 0 226.SDT1N 0.0611 SCBR 111

No. 2 SDT South 1/20/2004 M5 3 0 226.SDT1S 0.0680 SCBR 112

No. 3 SDT 1/17/2004 M5 3 0 226.SDT2 0.0855 SCBR 113

No. 5 SDT 5/25/2010 M5 3 0 240.RF02 0.0942 SCBR 114

No. 6 SDT East 3/17/2010 M5 3 0 240.RF05 0.0628 SCBR 115

No. 6 SDT West 3/17/2010 M5 3 0 240.RF06 0.0592 SCBR 116

SDT 9/15/2010 M5 3 0 242.AA

- 012 0.0846 SCBR 117

No. 5 SDT 10/29/2009 M5 3 0 243.R403 0.1463 SCBR 118

No. 6 SDT 10/28/2009 M5 3 0 243.R408 0.1563 SCBR 119

Smelt Dissolving Tank 7/23/2004 M5 3 0 different years 340.007 0.1647 SCBR 120 27

Smelt Dissolving Tank 6/21/2005 M5 3 0 different years 340.007 0.1611 SCBR 120 27

No. 15 SDT 5/4/2011 M5 3 0 531.RF10 0.0434 SCBR 121

No. 2 SDT 11/2/2010 M5 3 0 600.G0805 0.0562 SCBR 122

No. 3 SDT 6/8/2010 M5 3 0 600.G0807 0.0460 SCBR 123

No. 2 Smelt Dissolving

Tank 03/19/2010 M5 3 0 different dates 606.SDT2 0.0892 SCBR 124 28

No. 2 Smelt Dissolving

Tank 04/05/2011 M5 4 0 different dates 606.SDT2 0.1153 SCBR 124 28

No. 3 Smelt Dissolving

Tank 10/25/2005 M5 3 0 different dates 606.SDT3 0.0880 SCBR 125 29

No. 3 Smelt Dissolving

Tank 07/25/2010 M5 3 0 different dates 606.SDT3 0.0770 SCBR 125 29

No. 4 Smelt Dissolving

Tank 07/20/2006 M5 3 0 different dates 606.SDT4 0.0985 SCBR 126 30

No. 4 Smelt Dissolving

Tank 10/25/2010 M5 3 0 different dates 606.SDT4 0.1728 SCBR 126 30

No. 2 Smelt Dissolving

Tank 07/09/2009 M5 3 0 Separate conditions: weak wash

scrubber 610.10 0.0790 SCBR 127 31

No. 2 Smelt Dissolving

Tank 07/09/2009 M5 3 0 Separate conditions: water

scrubber 610.10 0.0540 SCBR 127 31

### E

- 43 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission Unit Notes RTI+EUID Outlet PM,

lb/ton BLS 1 ,2 Control 3 Graph

order

(Fig

C

- 1) Graph

order

(Fig

C

- 2)

No. 1 Smelt Dissolving

Tank 07/08/2009 M5 3 0 Separate conditions: weak wash

scrubber 610.9 0.1210 SCBR 128 32

No. 1 Smelt Dissolving

Tank 07/08/2009 M5 3 0 Separate conditions: water

scrubber 610.9 0.1230 SCBR 128 32

No. 1 Smelt Dissolving

Tank

- Left Side 10/29/2009 M5 3 0 613.005 unspecified SCBR

No. 1 Smelt Dissolving

Tank

- Right Side 10/29/2009 M5 3 0 613.006 unspecified SCBR

No. 2 Smelt Dissolving

Tank

- Left Side 10/29/2009 M5 3 0 613.007 unspecified SCBR

No. 2 Smelt Dissolving

Tank

- Right Side 10/29/2009 M5 3 0 613.008 unspecified SCBR

SDT 10/20/2009 M5 3 0 615.25 0.1170 SCBR 133



### 1. Mass emission rates for each stack from SDTs with multiple stacks were summed to arrive at total mass emissions from the SDT.

2. “Unspecified” lb/ton BLS results reflect emissions tests that did not include a BLS production rate needed to convert emissions to lb/ton B LS format.

Unspecified r esults were not graphed.

3. OTH = mist eliminator, PBSCBR = packed bed scrubber, SCBR = scrubber

### E

- 44 

## Data Table for Figures D

- 1 and D

- 2

. TRS Emissions Test Data for Smelt Dissolving Tanks

Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Outlet TRS, lb as

H 2 S/ton BLS 1,2 Control 3 Graph

order

(Fig

D

- 1) Graph

order

(Fig

D

- 2)

Smelt Dissolving Tank 04/06/2011 M16B 3 0 157.SDT 0.0002 OTH 1

No. 2 Smelt Dissolving

Tank 07/08/2009 M16A/M6C 3 0 different dates 171.006 0.0022 OTH 2 1

No. 2 Smelt Dissolving

Tank 07/14/2010 M16A/M6C 3 0 different dates 171.006 0.0188 OTH 2 1

No. 10 Smelt

Dissolving Tank 11/15/2007 M16A 3 0 206.G

- 35 unspecified OTH

No. 11 Smelt

Dissolving Tank 11/14/2007 M16A 3 0 206.G

- 36 unspecified OTH

Smelt Dissolving Tank 9/23/2010 M16B 3 0 138.003 0.0009 PBSCBR 3

Smelt Dissolving Tank 05/17/2011 M16A 3 0 140.57 0.0153 PBSCBR 4

SDT3 4/29/2008 M16A 12 0 154.P38

- Smelt

Dissolving Tank 3 0.0021 PBSCBR 5

Smelt Dissolving Tank 3/3/2011 M16C 5 0 155.SDT 0.0118 PBSCBR 6

No. 4 Smelt Dissolver 01/31/2007 M16A/M6C 3 0 185.05 0.0053 PBSCBR 7

S21 SDT 3/16/2011 M16A 3 0 617.P21 0.0130 PBSCBR 8

Smelt Dissolving Tank 8/9/2001 M16 3 0 100.109 0.0060 SCBR 9

No. 10 Smelt

Dissolving Tank 01/05/2011 M16A/M6C 3 0 102.SDTV10 0.0067 SCBR 10

#4 Smelt Dissolving

Tank 9/28/2010 M16A 3 0 105.EU445D 0.0074 SCBR 11

Smelt Dissolving

Tanks 6/9/2011 M16A 3 0 107.09

- P2 0.0100 SCBR 12

Smelt Dissolving Tank

# 3 9/9/2008 M16 3 0 109.SDT3 0.0040 SCBR 13

No. 4 Smelt Dissolver 9/10/2008 M16 3 0 109.SDT4 0.0020 SCBR 14

South Smelt Tank 1/29/2011 M16 3 0 111.G

- 127 0.0140 SCBR 15

Smelt Dissolving Tank 3/18/2009 M16A/M6C 3 0 112.AA

- 101 0.0029 SCBR 16

Smelt Dissolving Tank 12/2/2009 M16A 3 0 114.U508 0.0054 SCBR 17

SDT West 9/9/2010 M16A 3 0 separate stacks 115.SM01 SCBR

SDT East 9/9/2010 M16A 3 0 separate stacks 115.SM01 0.0053 SCBR 18

Smelt Dissolving Tank

Vent 7/20/2004 M16A 3 0 116.004 0.0039 SCBR 19

No. 20 SDT 12/1/2010 M16 3 0 119.EQT005 0.0150 SCBR 20

No. 1 Smelt Dissolver 11/3/2010 M16A 3 0 124.020 0.0111 SCBR 21

No. 2 Smelt Dissolver 11/4/2010 M16A 3 0 124.021 0.0154 SCBR 22

SDT 12/10/2009 M16A 3 0 126.SDT 0.0047 SCBR 23

SDT Vent 10/26/2010 M16A 3 0 127.SDT1 0.0016 SCBR 24

SDTV No. 4 6/15/2009 M16A 3 0 132.4SDT 0.0077 SCBR 25

Smelt Dissolving Tank 12/01/2010 Modified

M16 3 0 Combined stacks

given 135.007

- 1, 007

- 2 0.0127 SCBR 26

### E

- 45 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Outlet TRS, lb as

H 2 S/ton BLS 1,2 Control 3 Graph

order

(Fig

D

- 1) Graph

order

(Fig

D

- 2)

SDT 5/19/2010 M16A/M16B 3 0 136.EU 031 0.0044 SCBR 27

No. 3 Smelt Dissolving

Tank Vent 06/30/2003 M16A 3 0 142.P7236 0.0130 SCBR 28

No. 1 and No. 2 SDTs 7/22/2004 M16A 3 0 142.P7413 0.0040 SCBR 29

No. 1 Smelt Dissolving

Tank 07/30/2009 M16 3 0 143.7005 0.0031 SCBR 30

No. 2 Smelt Dissolving

Tank 07/30/2009 M16 3 0 143.7015 0.0007 SCBR 31

No. 3 Smelt Dissolving

Tank 07/31/2009 M16 3 0 143.7025 0.0062 SCBR 32

No. 1 SDT upriver 10/14/2008 M16A 3 0 separate stacks 146.10 SCBR

No. 1 SDT downriver 10/14/2008 M16A 3 0 separate stacks 146.10 0.0038 SCBR 33

No. 2 SDT 10/16/2008 M16A 3 0 146.17 0.0014 SCBR 34

No. 1 SDT 12/17/2010 M16C 3 0 different dates 148.002 0.0176 SCBR 35 2

No. 1 SDT 3/24/2004 M16A 3 0 different dates 148.002, SCMT1 0.0118 SCBR 35 2

No. 1 SDT 8/31/2010 M16C 3 0 different dates 148.002 0.0270 SCBR 35 2

No. 2 SDT 9/30/2010 M16C 4 0 different dates 148.008 0.0206 SCBR 36 3

No. 2 SDT 3/24/2004 M16A 3 0 different dates 148.008, SCMT2 0.0181 SCBR 36 3

No. 9 SDT (test 1) 4/3/2009 M16 reason unspecified 149.P005 0.0140 SCBR 37 4

No. 9 SDT (test 2) 4/8/2009 M16 3 0 reason unspecified 149.P005 0.0129 SCBR 37 4

Smelt Tank East 3/16/2011 M16B 3 0 Separate stacks: The

smelt dissolving tank

emission unit id

CREC

- 2 has two

identical stacks

(CREC

- 2a and CREC

2b) and each stack has

an identical scrubber

(SCRBSTa and

SCRBSTb). 150.CREC

- 2a SCBR

Smelt Tank West 3/16/2011 M16B 3 0 Separate stacks: The

smelt dissolving tank

emission unit id

CREC

- 2 has two

identical stacks

(CREC

- 2a and CREC

2b) and each stack has

an identical scrubber

(SCRBSTa and

SCRBSTb ). 150.CREC

- 2b 0.01 SCBR 38

No. 1 SDT 8/7/2008 M16 3 0 162.381C 0.0087 SCBR 39

No. 2 SDT 3/15/2007 M16 3 0 162.382B 0.0111 SCBR 40

No. 1 SDT South 7/16/2009 M16A 3 0 163.SD1902 0.0043 SCBR 41

### E

- 46 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Outlet TRS, lb as

H 2 S/ton BLS 1,2 Control 3 Graph

order

(Fig

D

- 1) Graph

order

(Fig

D

- 2)

No. 1 SDT North 7/16/2009 M16A 3 0 163.SD1903 0.0017 SCBR 42

No. 2 Smelt Dissolving

Tank 12/08/2003 M16A 3 0 163.SD2906 0.0086 SCBR 43

No. 1 Smelt Dissolving

Tank 7/14/2009 M16 3 0 166.ST01 0.0070 SCBR 44

No. 2 Smelt Dissolving

Tank 7/17/2009 M16 3 0 166.ST02 0.0140 SCBR 45

Smelt Dissolving Tank 01/17/2011 M16A 3 0 167.007SDT 0.0064 SCBR 46

No. 3 Smelt Dissolving

Tank 07/07/2009 M16A/M6C 3 0 different dates 171.007 0.0047 SCBR 47 5

No. 3 Smelt Dissolving

Tank 07/13/2010 M16A/M6C 3 0 different dates 171.007 0.0272 SCBR 47 5

No. 4 Smelt Dissolving

Tank 07/06/2009 M16A/M6C 3 0 different dates 171.008 0.0041 SCBR 48 6

No. 4 Smelt Dissolving

Tank 07/15/2010 M16A/M6C 3 0 different dates 171.008 0.0130 SCBR 48 6

Smelt Dissolving Tank 02/08/2001 M16 3 0 173.SDT 0.0100 SCBR 49

No. 5 SDT

- East Stack 10/22/2004 M16 3 0 separate stacks 174.G

- 63C SCBR

No. 5 SDT

- West

Stack 10/22/2004 M16 3 0 separate stacks 174.G

- 63C 0.0107 SCBR 50

No. 2 SDT 8/10/2010 M16C 3 0 175.ST2A 0.0037 SCBR 51

No. 3 Smelt Dissolving

Tank 08/10/2009 M16 3 0 175.ST3A 0.0012 SCBR 52

SDT 3/29/2011 M16C 3 0 177.EU0805 0.0021 SCBR 53

No. 3 SDT Vent 5/27/2009 M16 3 0 179.SDT 0.0102 SCBR 54

No. 3 SDT Vent 3/17/2009 M16 3 0 180.D002, D907 0.0050 SCBR 55

Smelt Dissolving Tank

Vent 1/12/2010 M16 3 0 182.110 0.0080 SCBR 56

No. 4 Smelt Tank 7/22/2008 M16 4 0 186.RB17 0.0210 SCBR 57

No. 1 Smelt Dissolving

Tank 06/06/2011 M16A/M6C 3 0 188.015SD1 0.0041 SCBR 58

No. 2 Smelt Dissolving

Tank 06/06/2011 M16A/M6C 3 0 188.017SD2 0.0041 SCBR 59

SDT East 12/2/2010 M16B 3 0 189.SN27 0.0001 SCBR 60

SDT West 11/30/2010 M16B 3 0 189.SN28 0.0017 SCBR 61

No. 2 SDT 3/24/2010 M16A 3 0 190.R405 0.0070 SCBR 62

No. 3 SDT 3/25/2011 M16C 3 0 190.R406 0.0090 SCBR 63

No. 2 North Smelt

Tank Vent 4/20/2010 M16A 3 0 196.SN

- 08North 0.0006 SCBR 64

No. 2 South Smelt

Tank Vents 4/20/2010 M16A 3 0 196.SN

- 08South 0.0006 SCBR 65

No. 3 Smelt Tank

Vents 4/21/2010 M16A 3 0 196.SN

- 15 0.0003 SCBR 66

### E

- 47 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Outlet TRS, lb as

H 2 S/ton BLS 1,2 Control 3 Graph

order

(Fig

D

- 1) Graph

order

(Fig

D

- 2)

No. 3 SDT 2/21/1995 M16A 3 0 198.020 0.0110 SCBR 67

No. 3 Smelt Dissolving

Tank 02/11/2009 M16 3 0 199.004 0.0100 SCBR 68

Nos. 2 and 3 SDT Vent 4/14/2011 M16 3 0 200.007_8, 007_9 0.0040 SCBR 69

Smelt Dissolving Tank 10/28/1987 M16A 3 0 201.SR0034 0.0145 SCBR 70

SDT EU322 7/19/2011 M16A 3 0 202.Smelt Dissolving

Tank EU322 0.0041 SCBR 71

Smelt Dissolving Tank 01/14/2009 M16A 3 0 205.010 0.0029 SCBR 72

No. 1 SDT 4/23/2007 M16A 3 0 208228535.002 0.0250 SCBR 73

No. 2 SDT 12/14/2006 M16A 3 0 208228535.008 0.0119 SCBR 74

No. 3 SDT 9/11/1992 M16 3 0 226.SDT2 0.0058 SCBR 75

No. 5 SDT 5/25/2010 M16 3 0 240.RF02 0.0097 SCBR 76

No. 6 SDT East 3/17/2010 M16 3 0 240.RF05 0.0078 SCBR 77

No. 6 SDT West 3/17/2010 M16 3 0 240.RF06 0.0017 SCBR 78

SDT 9/30/2010 M16 3 0 242.AA

- 012 0.0130 SCBR 79

No. 5 SDT 10/29/2009 M16 3 0 243.R403 0.0122 SCBR 80

No. 6 SDT 10/28/2009 M16 3 0 243.R408 0.0032 SCBR 81

No. 15 SDT 4/14/2010 M16 3 0 531.RF10 0.0050 SCBR 82

No. 2 SDT 10/23/2007 M16 3 0 600.G0805 0.0130 SCBR 83

No. 3 SDT 5/7/2008 M16 3 0 600.G0807 0.0080 SCBR 84

No. 2 Smelt Dissolving

Tank 12/15/2011 M16 3 0 606.SDT2 0.0090 SCBR 85

No. 3 Smelt Dissolving

Tank 10/25/2005 M16 3 0 606.SDT3 0.0093 SCBR 86

No. 4 Smelt Dissolving

Tank 07/20/2006 M16 3 0 606.SDT4 0.0137 SCBR 87

No. 2 Smelt Dissolving

Tank 07/14/2009 M16 3 0 Separate conditions:

weak wash scrubber 610.10 0.0110 SCBR 88 7

No. 2 Smelt Dissolving

Tank 07/14/2009 M16 3 0 Separate conditions:

water scrubber 610.10 0.0210 SCBR 88 7

No. 2 Smelt Dissolving

Tank 8/1/2005 M16 3 0 Different dates and

Separate condit i ons:

Normal weak wash

scrubber flow 610.10 0.0200 SCBR 88 7

No. 2 Smelt Dissolving

Tank 8/3/2005 M16 3 0 Different dates and

Separate condit i ons:

Low weak wash

scrubber flow 610.10 0.0290 SCBR 88 7

No. 2 Smelt Dissolving

Tank 8/4/2005 M16 3 0 Different dates and

Separate condit i ons:

Low water wash

scrubber flow 610.10 0.0240 SCBR 88 7

### E

- 48 Description Test Date Test Method No.

Runs No.

Runs

BDL Duplicate Emission

Unit Notes RTI+EUID Outlet TRS, lb as

H 2 S/ton BLS 1,2 Control 3 Graph

order

(Fig

D

- 1) Graph

order

(Fig

D

- 2)

No. 2 Smelt Dissolving

Tank 7/17/2007 M16 3 0 Different dates and

Separate condit i ons:

Weak wash scrubber

flow 610.10 0.0200 SCBR 88 7

No. 2 Smelt Dissolving

Tank 7/19/2007 M16 3 0 Different dates and

Separate condit i ons:

Water scrubber flow 610.10 0.0310 SCBR 88 7

No. 1 Smelt Dissolving

Tank 07/14/2009 M16 3 0 Separate conditions:

weak wash scrubber 610.9 0.0110 SCBR 89 8

No. 1 Smelt Dissolving

Tank 07/15/2009 M16 3 0 Separate conditions:

water scrubber 610.9 0.0040 SCBR 89 8

No. 1 Smelt Dissolving

Tank 7/30/2007 M16 3 0 Different dates and

Separate condit i ons:

Weak wash scrubber

flow 610.9 0.0250 SCBR 89 8

No. 1 Smelt Dissolving

Tank 7/31/2007 M16 3 0 Different dates and

Separate condit i ons:

Water scrubber flow 610.9 0.0290 SCBR 89 8

SDT 10/20/2009 M16A 3 0 615.25 0.0050 SCBR 90



### 1. Mass emission rates are provided in pounds (lb) of TRS (reported as hydrogen sulfide, H 2 

### S) per ton of black liquor solids (BLS). Mass emission

rates for each stack from SDTs with multiple stacks were summed to arrive at total mass emissions from the SDT.

2. “Unspecified” lb as H 2 

### S /ton BLS results reflect emissions tests that did not include a BLS production rate needed to convert emissions to lb as

H 2 

### S /ton BLS format. Unspecified results were not graphed.

3. OTH = mist eliminator, PBSCBR = packed bed scrubber, SCBR = scrubber