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Pulp and Paper Sector Survey

Instructions for Part III: 

Chemical Recovery Combustion Sources

11/16/10

This survey overview document provides instructions for completing Part III the pulp and paper survey. This 

overview is organized as follows:

A. Part III Introduction.........................................................................................................................................2

B. Confidential Business Information (CBI)........................................................................................................4

C. How to Submit Your Part III Survey Response...............................................................................................4

C1. Submitting Your Non-CBI Response................................................................................................4

C2. Submitting CBI.................................................................................................................................5

D. How to Complete the Part III Survey ..............................................................................................................5

D1. Process data (P&P survey_PIII.xls) ..................................................................................................5

a. PIII Equip detail tab.................................................................................................................7

b. PIII Permit limits tab .............................................................................................................10

c. PIII Controls tab ....................................................................................................................11

d. PCC tab..................................................................................................................................12

D2. Test data..........................................................................................................................................12

a. PIII Emissions test data tab ...................................................................................................12

b. CEMS data spreadsheet (P&P CEMS_PIII.xls) ....................................................................13

D3. Optional cost data............................................................................................................................16

PART III - ATTACHMENT 1 Emission Units to Include in the Part III Pulp and Paper Survey Response .............17

PART III - ATTACHMENT 2 Part III Emissions Test Data Request........................................................................18
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A. Part III Introduction

The pulp and paper sector information request applies for pulp and/or paper/paperboard mills that are a “major 

source” or “synthetic area source” of hazardous air pollutant (HAP) emissions that:

(a) Perform chemical wood pulping (kraft, sulfite, soda, or semichemical), or

(b) Perform mechanical, groundwood (e.g., thermomechanical pulping (TMP), refiner mechanical pulping 

(RMP)), secondary fiber, and non-wood pulping, or

(c) Perform bleaching, or

(d) Manufacture paper or paperboard products.

As defined in 40 CFR Part 63, subpart A,

“Major source” means any stationary source or group of stationary sources located within a contiguous 

area and under common control that emits or has the potential to emit considering controls, in the 

aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any 

combination of hazardous air pollutants, unless the Administrator establishes a lesser quantity, or in the 

case of radionuclides, different criteria from those specified in this sentence.

A “synthetic area source” is a stationary source which is subject to federally-enforceable conditions that limit its 

potential to emit to below major source thresholds.

Certain mills are not required to complete the pulp and paper sector survey. If your mill meets one of the following 

conditions, then you should have completed the form in Attachment 1 of the Survey Overview document and 

submitted it to Bill Schrock (EPA) before beginning Part I of the survey. Conditions for exemption from all parts of 

the pulp and paper sector survey are as follows: 

 Your mill is not a “major source” or “synthetic area source” of HAP emissions, or

 Your mill was not operational in 2009 (and remains closed), or 

 Your mill does not produce pulp, perform bleaching, or serve as a primary manufacturer of paper or 

paperboard products.

Part III of this information request applies for pulp mills that are a “major source” or “synthetic area source” of 

hazardous air pollutant (HAP) emissions that perform chemical wood pulping (for example, with the kraft, sulfite, 

soda, semichemical or other pulping process).

This survey is to be completed in a Microsoft Excel spreadsheet file that is divided into several worksheets (“tabs” 

within the spreadsheet file). You must complete certain tabs of the survey spreadsheet (depending on the type of 

mill you operate). Table 1 below denotes which survey spreadsheet tabs to complete depending on mill type. 

Additional spreadsheets are provided for submittal of continuous emissions monitoring system (CEMS) data or 

control measure cost information.

Please complete the survey for the facility listed in the Section 114 letter you received in the mail. If you received

more than one Section 114 letter for multiple facilities, you must create a separate survey response for each facility.

If you have not already received or downloaded a copy of the survey spreadsheets, they can be downloaded here:

https://icr2010.rti.org/Industries/PulpPaper.aspx

Use the 2009 calendar year as the base year for all survey responses (e.g., 2009 emissions inventory, 2009 capacity, 

2009 equipment configurations, etc.), unless another year is specified in the instructions (e.g., for emissions test 

data). 

Part III of this survey asks questions about the chemical recovery combustion sources listed in Attachment 1 to this 

document. Section D, How to Complete the Part III Survey, explains how to treat various configurations of 

emission units (e.g., multiple emission units venting to the same stack, etc.) for each survey tab. Attachment 2 of 

this document contains a table of emission units and pollutants for which existing emission test data are requested 

under Part III.
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Use the following attachments to the Survey Overview document for reference:

Attachment 2: Regulatory definitions from the kraft pulp mill new source performance standards (NSPS) 

(40 CFR Part 60, subpart BB), chemical recovery combustion source national emissions 

standards for hazardous air pollutants (NESHAP) (40 CFR Part 63, subpart MM), the pulp 

and paper production NESHAP (40 CFR Part 63, subpart S), and selected definitions from 

the NSPS and NESHAP General Provisions. 

Attachment 3: Acronyms and abbreviations used throughout the survey and associated spreadsheets. 

Table 1. Part III Survey Spreadsheets and Tabs to Complete

Spreadsheet and tab Types of mills that should complete this spreadsheet tab

P&P survey_PIII.xls

PIII Equip detail All mills subject to Part III

PIII Permit limits All mills subject to Part III (unless permit limit information for Part III emission 

units was provided in Part I)

PIII Controls Mills with add-on air pollution controls on chemical recovery combustion sources. 

PIII Emissions test data Mills operating emission units for which test data are requested in Attachment 2 to 

this document.

P&P CEMS_PIII.xls

CEMS data (separate tabs 

are included for different 

pollutants)

Mills operating CEMS on chemical recovery combustion sources.

P&P costs OPTIONAL_PIII.xls (Completion of this spreadsheet is optional)

APCD costs Mills that installed selected air pollution controls (see section D3)

Equip change costs Mills implementing selected process or equipment changes (see section D3)
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B. Confidential Business Information (CBI) 

The EPA's procedures for handling confidential business information (CBI) are described in the letter (and 

attachments) accompanying the pulp and paper information collection request (ICR). If you believe that providing 

any specific information to us would reveal a trade secret, please identify this information clearly in your 

spreadsheet response by shading the spreadsheet cell containing the CBI with red highlight and indicating in the red 

block at the top of each spreadsheet tab that the tab contains CBI. Also, please clearly label any attachments 

submitted with your survey that contain CBI. However, please do not label your entire response as CBI if only a 

portion includes trade secrets. The EPA is likely to follow-up with a request for validation of CBI claims for mills 

claiming large amounts of information as trade secret, especially information that is readily reported by other mills

without such claims.

C. How to Submit Your Part III Survey Response 

If your response to this information collection request includes data with a claim of CBI, you should follow the 

instructions in this section to ensure the protection of your data. Please note that if you submit CBI, you will be 

separating your data into two portions and sending your data to EPA using two different mailing addresses. 

C1. Submitting Your Non-CBI Response

Follow these instructions for the non-CBI portions of your survey response (or for responses that are entirely nonCBI.)

After you have completed and reviewed your survey response, sign and date the certification form in Attachment 4 

of the Survey Overview document. Remove the CBI components from your survey as instructed in section C2. Save 

the Excel spreadsheet(s) containing the non-CBI portions of your completed response, emission test reports, and any 

other electronic non-CBI attachments on the flash drive you were provided with your section 114 letter (or on a CD 

or DVD). Assemble any non-CBI hard copy attachments to your survey (such as the signed certification form or 

test data). Mail the non-CBI flash drive (or disk) and any non-CBI hard copy materials in one envelope to EPA at 

the address specified below by the specified response deadline in the Section 114 letter. (Note: If the 

spreadsheet/attachments contain CBI, use the address for Mr. Morales provided in section C2 of this document.)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (E143-03)

Attn: Mr. Bill Schrock

109 TW Alexander Drive

Research Triangle Park, NC 27711

EPA recommends sending your non-CBI files via Registered U.S. Mail using return receipt requested, Federal 

Express, or other method for which someone must provide a signature upon receipt.
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C2. Submitting CBI

Follow these instructions for any portion of your survey response that contains CBI. 

Please create a separate CD or DVD containing a version of your spreadsheet response with only the CBI portion of 

your data (i.e., only the red highlighted data in the survey spreadsheet). Include on the disk any pages of 

attachments to your survey response containing CBI, with the CBI portions of the pages clearly marked (e.g., 

highlighted or circled). Clearly mark the disk with the words “Confidential Business Information.” Send only these 

CBI files under separate cover to:

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (C404-02) 

Attn: Mr. Roberto Morales, Document Control Officer

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711

For the security of your data, EPA recommends sending your confidential files to Mr. Morales via Registered U.S. 

Mail using return receipt requested, Federal Express, or other method for which someone must provide a signature 

upon receipt.

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA. E-mail 

and facsimile are not secure forms of communication and should never be used to transmit CBI.

D. How to Complete the Part III Survey 

Your survey response will consist of emission test reports and completed Microsoft Excel spreadsheets. Separate 

Excel spreadsheet files are provided for completion (P&P survey_PIII.xls; P&P CEMS_PII.xls; P&P costs 

OPTIONAL_PIII.xls). You must complete certain tabs of the P&P survey_PIII.xls spreadsheet file (depending on 

the type of mill you operate) as shown in Table 1 above. The P&P CEMS_PIII.xls spreadsheet file is to be 

completed if you have continuous emissions monitoring data to supply. The P&P costs OPTIONAL_PIII.xls 

spreadsheet file is an optional spreadsheet file that can be completed to supply control measure cost information

helpful for EPA’s regulatory analyses.

D1. Process data (P&P survey_PIII.xls)

In this portion of the survey you are asked to add data to the various tabs in the P&P survey_PIII.xls spreadsheet. 

Many of the instructions you need for completing the survey tabs are included in the “Instruction” row of each tab in 

the P&P survey_PIII.xls spreadsheet. However, more detailed instructions for selected tabs are provided below to 

account for common situations and to provide information on how the data will be used by EPA. Each survey tab 

includes fields with pull-down menus for common entries. Use these pull-down menus whenever possible, or write 

in information if your selection is not contained in the pull-down menu. 
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Several IDs are requested throughout Part III of the the pulp and paper survey response spreadsheet(s), including: 

 NEI Site ID

 Emission Unit ID

 Collection system ID

 APCD_ID

The NEI Site ID and Emission Unit ID should correspond with the IDs used in the NEI update (Part II of this 

survey) where such IDs exist. If no NEI Site ID already exists (e.g., in cases where no previous NEI data exists for 

your mill), then you should use“NEW_____” for the NEI Site ID where the blank is your mill’s zip code, as this will 

(in all likelihood) provide a unique identifier for your mill. If Emission Unit ID(s) for selected process units do not 

already exist in the NEI data set, then you may use any Emission Unit ID you choose (for example, the ID used in 

your permit), and this same ID should be used throughout all Parts of the survey. You will specify the Collection 

system ID, and APCD_ID in the PIII Equip detail and other spreadsheet tabs. 

A Note About Identification Numbers (IDs)

The different parts of the pulp and paper survey include the following IDs: 

 NEI Site ID

 Emission Unit ID

 Collection system ID 

 APCD_ID

It is imperative that you use the same IDs to describe the same facility, equipment/emission unit, and 

emission release point throughout all parts of this survey. These ID codes will be used to link the 

various pulp and paper data base tables together into a functional and informative data base to be 

used for regulatory analyses. You may choose your own IDs (e.g., based on Emission Unit IDs 

already included in the NEI, IDs from existing process flow diagrams, IDs in your air permit, etc.), 

but the IDs you choose must be consistent throughout your survey response. If you wish to avoid 

follow-up calls regarding your survey data, please make every effort to ensure that your IDs match 

throughout the spreadsheet(s) and in each part of your survey response. For example, any Emission 

Unit ID or APCD_ID you create/specify in Part I should also be used when referring to the same 

piece of equipment in Parts II and III for this survey response.

Also, please be sure that no extra spaces or characters are included in the ID cells. For example, 

Emission Unit ID “DIG1” is not read the same as “DIG-1” or “DIG-1_” by data base software.

Why does EPA need process data?

Facility and equipment details are being requested to inform the technological review of the pulp and 

paper NESHAP and NSPS and to provide information on means of reducing residual risk. While the 

NEI update (requested in Part II of this survey) provides EPA with data related to emissions release 

points (e.g., mass emission rate and stack exit parameters used for risk analysis and tracking 

nationwide trends), the technological review of the NESHAP and NSPS standards considers 

emission unit and control equipment details specific to the processes employed and matches these 

details to emissions levels that are achieved (e.g., emission concentrations). Applicability of the 

NESHAP and NSPS compliance options depends on the specific process equipment. 
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Follow the instructions below and in the “Instruction” rows of the spreadsheet to complete the survey tabs. Refer to 

Table 1 of this document to determine which tabs you must complete, depending on the type of mill you operate.

a. PIII Equip detail tab 

All mills covered by Part III are asked to complete the PIII Equip detail tab. This tab asks for information for each 

individual emission unit. The purpose of this tab is to provide EPA with equipment-specific details needed for the 

Agency to review the technology-based standards (i.e., nationwide numbers of equipment, configuration of controls, 

pertinent equipment details, and regulatory compliance options used).

The types of emission units listed in Attachment 1 that you operate should be included in the PIII Equip detail tab.

Columns A through AM ask generic questions for all emission units. The columns to the right of column AM

request design and operating details for specific types of emission units (e.g., recovery furnaces, etc.). The table 

below summarizes the different types of equipment for which specific questions are included in the PIII Equip detail

tab.

PIII Equip detail

tab columns

Description of information requested

A-AM Equipment, controls, and Federal rule applicability for each emission unit and 

collection system. Complete these columns for all emission units. 

AN Black liquor gasification

AO-AT Black liquor oxidation systems

AU-BH Recovery furnaces and recovery furnace ESPs

BI-BN Semichemical combustion units (at stand-alone semichemical pulp mills)

BO-BT Smelt/ash dissolving tanks

BU-CB Lime kilns (including rotary lime kilns and fluidized bed calciners)

CC Fuel-fired equipment

CD-CJ Equipment incinerating NCG or SOG

CK-DN Primary and supplemental fuels

DO-DU Emission unit startup and shutdown.

What if I do not know or have the information to answer a survey question? 

There may be survey questions that you do not know the answer to, or for which information is not 

readily available. The following codes may be used: 

Unknown (UK): If you do not have the requested information, cannot obtain the information 

without extraordinary effort, and cannot provide a reasonable estimate, then you may enter 

“UK” for unknown. 

Not Applicable (NA): If a question is not applicable to your operations, then you may enter 

“NA” for not applicable.

Survey respondents are reminded that their certification of the accuracy of their response includes a

certification that any identification of information as "unknown" or "not applicable" is accurate. Further, 

survey respondents providing an excessive number of responses as “UK or “NA” are likely to receive 

scrutiny and follow-up inquiries from EPA related to their survey response.
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Data are requested for each emission unit (and need not be broken out by individual emission points for a given 

emission unit unless different collection or control measures apply for the different emission points from an 

emissions unit). Specify the Emission Unit ID and Collection system ID (if applicable), and APCD_ID(s) by 

following the directions in the “Instruction” row of the PIII Equip detail tab. Some common configurations of 

emission units are addressed below.

Multiple emission units ducted to a single release point. List each emission unit separately in the PIII 

Equip detail tab even if the exhaust from the emission unit is ducted to a common conveyance. For 

multiple emission units ducted through a common conveyance to the same release point, list each Emission 

Unit ID separately and provide the same Collection system ID for the different Emission Unit IDs.

Single emission unit with multiple release points. Repeat the Emission Unit ID on separate rows and 

distinguish the release points using the “Emission unit description” column in as many rows as needed to 

reflect all of the release points associated with the emission unit in the PIII Equip detail tab. For example, 

Emission Unit ID 001 (EU001) is vented to two stacks with different controls. Split EU001 to EU001a and 

EU001b on separate rows of the PIII Equip detail tab, and then indicate in the “Emission Unit Description” 

column that EU001a and EU001b vent through separate stacks. Enter details associated with emission 

release (APCD information and NSPS/NESHAP compliance options) in each row. Enter equipment details 

(year installed, hours per year [hr/yr], combustion controls, fuel data, equipment design and other operating 

parameters) in only 1 row, leaving all other rows associated with the Emission Unit ID blank.

Emission units vented into the building. Include emissions units that vent into a building in the PIII Equip 

detail tab, and enter “BLDG” in the “Configuration if not emitted through a conveyance” column.

Emission units that are not vented. Include emissions units that are not vented in the PIII Equip detail tab, 

and enter “NV” in the “Configuration if not emitted through a conveyance” column.

Emission units with fugitive emissions. Include emissions units with fugitive emissions in the PIII Equip 

detail tab, and enter “FUGITIVE” in the “Configuration if not emitted through a conveyance” column.

If an emission unit produces both fugitive emissions and emissions that are emitted though a conveyance,

then you need to specify the fugitive emissions on a separate row in the PIII Equip detail tab (e.g., as a 

“Single emission unit with multiple release points” as described in the instructions immediately above for 

the PIII Equip detail tab).

Bypass stacks used only during certain times. Do not include data for bypass stacks or control system 

bypasses in the PIII Equip detail tab, except as specified for backup controls below.

Air pollution control devices (APCDs). In the APCD columns, enter primary air pollution control devices

(APCDs) (i.e., the pollution control used most frequently) in the sequence in which they are used to control 

emissions from each emission unit (or collection system) identified in the Emission Unit ID column. Enter 

a description of the APCD in the APCD “type” column and an ID code in the APCD_ID column. The ID 

you enter into the APCD_ID field will correspond with the APCD_ID you enter in the Controls tab. For 

example,

If you use an electrostatic precipitator (ESP) (ESP1) followed by a scrubber (WSa), you would 

enter APCD1 type = ESP and APCD2 type = scrubber, and APCD1_ID = ESP1 and 

APCD2_ID = WSa. 

If a white liquor scrubber (identified as WLIQSBR) is used to scrub SOG prior to burning of the 

SOG in a lime kiln (Emission Unit ID = LK2), then APCD1_ID = WLIQSBR and APCD2_ID 

= LK2.

Emission units routed to another emission unit for emissions control. Enter the Emission Unit IDs for each 

emission unit being controlled in the Emission Unit ID column. Use the controlling emission unit’s 

Emission Unit ID as the APCD_ID in the APCD columns.
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Complete the applicable equipment-specific details requested in columns AN through DN for each type of emission 

unit in the PIII Equip detail tab by following the directions in the “Instruction” row of the tab. Additional specific 

instructions are provided below for equipment requiring instructions beyond what could be explained in the 

“Instruction” row. Leave columns that do not apply for a given emission unit blank.

All emission units listed in Attachment 1. Complete columns A through AM. These columns ask generic questions 

for all emission units related to how the emission units are vented and controlled, and related to Federal rule 

applicability. Additional questions in columns AN through DU may also apply for selected emission unit types.

Recovery furnaces and semichemical combustion units. Questions pertaining to recovery furnaces have been 

combined for kraft, kraft with co-located semichemical, soda, and sulfite pulps. The equipment-specific details will 

provide post-MACT recovery furnace and semichemical combustion unit configurations. Capacities and other 

design parameters are requested for purposes of impacts analyses. Conversion years (e.g., year DCE converted to 

NDCE, or year of wet- to dry-bottom ESP conversion) allow EPA to identify mills that might have relatively recent 

cost and other information related to equipment conversions. The combustion unit hottest temperature is requested 

for semichemical combustion units in order to characterize the different types of semichemical combustion units.

Smelt dissolving tanks and lime kilns. These questions will characterize the population of smelt dissolving tanks 

and lime kilns following subpart MM compliance. Capacities and other design parameters are requested for 

purposes of impacts analyses.

Primary and supplemental fuels. Fuel types are requested for fuel-fired equipment because fuel type can have an 

effect on emissions. The EPA may consider fuel types and perform calculations based on fuel firing rates for 

various nationwide impact analyses. Because the types and amounts of fuels fired can vary seasonally, EPA is 

requesting the approximate percent of annual heat input capacity in million British thermal units per year 

(MMBtu/yr) supplied by each fuel.

Primary fuel information is requested for fuel-fired equipment such as lime kilns and thermal oxidizers. Primary

fuels are not requested for recovery furnaces or semichemical combustion units because black liquor (or red liquor) 

is assumed to be the primary fuel for these units. Non-condensable gases (NCG) and stripper off gases (SOG) are 

not considered to be either primary or supplemental fuels for purposes of this survey. Supplemental and other fuel 

information is requested for recovery furnaces and semichemical combustion units in addition to other fuel-fired 

equipment such as lime kilns and thermal oxidizers. Information for secondary and additional fuels used routinely 

for multifuel-fired equipment may be indicated in the supplemental and other fuel columns.

Emission unit startup and shutdown. Complete the startup and shutdown questions for all emission units currently 

subject to Federal or State emission limits or monitoring requirements. Questions pertaining to emission unit startup 

and shutdown are asked in order to provide EPA with an understanding of the duration, emissions potential, work 

practices, and control mechanisms of startup and shutdown events for the wide variety of equipment used at pulp 

What averaging period should be used in responding to process detail questions?

Several questions in the PI Equip detail and other survey tabs ask for process parameters such as 

exhaust flow rate (acfm), percent solids, temperature, etc. Unless otherwise specified, typical values 

are requested, and are subject to the respondent’s discretion. For example, if you measure a 

particular parameter with an online meter and you have data available for most operating hours of 

the year, then you may choose to supply an annual average for the parameter. However, if the 

parameter is only measured periodically, then you may want to provide the most recent 

measurement. 
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and paper mills. The EPA is considering standards that could apply during startup and shutdown events (or whether 

the current standards developed for normal operation should apply) in light of the December 2008 vacatur of the 

NESHAP startup, shutdown, and malfunction exemption in 40 CFR Part 63, subpart A. The startup and shutdown 

questions would also identify pulp and paper emission unit types for which startup and shutdown are not already 

addressed with the current emission standards. You are asked to supply information for routine startup and 

shutdown events associated with planned process or mill downtime. (Do not provide information for unplanned 

startup/shutdown events associated with equipment malfunctions.) The startup and shutdown data in the PIII Equip 

detail tab are being sought for regulatory development purposes and will not be used for enforcement purposes. 

b. PIII Permit limits tab

Permit limits for each emission unit/point listed in Attachment 1 of this document are requested. You do not need to 

complete this section if you provided the Part III emission unit permit limits in your response to Part I (simply mark 

the box that appears in cell F3 of the PIII Permit limits tab to indicate permit limits were submitted under Part I).

If available in the permit, provide limits in terms consistent with the suggested units shown in Table 2 below. These 

suggested units were taken from existing Federal limits codified in 40 CFR Part 60, subpart BB or 40 CFR Part 63,

subparts S or MM. Specify permit limits as written in the permit if the suggested units are not included in the 

permit. You do not need to convert limits to the suggested units. You may specify limits for a given pollutant in 

multiple units/formats (e.g., ppmdv and/or % reduction) if the permit is written to include multiple compliance 

options. However, you do not need to provide every unit/format for pollutants with multiple limits in different units 

of measure or formats (e.g., only provide ppmdv and gr/dscf at specified % oxygen (O2) for a combustion unit SO2

limit specified in the permit in terms of ppmdv, lb/hr, lb/day, and tpy, gr/dscf at specified % O2, etc.). The survey 

spreadsheet allows for up to five different permit limit formats for the same pollutant. Permit limits of most interest 

to EPA are concentration limits (ppmdv, gr/dscf, etc.), percent reduction, mass per unit production (lb/ton of 

material throughput, etc.) because these limits can be compared from facility to facility independent of emission unit 

or mill capacity. Mass emission rate limits (lb/hr or tpy) are not being requested unless this is the only way in which 

limits are specified in the permit. Please note:

Permits restating NESHAP and NSPS limits. Your permit may simply restate the emission limits contained 

in Federal rules such as NESHAP subparts S and MM and NSPS subparts BB or Db. Some permits may 

list all of the compliance options contained in the Federal rules as permit limits. If this is the case, you do 

not need to enter permit limits that are exactly the same as Federal NESHAP or NSPS. Instead, specify the 

applicable Federal rule (not the specific numeric Federal limits) in Column F and skip the remaining permit 

questions/columns in the table. If your permit contains additional State limits in terms other than the 

Federal limit, please indicate these limits in the appropriate column (e.g., Column G for permit limit 1, 

Column J for permit limit 2, etc.) Please do not enter State lb/hr or tpy emission limits in addition to the

Federal limits.

Opacity. The opacity limits of most interest to EPA are those for fuel fired equipment such as recovery 

furnaces, semichemical combustion units, lime kilns, boilers, and thermal oxidizers. You do not need to 

include State opacity limits for every emission unit (only the fuel-fired units).

EPA will use the permit limit information you supply in comparing permit limits across similar emission units 

nationwide. Please be as specific as possible when entering permit limit units. Include any oxygen correction 

factors (% O2). Be sure to note if ppm values are on a dry (d) or volume (v) or weight (w) basis if specified this way 

in your permit (ppmdv, ppmdw, ppmv, ppmw). 

While we would prefer to receive data in the PIII Permit limits tab, we will accept a copy of your operating permit 

(e.g., title V operating permit) instead of the completed PIII Permit limits tab. Other complete and up-to-date 

summaries of permit limits, such as a mill-specific summary of permit limits or compliance matrix, would be 

acceptable as well. 
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Table 2. Suggested Units of Measure for Permit Limits

Pollutant Suggested units

PM1 Recovery furnaces/chemical recovery combustion units: gr/dscf @ 8% O2

SDT: lb/ton BLS

LK: gr/dscf @10% O2

Other processes: lb/ton of throughput, lb/MMBtu, gr/dscf, g/dscm, or specify

PM10

1

PM2.5

1

Opacity % (provide averaging time)

TRS RF/combustion units: ppmdv @ 8% O2

SDT: lb/ton BLS (as H2S)

LK: ppmdv @ 10% O2

Other processes: lb/ADT pulp and/or ppmdv

SO2 lb/MMBtu and/or ppmdv or limits on fuel S content

NOX lb/MMBtu (as NO2) or ppmdv

CO lb/MMBtu or ppmdv

Pb or other HAP metals Specify units

VOC lb/{production}, specify if as propane, etc. or ppmdv

THC Report as carbon. 

RF/combustion units: lb/ton BLS

HCl ppmdv and/or % reduction

Methanol and gaseous organic 

HAP

chemical recovery combustion sources: lb/ton BLS

process sources: ppmv @ 10% O2, lb/ton ODP, and/or percent reduction

Chlorine and chlorinated HAP ppmv, lb/ton ODP, and/or percent reduction 

Other speciated HAP (specify...) Specify units

1

Specify filterable and/or condensable if your permit limits distinguish between the filterable and condensable PM 

fractions.

c. PIII Controls tab

Complete the Controls tab by following the instructions in the “Instruction” row for add-on APCDs used to control 

pulp and paper emission units. The data requested in the Controls tab include pertinent control device design 

parameters that will be used by EPA to distinguish among control devices (e.g., pressure drop and L/G ratio can be 

used to identify high- vs. low-efficiency wet scrubbers) and to understand the non-air environmental impacts 

associated with the control devices (e.g., amount of wastewater or solid waste generated and methods for handling). 

Baghouses, cyclones, and other material handling equipment. The EPA is most interested in details for control 

systems used to reduce HAP emissions (for equipment in the NESHAP source categories) and criteria air pollutant 

emissions from equipment in the NSPS subpart BB source category. You do not need to include the specific details

requested in the Controls tab for control devices used solely for wood/material handling operations (e.g., baghouses 

or cyclones on pneumatic wood handling systems, etc.).

Control efficiency. Actual control efficiencies are requested for PM, TRS, HCl, SO2, and other HAP. This 

information will be used in determining the capability of different control devices for reducing emissions. If you 

have data from inlet/outlet emissions testing used to determine a percentage reduction in the requested pollutant 

across the control device, then you would enter this test result as the “actual” control efficiency. Leave the control 

efficiency columns blank if actual control efficiency is not known (or not applicable for a given pollutant). 

Thermal oxidizers. Questions pertaining to thermal oxidizers are included in both the Controls and PIII Equip detail

tabs. The PIII Equip detail tab contains questions about heat input capacity, equipment incinerating NCG or SOG,

and primary or supplemental fuels.
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Control device startup and shutdown. The EPA is considering standards that could apply during startup and 

shutdown events (or whether the current standards developed for normal operation should apply) in light of the 

December 2008 vacatur of the NESHAP startup, shutdown, and malfunction exemption in 40 CFR Part 63 subpart 

A. Questions pertaining to control device startup and shutdown are asked in order to provide EPA with an 

understanding of the duration and definition of startup and shutdown events for the types of control devices used at 

pulp and paper mills. The EPA is seeking information on the integral nature of startup and shutdown events for the 

different combinations of emission units and control devices used in the pulp and paper industry. In addition, 

because Federal NSPS and NESHAP require continuous monitoring of emissions or control device operating 

parameters, information is requested to inform EPA of particular pulp and paper NSPS or NESHAP control device 

parameter limits that cannot feasibly be met during startup and shutdown events. Certain parameters may be 

"instant on" while others are more transient in nature (i.e., changing as startup or shutdown progresses). Examples 

could include control device temperature that must heat up to a set point, or pressure drop that cannot be achieved 

due to low exhaust gas flow from the emission unit. The EPA will use this information to evaluate which existing 

control device parameter limits may remain in effect during startup and shutdown events, and which parameter 

limits may need to be replaced with another requirement during startup and shutdown. In all of the control device 

startup and shutdown questions, you are asked to supply information for routine startup and shutdown events

associated with planned equipment or mill downtime. (Do not provide information for unplanned startup/shutdown 

events associated with equipment malfunctions.) The startup and shutdown data in the Controls tab are being 

sought for regulatory development purposes, and will not be used for enforcement purposes. 

d. PCC tab

Mills that route lime kiln, boiler, or other process exhaust to a precipitated calcium carbonate (PCC) plant should 

complete the PCC tab. Information regarding the pulp and paper emission units involved, time, controls, and 

portion of pulp and paper process exhaust routed to the PCC plant are requested. Questions regarding land 

ownership and permitting are also asked. This information would help regulation writers understand the nature of 

this process and the relationship between pulp and paper mills and PCC plants, should routing of exhaust to an 

onsite PCC plant need to be mentioned (e.g., with a special provision, exemption, etc.) in a regulation.

Complete the PCC tab by following the instructions in the “Instruction” row.

D2. Test data

Attachment 2 of this Part III survey contains a table of emission units and pollutants for which existing emissions

data are requested. Emissions data are being requested in the form of emissions test reports or continuous emissions 

monitoring data, whichever may be available. You are not required to conduct any new emissions testing or 

continuous emissions monitoring to respond to this survey. Follow the instructions below for the “Emissions test 

data tab” for emissions test reports. Follow the instructions for completing the “CEMS data spreadsheet (P&P 

CEMS_PIII.xls)” if you have continuous emissions monitoring system (CEMS) data instead of emission test reports 

for a given emission unit and pollutant combination. The emissions test data collected will provide valuable 

information on current emissions levels and will allow EPA to consider variability in emissions from mill to mill 

(and over time for a given emission unit and pollutant) in reviewing and setting emission standards. When 

submitting test data, EPA is requesting full test reports with field and lab data sheets and example calculations, not 

just summary reports.

a. PIII Emissions test data tab

Attachment 2 of this survey contains a table of emission units and pollutants for which existing emission test data

are requested. You are not required to conduct any new emissions testing to respond to this survey. The EPA is 

only requesting existing emission test reports at this time as they may already be available. 

Review the test data request table in Attachment 2 of this survey. Locate any existing emissions test reports in your 

files that match the test method and other criteria for each emission unit and pollutant combination requested. 
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Emissions test data representative of your current operations are requested. You are not required to supply 

emissions data that are no longer representative of the current emission unit and control system configuration. For 

example, if you have installed controls or made significant process changes expected to change emissions, then you 

need not supply emissions data for the prior configuration. However, you may voluntarily supply emissions data for 

prior configurations, as such information would be useful to EPA in characterizing emissions in general (for nonsite-specific uses), but we request that you identify that such data are no longer representative in the PIII Emissions 

test data tab.

Cutoff dates are provided in Attachment 2 for certain emission unit and pollutant combinations. More recent cutoff 

dates (e.g., 2001 or date of MACT compliance) are specified for emission unit and pollutant combinations expected 

to be widely available. Longer cutoff dates (e.g., dating back to 1990) are included for emission unit and pollutant 

combinations for which data are likely to be sparse. Test data prior to the cutoff dates are requested only if 

necessary to obtain results of at least one representative test for a given process unit and pollutant.

Provide available test data for multiple years dating back to the cutoff date. Multiple years of test data will allow 

EPA to examine and account for variability in emissions in setting emissions standards. 

Supply both APCD inlet and outlet data if available. 

As noted above, submit full and complete copies of the emission test reports, to include field and lab data sheets and 

example calculations, meeting the criteria in Attachment 2 with your survey response. Electronic (pdf) or hard 

copies are acceptable. Include the summary portion of the report and any appendices showing run-by-run test 

parameters, method detection limits, laboratory data, production data, example calculations, etc. EPA will extract 

the test data from the emission test reports for use in nationwide regulatory analyses.

Complete the PIII Emissions test data tab to identify the specific emission units and control systems for which 

emission test reports are being submitted, the pollutant tested, and the test method. The PIII Emissions test data tab 

will be used by EPA as the starting point for development of the emissions test data base that EPA intends to

construct based on the emissions test data received through this survey.

b. CEMS data spreadsheet (P&P CEMS_PIII.xls)

The EPA is requesting existing CEMS data and/or continuous opacity monitoring system (COMS) data for calendar 

year 2009 (CY2009) operations from facilities that have installed continuous monitoring systems. You are not

required to install or operate any new CEMS or COMS to respond to this survey.

CEMS data that are representative of your current operations are requested. You are not required to supply CEMS 

data that are no longer representative of the current emission unit and control system configuration. 

You do not need to supply CEMS data for power boilers unless the boiler has a CEMS installed to show compliance 

with a NESHAP subpart S (or subpart MM) or NSPS subpart BB emission limit. 

A separate Microsoft Excel spreadsheet file (P&P CEMS_PIII.xls) is provided for submittal of the requested CEMS 

data. The spreadsheet file contains individual worksheets (tabs) designed specifically for TRS (12-hour block 

average), TRS (hourly), Opacity, NOx, SO2, CO, Methanol, Chlorine, and PM. Each worksheet is designed to 

accommodate data from one CEMS (including oxygen data). If you have multiple CEMS of the same type (e.g., 

two TRS CEMS on different emission units), then you must copy the relevant worksheet in order to enter data for 

the additional CEMS.

A brief introduction to each of the CEMS worksheets follows. Additional, field-specific instructions are included on 

each worksheet. An “EXAMPLE” completed worksheet is also provided as a separate tab within the P&P 

CEMS_PIII.xls spreadsheet file.
Part III Form Approved __/__/__

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TRS (12-Hour Average). This worksheet is designed for recovery furnaces, smelt dissolving tanks, lime 

kilns, digester systems, brown stock washer systems, multiple effect evaporator systems, and condensate 

stripper systems subject to the TRS monitoring requirements in NSPS subpart BB, but can be used for any 

emission units with TRS CEMS (e.g., for compliance with State emissions standards which may be based on 

the TRS emissions guidelines). Respondents are requested to specify the Emission Unit ID (or Collection 

system ID), the APCD_ID, and report the 12-hour averages of CEMS concentration data for TRS for 

CY2009 operations. In addition, respondents are asked to provide the highest single 12-hour average TRS 

concentration recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or 

shutdown, and (c) under malfunction conditions. [Note: The reported concentrations of TRS should be 

corrected to 8% O2 for recovery furnaces and 10% O2 for lime kilns and other equipment.]

TRS (1-Hour Average). Same as above, except that this worksheet is designed to accept the 1-hour average 

TRS data for the sametime period as provided for the 12-hour averages.

Opacity. This worksheet is designed for recovery furnaces or lime kilns equipped with COMS but may be 

used for thermal oxidizers and other equipment. Respondents are requested to specify the Emission Unit ID 

(or Collection system ID) and the APCD_ID, and report the 6-minute average opacity for CY2009

operations. An optional column is also included for hourly average opacity for mills that calculate an hourly 

average. In addition, respondents are asked to provide the highest single 6-minute average opacity recorded

in CY2009: (a) under normal operating conditions, (b) under conditions of startup or shutdown, and (c) under 

malfunction conditions. 

NOx, SO2, and CO. These worksheets are designed for recovery furnaces or lime kilns equipped with CEMS 

for NOx, SO2, or CO, but can be used for other emission units equipped with these CEMS. Respondents are 

requested to specify the Emission Unit ID (or Collection system ID) and the APCD_ID (or type of 

combustion controls used), and report the 1-hour averages of the CEMS data for these compounds for 

CY2009 operations. In addition, respondents are asked to provide the highest single 1-hour average 

concentration recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or 

shutdown, and (c) under malfunction conditions. 

Total HAP or Methanol. This worksheet is designed for total HAP or methanol CEMS installed to 

demonstrate compliance with the NESHAP subpart S limits for LVHC systems, HVLC systems, or steam 

strippers (but can be used for other emission units equipped with these CEMS). Respondents are requested 

to identify by Emission_Unit_ID (or Collection system ID) the source of NCGs/SOGs being controlled, 

specify the APCD_ID, and report the 1-hour averages of the CEMS data for CY2009 operations. In addition, 

respondents are asked to provide the highest single 1-hour average recorded in CY2009: (a) under normal 

operating conditions, (b) under conditions of startup or shutdown, and (c) under malfunction conditions.

Total Chlorinated HAP or Chlorine. This worksheet is designed for total chlorinated HAP or chlorine CEMS 

installed to show compliance with the NESHAP subpart S limits for bleaching systems (but can be used for 

other emission units equipped with these CEMS or HCl CEMS). Respondents are requested to indicate the 

Emission Unit ID (or Collection system ID) being controlled and APCD_ID, and report the 1-hour averages 

of the CEMS data for CY2009 operations. In addition, respondents are asked to provide the highest single 

1-hour average recorded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or 

shutdown, and (c) under malfunction conditions.

PM. This worksheet is designed for any emissions unit equipped with a PM CEMS. Respondents are 

requested to specify the Emission Unit ID (or Collection system ID) and the APCD_ID, and report the 1-hour 

averages of the CEMS data for CY2009 operations. In addition, respondents are asked to provide the highest 

single 1-hour average concentration recorded in CY2009: (a) under normal operating conditions, (b) under 

conditions of startup or shutdown, and (c) under malfunction conditions. 
Part III Form Approved __/__/__

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OPTIONAL-CEMS cost. Completion of this worksheet is OPTIONAL. This worksheet requests equipment 

cost data for CEMS or COMS installed within the past 10 years. EPA can use these data to estimate costs of 

CEMS or COMS when evaluating monitoring options.

What if my data are not in a form that can be inserted into P&P CEMS_PIII.xls? 

It is very helpful for EPA’s data analysis purposes if data are entered into the P&P 

CEMS_PIII.xls template provided. However, we understand that some CEMS software may 

not be configured to provide output that can be easily converted to our preferred spreadsheet 

format. We also understand that, in some cases, the hourly production data requested in the 

CEMS spreadsheet may not be coupled with the CEMS data or may not be available in a 

manner to be easily linked to the CEMS data. If you face these or related issues, please note 

that EPA is not asking you to hand enter hard copy CEMS data into the spreadsheet. You may 

provide CEMS data in an alternative format if you are unable to convert it to our spreadsheet 

format within the timeframe for this survey. We request that you provide CEMS data in a form 

suitable for analysis if possible (e.g., spreadsheet or data base format is preferred over read-only 

pdf format). We’d accept more recent CEMS data (e.g., from the most recent 6 months) if 2009 

CEMS data are no longer in electronic form due to company records retention policies. Further, 

you may omit the production data if they cannot reasonably be included in your CEMS 

spreadsheet. Estimates of production data are acceptable (e.g., if you have a daily production 

rates, you may divide by 24 operating hours in a day to estimate hourly production). 
Part III Form Approved __/__/__

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D3. Optional cost data

The EPA requests information related to the capital and operating costs of selected air pollution controls or 

process/equipment changes. Providing this cost information to EPA is optional at this time. The Agency wishes to 

receive enough cost information on a voluntary basis to perform regulatory analyses. However, should additional 

cost information be needed, EPA reserves the right to follow up with mills that have installed equipment or 

implemented process changes of interest to request cost information under CAA section 114 authority. 

The spreadsheet entitled “P&P costs OPTIONAL_PIII.xls” can be completed to provide cost information. This 

spreadsheet contains two tabs (APCD costs and Equip change costs). The EPA recognizes that cost information can 

be sensitive. The “P&P costs OPTIONAL_PIII.xls” spreadsheet contains a red block at the top of each tab where 

you can indicate if the tab contains CBI, or if the entire tab should be treated as CBI. Responses containing CBI 

should be submitted according to the instructions in section C2 of this document.

Any cost information that you provide would be very useful to EPA for purposes of evaluating the costs of control 

measures that may be considered as regulatory options. These cost data will be used by EPA to estimate the 

nationwide costs of any regulatory options based on the control measure indicated. Cost information from within

the last 10-12 years is requested (e.g., costs dating back to 1998). The cost information could come from vendor 

quotes for APCD or equipment changes that either have been implemented or were explored but not implemented.

For Part III, the EPA is particularly interested in costs of the following APCDs. Please supply this information 

using the APCD costs tab:

 - Recovery furnace scrubbers, dry sorbent injection/fabric filter (DI/FF), selective catalytic reduction (SCR), or 

selective non-catalytic reduction (SNCR)

 - Black liquor oxidizer incinerators or thermal oxidizers

 - Lime kiln ESP

The EPA is particularly interested in costs of the following process changes or equipment changes/upgrades. Please 

supply this information using the Equip change costs tab.

 - Changing from a direct contact evaporator (DCE) to non-direct contact evaporator (NDCE) recovery furnace

 - Changing from a wet bottom ESP to a dry bottom ESP

 - Changing from a wet PM return system to a dry PM return system for your ESP

 - Adding chambers/fields to an existing ESP 

 - Installation of quaternary air ports in the recovery furnace to improve combustion efficiency

 - Process changes to improve lime mud washing or to control makeup water quality in the causticizing area

 - Replacing a recovery furnace with a black liquor gasification system

Complete the APCD costs and Equip change costs tabs by following the instructions in the “Instruction” rows of 

those tabs. You may also submit information in an alternative format (e.g., as an attachment to your response) if 

needed. Because the cost data will be used by EPA to estimate the nationwide costs, please note if you believe that 

any portion of the cost information that you supply would be completely unrepresentative of costs that other mills 

may face for similar control projects (e.g., if your project capital cost included installation of extra buildings, land 

purchases, etc. that may not be required for other mills). 

 
Part III Form Approved __/__/__

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PART III - ATTACHMENT 1

Emission Units to Include in the Part III Pulp and Paper Survey Response

Include the following types of equipment (emission units) in your Part III survey response. You may not operate all 

of the emission units listed below. Only include equipment operated at your mill. 

Chemical Recovery Combustion Equipment

Recovery furnace

Semichemical combustion unit 

Black liquor oxidation system

Smelt or ash dissolving tank

Lime kiln or calciner 

Black liquor gasification system

Sulfur burner
Part III

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PART III - ATTACHMENT 2

Part III Emissions Test Data Request

(Note: Test Reports submitted should be full and complete copies of the emission test reports, to include field and 

lab data sheets and example calculations.)
Part III Form Approved __/__/__

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Part III - Attachment 2. Pulp and Paper Emission Units and Pollutants for Which Existing Representative Emission Test Data Are Requested

Note: Emissions test data representative of your current operations are requested as described in the survey instructions.

Emission Unit Particulate 

matter 

(PM)1

Speciated 

HAP metals2

PM2.5 

(fil.)

PM2.5 

(cond.)

Chlorinated 

HAP (Cl)1

Hydrochloric 

acid (HCl)

Acetaldehyde, 

Formaldehyde, 

Methanol1

Total 

hydrocarbon 

(THC) as 

carbon

CDD/CDF

and

POM/PAH

Total 

reduced 

sulfur 

(TRS)1,3

Nitrogen 

oxides 

(NOx)1

Sulfur 

dioxide 

(SO2)

1

Carbon 

monoxide 

(CO)1

Test methods4 M5, M29, 

M17

PM CEMS, 

COMS

M29 EPA 

OTM 

27

EPA

OTM 28

Chlorine (Cl2) 

via M26A 

with 

modifications 

described in 

subpart S

Cl2 CEMS

M26 or 26A Methanol: 

Method 308 

(part 63); 

Methanol 

CEMS; or 

Other 

applicable 

methods

M25 or 

M25A

M23 M16 or

TRS CEMS

Provide total 

TRS data. 

Also provide 

speciated 

TRS data, if 

available.

M7

CEMS

M6

CEMS

M10

CEMS

Recovery 

furnaces (NDCE 

and DCE)

Supply data 

from 2001 

and more 

recent 

following 

subpart MM 

MACT 

compliance

Supply data 

from 1990 or 

more recent

Supply 

most 

recent 

data

Not requested Supply data 

from 1990 or 

more recent

Supply any

CDD or 

POM data 

and note if 

equipment 

config. has 

changed

Supply most 

recent data

Black liquor 

oxidizer (BLO)

Note: The BLO 

vent is included 

in definition of 

DCE, but listed 

separately in case 

data are available 

for only the 

BLO)

Not 

requested

Supply data 

from 1990 or 

more recent

Not 

requested

Supply most 

recent data

Not 

requested

Chemical 

recovery 

combustion units 

- sulfite

Supply data 

from 2001 

and more 

recent 

following 

subpart MM 

MACT 

compliance

Supply data 

from 1990 or 

more recent

Supply 

most 

recent 

data

Not requested

Supply data 

from 1990 or 

more recent

Not 

requested

Supply 

most 

recent 

data
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Emission Unit Particulate 

matter 

(PM)1

Speciated 

HAP metals2

PM2.5 

(fil.)

PM2.5 

(cond.)

Chlorinated 

HAP (Cl)1

Hydrochloric 

acid (HCl)

Acetaldehyde, 

Formaldehyde, 

Methanol1

Total 

hydrocarbon 

(THC) as 

carbon

CDD/CDF

and

POM/PAH

Total 

reduced 

sulfur 

(TRS)1,3

Nitrogen 

oxides 

(NOx)1

Sulfur 

dioxide 

(SO2)

1

Carbon 

monoxide 

(CO)1

Chemical 

recovery 

combustion units 

- stand alone 

semichemical

Supply data 

from 1990 

or more 

recent

Supply 

most 

recent 

data

Not requested

Supply data 

from 1990 or

more recent

Not 

requested

Supply 

most 

recent 

data

Smelt dissolving 

tanks (SDT) or 

ash dissolving 

tanks

Supply data 

from 2001 

and more 

recent 

following 

subpart MM 

MACT 

compliance

Supply data 

from 1990 or 

more recent

Supply 

most 

recent 

data

Not requested

Supply data 

from 1990 or 

more recent

Supply most 

recent data

Not 

requested

Lime 

kilns/fluidized 

bed calciners

Supply data 

from 2001 

and more 

recent 

following 

subpart MM 

MACT 

compliance

Supply data 

from 1990 or 

more recent

Supply 

most 

recent 

data

Not requested

Supply data 

from 1990 or 

more recent

Supply most 

recent data

Black liquor 

gasification 

systems

Supply 

most recent 

data

Not requested Supply most 

recent data

1

If your emission unit is equipped with a continuous emissions monitoring system (CEMS) or continuous opacity monitoring system (COMS), supply the CEMS data using the CEMS data spreadsheet (P&P 

CEMS_PIII.xls)

2 The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chromium VI (Cr+6) and speciated mercury (Hg) test data if 

available.

3

Speciated TRS would include: hydrogen sulfide (H2S), methyl mercaptan, dimethyl sulfide, and dimethyl disulfide.

4 M = method (e.g., M5 is EPA Method 5). EPA Methods 5, 6, 7, 10, 16, 17, 23, 25/25A, 26/26A appear in 40 CFR Part 60, Appendix A. EPA Method 308 appears in Part 63, Appendix A. The “OTM” test 

methods can be found at http://www.epa.gov/ttn/emc/prelim.html