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# Pulp and Paper Sector Survey Instructions for Part I II: Chemical Recovery Combustion Sources

11/ 16 /10 This survey overview document provides instructions for completing Part III the p ulp 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. PI II 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
- AT TA CHMENT 1 Emission Units to Include in the Part III Pulp and Paper Survey Response
............. 17 PART III
- AT TA CHMENT 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 hazardou s air pollutant (HAP) emissions that: (a) Perform chemical wood pulping (kraft, sulfite, soda, or semichemical ), or (b) Perform mechanical, groundw ood (e.g., thermomechanical pulping (TMP), refiner mechanical pulping (RMP)), secondary fiber, and non

- wood p ulping, 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 contro l 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 les ser 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 y our mill meets one of the following conditions, then you should have com plete d the form in Attachment 1 of the Survey Overview document and submitted it t o 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 sourc e” 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 fo r 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 compl eted 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). T able 1 below denotes which survey spreadsheet tabs to com plete 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 mo re 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 spr eadsheets, they can be dow nloaded 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 invento ry , 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 stac k, 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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### 3 Use the following attachments to the Survey Overview document for reference: Attachment 2: Regulatory definitions from the kraft pulp mill new sour ce 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 t ab 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 i n 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 CEM S 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 pollutio n controls (see section D3) Equip change costs Mills implementing selected process or equipment changes (see section D3)

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## B. Confidential Business I nformation (CBI) The EPA's procedures for handling confidential business information (CBI) are descri bed 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 spreadshee t response by shading the spreadsheet cell containing the CBI with red highlight and indicat ing 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 conta in CBI. How ever, 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, especia lly information that is readily reported by other mills without such claims
. 

## C. How to S ubmit Your Part III S urvey R esponse 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 t wo different mailing addresses
. 

### C 1 . Submitting Your N on - CBI Response Follo w these instructions for the non

- CBI portions of your survey response (or for responses that are entirely non

CBI.) After you have completed and reviewed your survey response , sign and date the certification form in Attachment 4 of the S urvey O verview doc ument. R emove the CBI com ponents from your survey as instructed in section C2 . Save the Excel spreadsheet (s) containing the non

- CBI portion s of your completed response, emission test reports, and any other electronic non - CBI attachments on the flash driv e 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 materia ls 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. Envi ronm ental 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 us ing return receipt requested, Federal Express, or other method for which someone must provide a signature upon receipt.

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### 5 C 2 . 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 yo ur 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 w ords “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 M r. 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 ar e not secure forms of communication and should never be used to transmit CBI. 

## D. How to Complete the Part III S urvey Your survey response will consist of emission test reports and completed Microsoft Excel spreadsheets. Separate Excel spreadsheet file s 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_PI I I.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. 

### D 1 . Process data (P&P survey_PI II .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_PI II .xls spreadsheet. How ever, 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 m enus for common entries. Use these pull

- down menus whenever possible, or w rite in information if your selection is not contained in the pull

- down menu.

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### 6 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 up date (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 yo ur mill), then you should use “NEW_____” for the NEI Site ID w here 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 yo ur 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 P II I 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 im perative 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 l ink the various pulp and paper data base tables together into a functiona l 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 f low 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 w hen referring to the same piece of equipment in Parts II and III for this survey response. Also, ple ase be sure that no extra spaces or characters are included in th e 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 request ed to inform the technological review of the pulp and paper NE SHAP 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 proc esses employed and matches these details to emissions levels that are achieved (e.g., emission concentrations). A pplicability of the NESHAP and NSPS compliance options depend s on the specific process equipment.

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### 7 Follow the instruction s below

and in the “Instruction” row s 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 b y 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 st andards (i.e., nationwide numbers of equipment, configuration of controls, pertinent equipment details, and regulatory compliance options used). T he types of emission units listed in Attachment 1 that you operate should be included in the PIII Equip detai l tab. Columns A through AM ask generic questions for all emission units. The c olumns 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 dif

ferent types of equipment for which specific questions are included in the PIII Equip detail tab. PIII Equip detail

tab columns Description of inform ation requested

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

collection system. Com

plete 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 com bustion units (at stand

- alone semichemical pulp mills) BO
- BT Sm elt/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 shutdow n . What if I do not know or have the inform ation to answer a survey question? There may be survey questions that you do not know the answer to, or for w

hich 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 yo u 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 relat ed to their survey response.

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### 8 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)
. S pecify 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 un its ducted to a single release point
. L ist 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 s ystem ID for the different Emission Unit ID s. Single emission unit with multiple release points
. Repeat the Emission Unit ID on separate rows and distinguish the relea se 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 di fferent controls . Split EU001 to EU001a and EU001b on separate rows of the PIII Equip detail tab, and then indicate in the “Emi ssion Unit D escription” column that EU001a and EU001b vent through separate stacks. Enter details associated with emission rele ase (APCD information and NSPS/NESHAP compliance options ) in each row . Enter equipment details (year installed, hours per year [ hr/yr ] , com bustion controls, fuel data, equipment design and other operating parameters) in only 1 row , leaving all other row s 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. Emis sion 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 w ith 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 n eed 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 ). By pass 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 (APCD s )
. 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 APC D in the APCD “type” column and an ID code in the APCD_ID column. The ID yo u enter into the APCD_ID field will correspond with the APCD_ID you enter in the Controls tab. For example, I f 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. I f 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), t hen APCD1_ID = WLIQSBR and APCD2_ID = LK2. Emission units routed to another emission unit for emissions control . Enter the Emission Unit ID s for each emission unit being controlled in the Emission Unit ID column. Use the controlling emission unit’s Emis sion Unit ID as the APCD_ID in the APCD columns.

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### 9 Com plete the applicable equipment

- specific details requested in columns A N through DN for each ty pe 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 e quipment requiring instructions beyond what could be explained in the
“ Instruction ” row . Leave c olumns that do not apply for a given emission unit blank.

All emission units listed in Attachment 1 . Comple te 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 A N through D U ma y also apply for selected emission unit types. Recovery furnaces and semi chemical 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 semi chemical 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 com

bustion units in order to characterize the different types of semichemical com bustion units. Sm elt 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 s upplemental fuels
. Fuel types are requested fo r fuel

- fired equipment because fuel type can have an effect on emissions . The EPA may consider fuel types and perform calculations based on fuel firi ng rates for various nationwide impact analy ses. 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 therm al units per year (MMBtu/yr) supplied by each fuel. Primary fuel information is requested for fuel

- fi red equipment su ch as li me kilns and thermal oxidizers . Prim ary fuels are not requested for recovery furnaces or semi chemical c om bustion units because bl ack liquor (or red liquor) is assumed to be th e primary fuel for these units. Non

- condens able gases (NCG) and stripper off gases ( SOG ) are not considered to be either primary o r supplemental fuels for purposes of this survey. Supplemental and other fuel information is requested for recovery furnaces and semi che mical com bustion units in addition to other fuel

- f ired equipment such as lime kilns and thermal oxidizers. Information for s econdary and additional fuels used routinely for multifuel

- fired equipment may be indicated in the supplemental and other fuel columns. Emission unit s tartup and shutdow n . Com plete the startup and shutdown questions for all emission units currently subject to Federal or State emission limits or monitoring requirements. Ques tions 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 use d 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, temp erature, etc. Unless otherwise speci fied, ty pical 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 ye ar, 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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### 10 and paper mills. The EPA is considering standards that c ould apply during startup and shutdow n 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 shutdow n are not already addressed with the current emission standards. You are asked to s upply information for routine startup and shutdown events associated with planned process or mi ll downtime. (Do not provide information for unplanned startup/shutdown events associated with equipment malfunctions
. ) The st artup and shutdown dat a in the PIII Equip detail tab are being sought for regulatory development purposes and will not be used for enforcement purposes. b . PI II Permit limits tab Permit limits for each emission unit/point listed in Attachment 1 of this document are reques ted. 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 P art 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. How ever, 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 speci fied % oxygen ( O 2 ) for a combustion unit SO 2 limit specified in the permit in terms of ppmdv, lb/hr, lb/day, and tpy, gr/dscf at specified % O 2 , etc. ). The survey spreadsheet allows for up to five different permit limit formats for the same pollutant. P ermit 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 u nit 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 em ission 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 permi t 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 additio nal 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, semi chemical 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 a ny oxygen correction factors (% O 2 ). Be sure to note if ppm values are on a dry (d) or volume (v) or w eight (w) basis if specified this way in your permit (ppmdv, ppmdw, ppmv, ppmw). While we would prefer to receive data in the P II I Permit limits tab, w e will accept a copy of your operating permit (e.g., title V operating permit) instead of the completed P II I 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 , wo uld be acceptable as w ell.

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### 11 Table 2. Suggested Units of Measure for Permit Limits Pollutant Suggested units PM 1 Recovery furnaces/chemical recovery com bustion units: gr/dscf @ 8% O 2 SDT: lb/ton BLS LK: gr/dscf @10% O 2 Other processes: lb/ton of throughput, lb/MMBtu, gr/dscf, g/dscm, or specify PM 10 1 PM 2.5 1 Opacity % (provide averaging time) TRS RF/combustion units: ppmdv @ 8% O 2 SDT: lb/ton BLS (as H 2 S) LK: ppmdv @ 10% O 2 Other processes: lb/ADT pulp and/or ppmdv SO 2 lb/MMBtu and/or ppmdv or limits on fuel S content NO X lb/MMBtu (as NO 2 ) 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: l b/ton BLS HCl ppmdv and/or % reduction Methanol and gaseous organic HAP chemical recovery combustion sources: lb/ton BLS process sources: ppmv @ 10% O 2 , 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 . P II I Controls tab Com plete the Controls tab by following the instructions in the “ Instruction ” row for add

- on APCD s 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 rati o 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 w aste generated and methods for handling). Baghouses, cyclones , and other material handling equipment
. Th e 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 sour ce category
. You do not need to incl ude the specific detail s requested in the Controls tab for control devices used solely for wood/m aterial handling operations (e.g., baghouses or cyclones on pneumatic wood handling systems, etc
. )
. Control efficiency
. Actual control efficiencies are requested for PM, TRS, HCl, SO 2 , 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 Control s and PIII Equip detail tabs. The PIII Equip detail tab contains questions about heat input capacity, e quipment incinerating NCG or SOG , and prim ary

or supplemental fuels
.

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### 12 Control device s tartup and shutdow n . The EPA is considering standards that could apply during startup and shutdown events (or whether the current standards developed for normal operation should apply) i n 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 duratio n 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 contro l 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 NESH AP 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, y ou are asked to s upply 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 ma lfunctions
. ) The startup and shutdown data in the Controls tab are bein g 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. Informat ion 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 r egulation writers understand the nature of this process and the relationship betw een 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 regulatio n. Com plete the PCC tab by following the instructions in the “ Instruction” row . 

### D 2 . Test data Attachment 2 of this Part III survey contains a table of emission units and pollutants for which existing emission s data are requested. Emissions data are b eing requested in the form of emissions test reports or continuous emissions mo nitoring 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 i nstructions below

for the “Emissions test data tab” for emissions test reports. Follow the instructions for completing the “ CEMS data spreadsheet ( P&P CEMS_PI I I.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 giv en 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 ta b 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 existin g emission test reports at this time as they may already be available
. Revie w 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 e mission unit and pollutant combination requested.

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### 13 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 yo u need no t supply emissions data for the prior configuration. How ever, you may voluntarily supply emission s data for prio r configurations, as such information would be useful to EPA in characterizing emissions in general (for non

site

- specific uses) , but we request that you identify that such data are no longer representative in the PIII Emissions test data tab. C utoff date s are provided in Attachment 2 for certain emission unit and pollutant com binations. 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 cuto ff dates (e.g., dating back to 1990) are included for emission unit and pollutant combinations for which data are likely to be sparse. Test d ata prior to the cutoff dates are requested only if necessary to obtain results of at least one representative tes t 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
. Sup ply both APCD inlet and outlet data if available. As noted above, s ubmit 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. Com plete the PIII Emission s test data tab to identify the specific emission units and control systems for which emission te st reports are being submitted, the pollutant t ested, and the test method. The PIII Emission s 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 emission s test data received through this survey. b. CEMS d ata spreadsheet ( P&P CEMS_PI I I.xls ) The EPA is requesting existin g CEMS data an d/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 emissio n unit and control system configuration. You do not need to supply CEMS data for pow er boilers unless the boiler has a CEMS installed to show com pliance with a NESHAP subpart S (or subpart MM) or NSPS subpart BB emission limit. A separate Microsoft E xcel spreadsheet file ( P&P CEMS_PII I .xls ) i s provided for submittal of the re quested CEMS data. The spreadsheet file contains individual worksheets (tabs) designed specifically for TRS (12

- hour block average), TRS (hourly), Opacity, NOx, SO 2 , CO, Methanol , Chlorine, and PM. Each wo rksheet 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 e nter 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 CE MS_PI I I.xls spreadsheet file
.

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### 14 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 s ubject 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 re quested to specif y the Emission Unit ID (or C ollection system ID) , the APCD_ID, and report the 12

- hour averages of CEM S concentration data for TRS for CY2009 operations . In addition, respondents are asked to provide the highest single 12

- hour average TRS concentration rec orded in CY2009: (a) under normal operating conditions, (b) under conditions of startup or shutdown, and (c) under m alfunction conditions
. [ Note: The reported concentrations of TRS should be corrected to 8% O 2 for recovery furnaces and 10% O 2 for lime kil ns 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 same tim e 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 re quested to specify the Emission Unit ID (or C ollection system ID) and the APCD_ID, and report the 6

- mi nute average opacity for CY 2009 oper ations
. 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 highe st single 6

- minute average opacity recorded in CY2009: (a) under normal operating co nditions, (b) under conditions of startup or shutdow n, and (c) under m alfunction conditions
. NOx, SO 2 , and CO . These worksheets are designed for recovery furnaces or lime kilns equipped with CEMS for NOx, SO 2 , or CO , but can be used for other emission units equipped with these CEMS . Respondents are requested to specify the Emission Unit ID (or C ollection 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 oper ations
. 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 m alfunction conditions
. Total HAP or M ethanol . 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 thes e CEMS) . Respondents are requested to identify by

Emission_Unit_ID (or C ollection 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 ar e asked to provide the highest single 1

- hour average recorded in CY2009: (a) under normal operating conditions , (b) under conditions of startup or shutdow n, and (c) under m alfunction conditions
. Total C hlorinated HAP or C hlorine . This worksheet is desig ned 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 E mission Unit ID (or C ollection 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 s ingle 1- hour average recorded in CY2009: (a) under no rm al operating conditions , (b) under conditions of startup or shutdown, and (c) under m alfunction conditions
. PM . This worksheet is de signed for any emissions unit equipped with a PM CEMS. Respondents are requested to specify the Emission Unit ID (or C ollection system ID) and the APCD_ID , and report the 1

- hour averages of the CEMS data for CY 2009 operatio ns . In addition, respondents are asked to provide the highest single 1

- hour average concentration recorded in CY2009: (a) under normal operating condi tions , (b) under conditions of start

up or shutdown, and (c) under m alfunction conditions
.

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### 15 OPTIONAL
- CEMS cost . Completion of this worksheet is OPTIONAL. This w orksheet 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 formthat ca n 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. How ever, w e understand that some CEMS software may not be configured to provide output that can b e 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 mos t recent 6 months) if 2009 CEMS data are no longer in electronic form due to company records retention policies. Further, yo u may omit the production data if they cannot reasonably be included in your CEMS spreadsheet. Estimates of production data are ac ceptable (e.g., if you have a daily production rates, you may divide by 24 operating hours in a day to estimate hourly production).

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### 16 D3 . Optional cost dat a The EPA requests information related to the capital and operating costs of selected air pollution contro ls 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 ne eded, EPA reserves the right to follow up with mills that have installed equipment or im plemented process changes of interest to request cost information under CAA section 114 authority. The spreadsheet entitled “P&P costs OPTIONAL_PIII .xls” can be comp leted 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 yo u 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 C 2 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 y ears is requested (e .g., costs dating back to 1998). The c ost information could come from vendor quotes for APCD or equipment changes that either have been implemented or w ere explored but not implemented. F or Part III, the EPA is particularly interested in costs of the following APCD s . Please supply this informati on 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 syste m 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 ma keup w ater quality in the causticizing area

- Replacing a recovery furnace with a black liquor gasification system Com plete 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 supp ly w ould 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 n ot be required for other mills)
.

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### 17 PA RT III - ATTACHMENT 1 Emission Units to Includ e in the Part III Pulp and Paper Survey Response Include the following types of equipment (emission units) in y our P art III survey response. You may not operate all of the emission units listed below
. Only i nclude equipment operated at your mill. Chemical Recovery Combustion Equipment R ecovery furnace Semic hemical com

bustion unit B lack liquor oxidation system S melt or ash dissolving tank L ime kiln or calciner B lack liquor gasification system Sulfur burnerPart III OMB Control No. ____

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### 18 PART III - ATTACHMENT 2 Part III E mi ssions 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 cal culations
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### 19 Part III - Attachment 2. Pulp and Paper E mission U nits and P ollutants for W hich E xisting R epresentative E mission T est D ata A re R equested

Note: Emissions test data representative of your current operations are requested as described in the sur vey instructions. Emission Unit Particulate

matter (PM) 1 Speciated

HAP metals 2 PM 2.5

(fil.) PM 2.5

(cond. ) Chlorinated

HAP (Cl) 1 Hydrochloric

acid (HCl) Acetaldehyde,

Formaldehyde, Methanol 1 Total

hydrocarbon (THC) as carbon CDD/CDF

and POM/PAH Total

re duced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 1 Carbon

monoxide (CO) 1 Test methods 4 M5, M29,

M17 PM CEMS, COMS M29 EPA OTM 27 EPA OTM 28 Chlorine (Cl 2 )

via M26A with modifications described in subpart S Cl 2 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 fu rnaces (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 fo r 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 N ot requested Supply

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### 20 Emission Unit Particulate

matter (PM) 1 Speciated

HAP metals 2 PM 2.5

(fil.) PM 2.5

(cond. ) Chlorinated

HAP (Cl) 1 Hydrochloric

acid (HCl) Acetaldehyde,

Formaldehyde, Methanol 1 Total

hydrocarbon (THC) as carbon CDD/CDF

and POM/PAH Total

re duced sulfur (TRS) 1,3 Nitrogen

oxides (NOx) 1 Sulfur

dioxide (SO 2 ) 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 dat a 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 rece nt 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 monito ring system (COMS), supply the CEMS data using the CEMS data spreadsheet (P&P CEMS_PI I I.xls ) 2 The HAP metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. Include chromium VI (Cr+6 ) and s peciated mercury (Hg) test data if available. 3 Speciated TRS would include: hydrogen sulfide (H 2 S), 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