**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY** SECTOR POLICIES AND PROGRAMS DIVISION OFFICE OF AIR QUALIT Y PLANNING AND STANDARDS

OFFICE OF AIR AND RADIATION October 20, 2011 MEMORANDUM SUBJECT: Summary

of Clean Condensate Alternative Technology Review FROM: John Bradfield (EPA/OAR/OAQPS/SPPD/NRG)

Kelley Spence (EPA/OAR/OAQPS/SPPD/NRG) TO: Docket EPA
- HQ
- OAR
- 2007
- 0544 This memorandum summarizes the technology review of the Clean Condensate Alternative (CCA) in pulp mills subject to 40 CFR 63, subpart S anal yz ed for the Risk and Technology Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the pulp and paper industry
. **Background** 1 **:** The clean condensate alternative (CCA) is a pollution prevention alternative emission limit for pulping vents that is available only to kraft HVLC systems (which includes washers, knitters, screens, deckers, and oxygen delignification)
. The CCA allows mills to meet the HVLC emission requirements by reducing the HAP emissions elsewhere, usually p rocess water . This approach allows mills to control HAP emissions by reducing the amount of HAPs that are volatilized from selected process equipment instead of using combustion devices to control HVLC system vent streams. In a classic example, HAP condensates in paper machine process water are removed. By reducing the HAP concentration in process water, the amounts of volatilized HAPs are also reduced. To achieve compliance, the facility must demonstrate that the HAP emission reductions using the CCA technology are equal to or greater than those emissi on reductions that would have been achieved through compliance with the HVLC system requirements. Mathematicall y, the mass of emissions required for control on HVLC sources creates a debit. The sum of the debits must be offset by

an equal or greater number of credits achieved by c ontrol of the selected alternative emission source. The baseline emission value against which emission credits are measured must be determined after compliance has been achieved with the kraft pulping process condensate standards, and the revised effluent limitations guidelines and standards in 40 CFR 430 subpart BB.The CCA allows mills to take credit for emission reductions achieved in several systems

through the use of CCA technologies. The sources from which emission reductions can be debited or credited are limited to the following: pulping systems (HVLC), bleaching systems, causticizing systems, and papermaking systems. The CCA emission reductions are generated either by control of condensates that are not regulated under the kraft pulping condensate standard or control beyond the levels required by the condensate standard. **Developments in Practices, Processes, and Control Technologies** The Information Collection Request (ICR) 2 requested that facilities utilizing CCA provide their baseline emissions (debits), their CCA emission reductions (credits) and a process description. The CCA emission reduction value requested was defined as: HAP emission reductions from baseline. Out of 175 survey

responses from major sources, 38 facilities responded as CCA facilities. Compliance approaches ranged significantl y between the facilities, but included steam strippers, clean washer showers, hard
-piping, stand
- alone biological treatment, whitewater temperature and HAP content monitoring, and over- collection and over- treatment of condensates , as shown in Table 1
. Of the predominant compliance methods, 6 utilized steam stripping, 15 utilized wastewater treatment (1 facility utilizing dredging and 5 utilizing hard
- piping), and 5 utilized c leaner water practices on paper machines. Using the survey

data, EPA compared the baseline HAP reduction required by subpart S with the reductions achieved using the CCA approach. B aseline control at the 38 CCA mills would have resulted in base emissions of approximately 31 kg HAP per ODTP (oven
- dried ton pulp). The nationwide HAP emissions achieved through use of CCA at these 38 mills was approximately 16 kg HAP per ODTP . Thus, the CCA achieved a 50% reduction in HAPs on a kg HAP per ODTP basis beyond what would have been required through HVLC vent gas incineration under subpart S. Based on available production values, the CCA compliance option resulted in approximately 4 0% lower total emissions on a tons per year basis than compliance with subpart S utilizing HVLC vent gas incineration. Due to the broad scope of practices, processes, and controls that were used to generate credits, our technology

review did not elucidate any developments or advances in HAP control at CCA sources.**Table 1: Summary of CCA technologies from ICR part 1 review**

**Facility NEI ID**  **Facility Location CCA Technology**  NEI11172 Monticello, MS S team stripper NEI11251 Valliant, OK Clean shower water NEI13340 Halsey, OR C aptured Brow nstock washers and decker exit gases. Installed low flow hoods on brownstock washers. The decker is not required to be collected but it is a large source of methanol. Gases sent to a methanol scrubber and then sent to the waste water treatment NEI12492 Orange , TX Reduction of methanol stripped to air at the ASB by installing and operating additional aerators NEI18334 Pennington, AL S tand
- alone biological treatment unit NEI18335 S elma, AL S tand
- alone biological treatment unit NEI18338 Brew

ton, AL Maintain a minimum of 60% control efficiency in the ASB NEI18652 Arkansas City, AR C ollection and hard
-piping of additional pulping process condensates from the evaporator and pre
- evaporator areas of the mill NEI18658 Pine Bluff, AR Closed collection system, hard
-piping to WWT and discharged below liquid surface for biological treatment NEI18660 Ashdown, AR H ard
-piping additional methanol to ASB treatment system NEI26309 Cantonment, FL Install 2 primary clarifiers NEI26471 Macon, GA M aintain paper machine white water temperature to equal to or less than 185 degrees F to ensure volatilization of methanol is minimized. NEI26491 Cedar Springs, GA Installation of foam tank fog nozzles and barometric condenser to minimize methanol losses NEI26526 Jessup , GA Rerouted hard
-piped Subpart S regulated condensates to subsurface injection in the Mill's No. 1 Aeration Stabilization Basin and installed additional curtains, aerators, and mixers to further segment the basin's treatment stages and increase overall methanol NEI26581 Lewiston, ID S tand
- alone biological treatment unit NEI33023 Hodge, LA C ollection and treatment of flash evaporator condensates with addition to turpentine decanter underflow before routing the stropped condensates to the pulp washing system NEI33025 Campti, LA C lean water
- shower water flow monitoring, periodic sampling and testing for methanol concentration. NEI34064 Columbus, MS C lean condensate to recaust NEI34066 New

Augusta, MS S tand
- alone biological treatment unit NEI40247 Riegelwood, NC C lose recov ery boiler and transfer weak black liquor from lagoon to storage tank NEI40600 Toledo, OR O ffset HVLC emissions through over
- collection and over
- treatment of foul condensate. NEI41252 North Charleston, SC S team stripper NEI41552 Counce, TN Use fresh water only on last stage of each brown stock washer, maintain paper machine white water MeOH concentration of 15 mg/L or less (28
- day average), and collect pulp mill condensates totaling 7.2 ln/ODTP MeOH and treating to remove at least 6**Facility**

**NEI ID Facility Location**  **CCA Technology** NEI42317 Hopewell, VA T raded use of digester condensate for wash water on brown stock washers with freshwater and digester condensate is collected and hard
-piped to POTW UNOX basin and treated to 92 % control efficiency NEI42338 Longview, WA Additional collection of ~1,500 additional pounds per day (1.0 lb/ODTP), total of >8.2 lb/ODTP of HAPS on 30 day rolling average as measured at hard pipe outlet; destroy additional 1.0 lb/ODTP (>7.6 lb/ODTP)at WW outlet NEI42357 Port Tow

nsend , WA Upgrade ASB NEI42410 Wallula, WA S tand
- alone biological treatment unit NEI42710 Kaukauna, WI Increase condensate treatment NEI45182 Springfield, OR Lock out NCG scrubber underflow from causticizer and condensate from dissolving tank scrubber NEI47091 Perry, FL S tand
- alone biological treatment unit NEI6261 Jay, ME O ver collection of foul condensate through the hard
-pipe which bypasses the primary clarifier (reduces emissions from the primary clarifier). NEI7559 Deridder , LA S team stripper NEI8177 Riceboro, GA S team stripper NEI8261 Fernandina Beach,

FL Replacing the wastewater treatment (WWT) cooling tower with non
contact heat exchangers, thereby eliminating HAP emissions from HVLC NEI8278 Panama City, FL S team stripper NEI8619 Pine Hill, AL Mill water, clean condensates of Kraft Multi
- Effect Evaporator (4th Effect), and stripped condensates are used in pulp washers to reduced methanol carryover to Paper Machine No. 1. NEI9201 Plymouth, NC ASB dredging NEI7933 Florence, SC New steam stripper

**References:** 1. Pulp and Paper NESHAP: A Plain English Description. U.S. Environmental Protection Agency , Office of Air Quality P lanning and Standards. EPA
- 456/R
- 98
- 008. November 1998. 2. Pulp and Paper ICR