UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

SECTOR POLICIES AND PROGRAMS DIVISION

OFFICE OF AIR QUALITY 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 analyzed for the Risk and Technology

Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

the pulp and paper industry. 

Background1:

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 process 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 emission reductions that would have 

been achieved through compliance with the HVLC system requirements. Mathematically, 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 control 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)2requested 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 significantly 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 

cleaner 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. Baseline 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 40% 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 Steam stripper

NEI11251 Valliant, OK Clean shower water

NEI13340 Halsey, OR

Captured Brownstock 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 wastewater treatment

NEI12492 Orange, TX Reduction of methanol stripped to air at the ASB by installing and 

operating additional aerators

NEI18334 Pennington, AL Stand-alone biological treatment unit

NEI18335 Selma, AL Stand-alone biological treatment unit

NEI18338 Brewton, AL Maintain a minimum of 60% control efficiency in the ASB

NEI18652 Arkansas City, AR Collection 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 Hard-piping additional methanol to ASB treatment system

NEI26309 Cantonment, FL Install 2 primary clarifiers

NEI26471 Macon, GA Maintain 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 Stand-alone biological treatment unit

NEI33023 Hodge, LA

Collection 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 Clean water - shower water flow monitoring, periodic sampling and testing 

for methanol concentration.

NEI34064 Columbus, MS Clean condensate to recaust

NEI34066 New Augusta, MS Stand-alone biological treatment unit

NEI40247 Riegelwood, NC Close recovery boiler and transfer weak black liquor from lagoon to 

storage tank

NEI40600 Toledo, OR Offset HVLC emissions through over-collection and over-treatment of foul 

condensate.

NEI41252 North Charleston, SC Steam 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

Traded 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 Townsend, WA Upgrade ASB

NEI42410 Wallula, WA Stand-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 Stand-alone biological treatment unit

NEI6261 Jay, ME Over collection of foul condensate through the hard-pipe which bypasses 

the primary clarifier (reduces emissions from the primary clarifier).

NEI7559 Deridder, LA Steam stripper

NEI8177 Riceboro, GA Steam stripper

NEI8261 Fernandina Beach, 

FL

Replacing the wastewater treatment (WWT) cooling tower with noncontact heat exchangers, thereby eliminating HAP emissions from HVLC

NEI8278 Panama City, FL Steam 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 Planning and Standards. EPA-456/R-98-008. November 

1998.

2. Pulp and Paper ICR