National Emission Standards for Hazardous Air Pollutants for Source Category: Pulp and Paper Production

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 63

[AP-FRL-5437-6]

RIN 2060-AE04

National Emission Standards for Hazardous Air Pollutants for

Source Category: Pulp and Paper Production

AGENCY: Environmental Protection Agency (EPA).

ACTION: Announcement of availability of supplemental information,

proposed rule, and opening of the public comment period for these

actions.

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SUMMARY: This action presents an assessment of supplemental information

on 1993 proposed National Emission Standards for Hazardous Air

Pollutants (NESHAP) for the Pulp and Paper Production Source Category

and announces proposed additional sources in that source category not

covered by the 1993 proposed standards. These additional sources

include mechanical mills, secondary fiber mills, nonwood fiber mills,

and paper machines. This action also announces availability of data for

public review that is in addition to data previously announced in a

February 22, 1995 Notice of Data Availability (60 FR 9813). In

addition, this action announces the availability and requests comments

on new emission factors developed using that data.

This action sets forth the most significant changes EPA is

considering, but is not inclusive of all changes likely

[[Page 9384]]

to be made on the 1993 proposed NESHAP. EPA is still considering other

comments submitted on the 1993 proposed NESHAP and will combine them

along with comments and data received on this action to form the basis

for the promulgation of a final NESHAP later this year. Proposed NESHAP

for the chemical recovery area combustion sources at mills are not

contained in this action, but will follow in a separate action later

this year.

DATES: Comments are requested only on information presented in this

action. Comments must be received on or before April 8, 1996, unless a

public hearing is requested by March 18, 1996. If a hearing is

requested, written comments must be received by April 22, 1996.

ADDRESSES: Comments related to the chemical wood pulping mills (kraft,

sulfite, soda, and semi-chemical) should be submitted (in duplicate, if

possible) to: Air Docket Section (6102), Attn: Docket No. A-92-40, U.S.

EPA, 401 M Street, SW, Washington, DC 20460, and Ms. Penny Lassiter,

address shown in FOR FURTHER INFORMATION CONTACT Section. Comments

related to mechanical mills, secondary fiber mills, nonwood mills, and

paper machines should be submitted (in duplicate, if possible) to Air

Docket Section (6102), Attn: Docket No. A-95-31 (MACT III), U.S. EPA,

401 M Street, SW, Washington, DC 20460 and Ms. Elaine Manning, address

shown in FOR FURTHER INFORMATION CONTACT Section.

FOR FURTHER INFORMATION CONTACT: For additional information or

regulations applicable to chemical wood pulping mills, contact Ms.

Penny Lassiter or Mr. Stephen Shedd, Office of Air Quality, Planning,

and Standards (MD-13), U.S. EPA, Research Triangle Park, North Carolina

27711: telephone Ms. Lassiter at (919) 541-5396 or Mr. Shedd at (919)

541-5397. For further information on the regulatory development for

mechanical mills, secondary fiber mills, nonwood mills, and paper

machines, contact Ms. Elaine Manning at the address in Research

Triangle Park listed above, telephone (919) 541-5499, facsimile for the

address in Research Triangle Park listed above is (919) 541-3470.

SUPPLEMENTARY INFORMATION: Public Hearing. Anyone requesting a public

hearing must contact EPA no later than March 18, 1996. If a hearing is

held, it will take place on March 25, 1996, beginning at 9 a.m. at the

EPA Administration Bldg., Main Auditorium, 79 T.W. Alexander Drive,

(near intersection of NC54), Research Triangle Park, NC. Persons

interested in attending the hearing or wishing to present oral

testimony should notify Ms. Jolynn Collins, U.S. EPA, Research Triangle

Park, North Carolina 27711, telephone (919) 541-5671.

Docket. Air Docket No. A-92-40, contains supporting information

used in developing the proposed standards and this action for the

chemical wood pulping mills. All docket cites in this action are from

Air Docket No. A-92-40, unless specified differently. Air Docket No. A-

95-31 contains information that supports the proposed standards for the

rule development for the mechanical mills, secondary fiber mills,

nonwood mills and paper machines. These air dockets are located at the

U.S. Environmental Protection Agency, 401 M Street, SW, Washington, DC

20460 in room M-1500, Waterside Mall (ground floor). All comments

received during the public comment period on the 1993 proposed NESHAP

are contained in the Pulp and Paper Water Docket located in the

basement of Waterside Mall, room L102. These dockets may be inspected

from 8:30 a.m. to 12 p.m. and 1:00 p.m. to 3:00 p.m., Monday through

Friday. A reasonable fee may be charged for copying.

Documents. An electronic version of this action as well as ``Review

Draft: Chemical Pulping Emission Factor Development Document,''

``Presumptive MACT for Non-Chemical and Other Pulp and Paper (MACT III)

Mills,'' and previous Federal Register notices pertinent to the pulp

and paper NESHAP are available for download from EPA's Technology

Transfer Network (TTN), which is a network of electronic bulletin

boards developed and operated by EPA's Office of Air Quality Planning

and Standards. The TTN provides information and technology exchange in

various areas of air pollution control. The service is free, except for

the cost of a phone call. Dial (919) 541-5742 for data transfer of up

to 14,400 bits per second. The TTN is also available on the Internet

(access: TELENET ttnbbs.rtpnc.epa.gov). For more information on the

operation of the TTN, contact the systems operator at (919) 541-5384.

The information in this action is organized as follows:

I. Background

A. History

B. Summary of Action

C. New Data

D. Public Participation

II. Source Category and Pollutants for Control

III. Emission Factors

IV. Definition of Source

V. Subcategorization

VI. Level of Standards

A. Kraft

B. Sulfite

C. Semi-Chemical

D. Soda

E. Bleaching

VII. Compliance Extension for Kraft Mills

VIII. Emission Averaging

IX. Relationship with Other Rules

A. New Source Review/Prevention of Significant Deterioration

Applicability

B. Boiler/Industrial Furnace/Resource Conservation and Recovery

Act Applicability

C. Kraft New Source Performance Standards

X. Standard for Nonchemical Pulp Mills

A. Presumptive MACT Process

B. Summary of the Presumptive MACT for MACT II Sources

C. Area/Major Source Discussion

D. Proposed MACT III

E. Request for Information

I. Background

A. History

The Clean Air Act (the Act) requires EPA to develop NESHAP for the

pulp and paper source category by November 1997. Under section 112 (d)

of the Act, the goal of NESHAP is to require the implementation of

maximum achievable control technology (MACT) to reduce emissions and,

therefore, reduce the public health hazard of pollutants emitted from

stationary sources.

On December 17, 1993 (58 FR 66078), EPA published proposed NESHAP

and effluent guidelines for the pulp and paper industry. These

integrated regulations are referred to as the cluster rule. The purpose

of this action is to announce the availability of additional data and

to reopen the public comment period only for items identified in this

action. EPA's Office of Water (OW) plans to issue a Federal Register

notice similar to this action for the effluent guidelines portion of

the cluster rule. Publication of OW's action is anticipated to be in

approximately four weeks.

The 1993 proposed air standards would regulate all HAP's emitted

from new and existing pulp and paper mills that chemically pulp wood

fiber using kraft, sulfite, soda, or semi-chemical methods (MACT I).

These proposed MACT I standards address air emission points in the

pulping and bleaching processes and in the associated process

wastewater collection and treatment systems. Information was not

available at that time to evaluate controls on other emission points

within the source category. The standards for the pulp and paper source

category, therefore, are being developed in phases. Standards for

combustion sources (MACT II) are under development and will be proposed

later this year. Proposed standards for the remaining sources

[[Page 9385]]

(MACT III) are addressed in Section X of this notice. The MACT III

standards apply to the following operations located at all mills:

mechanical pulping (e.g., groundwood, thermomechanical, pressurized);

pulping of secondary fibers (deinked and nondeinked) by nonchemical

means; nonwood pulping; and paper machine additives. Coating and

converting operations will be addressed later under a separate source

category.

Available data shows that pulp and paper facilities emit

significant quantities of HAP's that would be controlled by the

proposed standards. Some of these pollutants are considered to be

carcinogenic, and all can cause toxic health effects following

exposure, including nausea, headaches, respiratory distress, and

possible reproductive effects. Most of the organic HAP's emitted from

this industry also are classified as volatile organic compounds (VOC)

which participate in photochemical reactions in the atmosphere to

produce ozone, a contributor to photochemical smog. The proposed

emission controls for HAP's will reduce VOC emissions as well. The

proposed HAP control technologies will similarly reduce emissions of

total reduced sulfur (TRS) compounds that are of concern because they

produce some odor and they include some HAP.

The public comment period on the proposed NESHAP ended on April 18,

1994; however, EPA recognized in the preamble to the proposed rule that

various industry groups were collecting air emissions data that would

not be available until after the comment period and further stated that

EPA would still consider those data before the promulgation of the

NESHAP. Some of the data were received and were noticed in a February

22, 1995 Notice of Data Availability (60 FR 9813).

This action announces the availability of new data and solicits

comments on the use of the data for emission factor development and on

changes to the proposed rule. These data and analyses are included in

Air Docket A-92-40. This action does not reopen the public comment

period for all issues related to the proposed rule. Comments should

address only those technical and regulatory changes specifically

mentioned in this action.

On September 29, 1995, a Presumptive MACT report was issued for the

MACT III source category. A brief description of the Presumptive MACT

process and the outcome of the process is provided in Section X.

Comments are also solicited on the MACT III tentative conclusions. EPA

currently plans to take final action on the MACT III NESHAP for the

sources discussed in this action at the same time as the MACT I final

action. EPA also plans to propose NESHAP for recovery area combustion

sources (MACT II) at the same time.

B. Summary of Action

As noted earlier, EPA has proposed NESHAP for mills that chemically

pulp wood fiber. EPA is considering revisions to this proposed NESHAP

based on comments from the public as well as test data that has been

given to EPA since proposal. The changes to the proposed rule under

consideration include: revisions to emission factors; broadening of the

source definition; development of subcategories for pulping; revisions

to MACT requirements and how they are applied; and revisions to MACT

compliance schedule for certain kraft mill emission points. This action

also identifies how EPA currently plans to address concerns raised by

commentors regarding interaction between the NESHAP, currently under

development and other rules, such as Resource Conservation and Recovery

Act/Boiler Industrial Furnace (RCRA/BIF) and Prevention of Significant

Deterioration/New Source Review (PSD/NSR). EPA is also soliciting

comments on the industry's alternative compliance concept that includes

some degree of emissions averaging. A brief overview of these changes

is described below. The data and information to support these changes

under consideration can be found in the Air Docket No. A-92-40.

Additionally, EPA is announcing a proposed decision for standards for

other mills and paper machines.

The emission factors were evaluated using additional emission test

data submitted by the industry. Also, the approach to emission factor

development has changed since proposal as more information has become

available. The new approach involves developing emission factors for

functional mill systems, as opposed to the individual emission points

used at proposal. This emission factor evaluation is contained in a

development document and is being announced in this notice for public

review and comment.

At proposal, EPA chose a single source definition to include

pulping processes, bleaching processes, and pulping and bleaching

wastewater streams at a pulp and paper mill. EPA currently intends to

expand this definition to include paper machines and the causticizing

area due to the interrelated nature of these processes with the pulping

and bleaching areas.

At this time, EPA plans to subcategorize the pulping and associated

wastewater components to develop different MACT requirements. This

subcategorization is necessary to reflect important differences between

the different pulping process emissions, emission controls, and control

cost. The pulping (and associated wastewater) subcategories being

considered are kraft, sulfite, soda, and semi-chemical.

At proposal, all vents and pulping wastewater streams in pulping

and bleaching areas were subject as a group to the MACT requirements

with the exception of certain small vents and wastewater streams

defined by numerical cutoffs. For existing source MACT applicable to

the pulping component at kraft mills, EPA is considering specifically

defining the following systems as requiring enclosure and venting to a

control device: the low volume-high concentration (LVHC) vent system

(i.e., the digester, turpentine recovery, and evaporator systems); weak

black liquor storage tanks; the pre-washer knotting and screening

system; the brownstock washing system; and the oxygen delignification

system. Enclosure and vent control requirements would not change from

proposal. Only these enumerated systems would be subject to the rule.

EPA currently intends to define new source MACT for the pulping

area at kraft mills to be the same as existing source MACT with the

addition of control of post-washer deckers and screens. EPA currently

intends to define new and existing source MACT for kraft mill

wastewater to be collection and treatment of certain named pulping

condensate streams instead of all pulping wastewater above 500 parts

per million by weight (ppmw). EPA is considering changing the proposed

treatment requirements for steam strippers at kraft mills to allow

compliance with one of the following: (1) Removal of 92 percent of the

HAP or methanol content, (2) removal of 9.2 pounds of methanol per air-

dried ton of pulp (lb/ADTP), or (3) treat to a steam stripper outlet

HAP concentration below 330 ppmw measured as methanol. For unbleached

kraft mills, the following treatment requirements would be applicable:

(1) Removal of 92 percent of the HAP or methanol content; (2) removal

of 5.9 lb/ADTP of methanol; or (3) treatment to a steam stripper outlet

HAP concentration below 210 ppmw measured as methanol. As at proposal,

methanol is being used here as a surrogate for tracking total HAP

reduced. Mills still have the option of achieving these removals with

an

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alternative control device, recycling to a controlled system, or

hardpiping these condensate streams directly to the biological

wastewater treatment plant instead of steam stripping.

EPA is considering extending the compliance time for controlling

brownstock washers and oxygen delignification units for kraft pulping

mills by an additional 5 years. The additional period would be provided

to allow industry sufficient time to plan, coordinate, and implement

the best combination of control technologies that facilitate pollution

prevention and emphasize the multimedia nature of pollution control.

EPA is considering the following standards for the newly-created

sulfite, semi-chemical, and soda mill subcategories. Based on an

analysis of current controls, EPA is considering requiring certain

sulfite mill vents in the pulping component at existing sources (i.e.,

digester, evaporator, and red stock washers) to be vented to recovery

systems to reduce HAP emissions. Affected vents at new sources include

the same vents as at existing sources, with the addition of knotter and

screening systems, and weak and strong liquor and acid condensate

storage tank vents. Air emissions from these selected vents and

connected recovery systems would be limited to certain mass emission

rates or percent reductions across the complete connected system. This

systems approach would allow many mills to use the various

configurations of current recovery systems to meet either of these

limits. Compliance would be demonstrated by an initial performance test

to confirm compliance with one of the mass limits, followed by

monitoring of control and process equipment operating parameters to

demonstrate long-term compliance. EPA has determined from an evaluation

of the current mill emission data that the following emission values

represent the best performing existing and new mills: (1) Mass emission

rates of 0.65 and 1.10 lb methanol/ODTP, or (2) a mass HAP or methanol

emission reduction of 92 and 87 percent, for calcium-based and ammonium

and magnesium-based mills, respectively. The new and existing MACT for

pulping wastewater streams at sulfite mills would be no additional

control.

EPA currently plans to define existing source MACT for semi-

chemical mills and soda mills to be enclosure and venting of LVHC vents

to a control device. Enclosure and control device requirements would be

the same as at proposal. New source MACT for semi-chemical and soda

mills would be the same as existing source MACT plus the control of the

washer system vents. The new and existing MACT for pulping wastewater

streams at semi-chemical and soda mills is no additional control.

For bleaching processes at all mills, EPA is still considering

requiring all vents from the bleaching stages which utilize chlorine

and/or chlorine dioxide to control emissions of chlorinated HAP's by 99

percent from the tower, seal tank, and washer vents as in the proposed

NESHAP. A new limit of 10 parts per million by volume (ppmv) of

chlorinated HAP from the outlet of the scrubber is also now being

considered as an alternative to the 99 percent removal limit. A mill

would still be allowed to measure the chlorinated HAP's as chlorine.

Additionally paper-grade bleaching processes would be required to

control chloroform air emissions by complying with the Best Available

Technology (BAT) economically achievable currently under development by

EPA's OW. EPA is still re-considering the level of control for

chloroform from bleach plants at dissolving-grade mills. MACT for new

sources would be the same as MACT for existing sources. The proposed

requirements for controlling methanol and other organic HAP emissions

for bleaching stages will likely no longer be considered. As at

proposal, MACT for bleaching wastewater would be no additional control.

EPA has responded to requests for guidance on the interaction and

applicability of the proposed air regulation with RCRA/BIF and NSR/PSD.

With regard to the possible interaction of the regulation with RCRA/BIF

that could result from the combustion of concentrated condensates

derived from steam stripper overhead vents, EPA has initially

determined that regulation of combustion of these condensates under

RCRA is unnecessary because the MACT controls would be protective. With

regard to the possible interaction of the regulation with NSR/PSD that

could come as a result of secondary emissions from combustion control

devices used to comply with this NESHAP, EPA is considering

recommending to State permitting agencies that mills complying with the

cluster rule be granted the ``pollution control project'' (PCP)

exclusion and be allowed to conduct minor NSR only.

These are the most significant changes to the 1993 proposal that

EPA may implement in the final NESHAP, but they do not include all

changes likely to be made. More detailed information on changes

discussed in this action and supporting documentation can be found in

later sections.

In this action, EPA is also announcing a proposed decision for

standards for mechanical mills, secondary fiber mills, nonwood mills,

and additives and solvents applied to paper machines (MACT III). The

proposal is based on Presumptive MACT that was issued in September

1995.

C. New Data

In the February 22, 1995 Notice of Data Availability (60 FR 9813),

EPA announced data that had been received through February 16, 1995.

These data included three separate multi-volume test reports, several

test report and testing program summaries, and a draft condensate

study. This action announces the availability of new data and solicits

comments on the use of the data for emission factor development and on

changes to the proposed rule.

Data added to Air Docket A-92-40 since the 1993 proposal are

located in Section IV of this docket. Major groups of data of

particular note (but not inclusive of all data in Section IV under

consideration by EPA) are as follows: (1) Items IV-A-4, IV-D1-30, IV-

D1-32, IV-D1-36, IV-J-17, and IV-J-28, supplemental information and

corrections to the data noticed at 60 FR 9813; (2) IV-D1-84 and IV-J-

31, compilation of emissions data noticed at 60 FR 9813; (3) items IV-

D1-27, IV-D1-46, IV-D1-66, IV-D1-75, and IV-D1-79, wastewater system

components, emissions, methanol biodegradability in wastewater

treatment systems, and soluble biological oxygen demand (BOD) as a

parameter to track methanol biodegradability; (4) IV-D1-72, IV-D1-76,

IV-D1-77, IV-D1-80, IV-D1-81, IV-D1-86, IV-D1-89, IV-D1-90, IV-D1-92,

IV-E-64, and IV-E-68, control of air emissions at semi-chemical pulp

mills; (5) IV-D1-87, IV-D1-88, IV-D-93, IV-D1-94, IV-E-31b, IV-E-60,

IV-E-66, and IV-E-67, control of air emissions at sulfite pulp mills;

(6) IV-D1-43, IV-D1-58, IV-D1-62, IV-E-15, IV-E-25, IV-E-28, IV-E-38,

IV-E-45, and IV-J-9, control design and costs; (7) IV-J-29 and IV-J-32,

characterization of pulping condensates; (8) IV-D1-59 and IV-D1-95,

industry's Clean Water Alternative (see Section VIII of this notice);

(9) IV-D1-83, knotter emissions data; and (10) IV-D1-51, IV-D1-56, and

IV-E-63, characterization and control of concentrated steam stripper

condensates.

EPA also requests comments on EPA studies and memoranda completed

since the 1993 proposal and contained in the docket (docket categories

IV-A EPA Studies or Contractor Reports and IV-B EPA Factual Memoranda).

These EPA studies and memoranda include

[[Page 9387]]

the emission factor development document and provide support material

for the Level of the Standards Section VI in this notice.

D. Public Participation

A public comment period was open from December 17, 1993 to April

18, 1994 and a public hearing was held on February 10, 1994 to receive

comments on the 1993 proposal. Comments and data received at the

hearing and during the comment period are included in the docket (see

SUPPLEMENTARY INFORMATION Section). EPA has also held numerous meetings

on the 1993 proposed integrated rules and the Presumptive MACT with

many of the stakeholders from the pulp and paper industry, including a

trade association (American Forest and Paper Association - AF&PA),

numerous individual companies, consultants and vendors, environmental

groups, labor unions, and other interested parties. Materials have been

added to the docket to document these meetings and to make available

for public review new information received at those meetings.

II. Source Category and Pollutants for Control

EPA proposed in 1993 to regulate total HAP emissions from mills

that chemically pulp wood fiber using kraft, sulfite, soda, and semi-

chemical methods. At that time, EPA did not propose to regulate the HAP

emissions from other types of mills. EPA is now inclined to include

into this standard additional types of mills in the pulp and paper

industry as well as the paper machines at all the mills (MACT III).

These new mills include mechanical mills, secondary fiber mills, and

nonwood mills. EPA's current position on these mills and on paper

machines is described in Section X.

The 1993 proposed NESHAP regulates total HAP emissions from

pulping, bleaching, and process wastewater at facilities covered by the

proposal, as opposed to individual HAP's. The proposed standards allow

the use of methanol (or methanol and chlorine from bleaching emissions)

as surrogate compounds because EPA initially concluded that use of

surrogates is technically viable and is a less costly way to track HAP

emission reductions.

For pulping processes and wastewater, EPA's position on pollutants

to be covered has not changed since proposal, and EPA is still inclined

to regulate total HAP emissions, allowing the use of methanol as a

surrogate measurement parameter. At proposal, EPA determined that the

bleach plant emissions were comprised of various chlorinated and

nonchlorinated HAP's. Therefore, a total HAP standard was proposed.

Data at proposal indicated that methanol and chlorine could be used as

surrogates for the nonchlorinated and chlorinated portions of total

HAP, respectively. As a result of comments and data received since

proposal, EPA now knows that only chlorinated HAP's, primarily

chlorine, chloroform, and hydrochloric acid, are being controlled by

the MACT control technologies for bleach plant emissions. Therefore,

EPA currently plans to regulate only the emissions of chlorinated HAP's

from bleaching processes. A more detailed discussion on this topic is

presented in Section VI.

III. Emission Factors

Based on comments and data received, EPA has re-evaluated the

emission factor development approach used to characterize emission

sources and developed new emission factors. EPA developed emission

factors at proposal based on all available data. These data included a

field test program of air and liquid samples from four kraft mills and

one sulfite mill (EPA 5-mill study) and some limited additional

industry data that was used to supplement EPA 5-mill study (see the

Pulp, Paper, and Paperboard Industry Background Information for

Promulgated Standards, Volume 2). Industry representatives commented

that these data were insufficient to accurately characterize emissions

and have since supplied EPA with additional test data from kraft,

sulfite, semi-chemical, and soda mills. EPA analyzed and incorporated

these data into the existing database.

At proposal, EPA developed emission factors for each type of

individual emission point typically found at the mills. Based on the

additional test data, EPA is considering changing that approach. The

new approach involves developing emission factors based on mill systems

rather than on individual emission points. The mill systems are defined

in Section VI, Level of Standards.

EPA now considers this mill system approach the best approach for

several reasons. First, this approach provides a more objective

comparison of the mills. Mills often utilize different configurations

of equipment within a system, making point by point comparisons

misleading. Averaging such pieces of equipment together can provide an

inaccurate estimate of the total system. For example, comparing one

mill's oxygen delignification system as a whole to another mill's

system was more meaningful than establishing separate emission factors

for each piece in the system (e.g., blow tanks, washer units,

interstage storage chests, and filtrate tanks); not all mills have the

same types of equipment in their oxygen delignification system, and

some mills label their oxygen delignification equipment differently.

Next, one mill may have a single screen and another mill may have

multiple screens, but both mills have one screening system with

emissions that can be compared. The mill system approach makes these

kinds of comparisons between mills possible.

Finally, the mill system approach lessens the problems associated

with the nomenclature assigned to each of the components. Variability

exists between the names that different mills assign to similar pieces

of equipment in the same locations. By combining individual emission

points into complete systems, the problem was lessened.

The results and the grouping procedures and approach followed for

each mill system at the various mill types are detailed in the ``Review

Draft: Chemical Pulping Emission Factor Development Document.'' The

report is available in the docket and may be downloaded from the TTN

(see SUPPLEMENTARY INFORMATION Section). This report also discusses the

specific issues and all assumptions that were made in the emission

factor development, including the specific data points tested by

industry that were included in each mill system. EPA is specifically

asking for comments on the results and the approach used in developing

the emission factors before issuing the final report.

IV. Definition of Source

In the December 17, 1993 proposal, three definitions of ``source''

were proposed and considered by EPA. The one chosen by EPA at the time

of proposal was a single source to include the pulping processes, the

bleaching processes, and the pulping and bleaching process wastewater

streams at a pulp and paper mill. EPA is still inclined to use the

single source definition. EPA considers the broad source definition to

be the best interpretation for the pulp and paper industry. This broad

source definition would alleviate concerns that a small change to an

existing mill that creates a small increase in emissions would trigger

new source requirements in the NESHAP. The single source definition is

also the most appropriate interpretation for the industry due to the

interrelated nature of equipment in pulp and paper mills. For example,

wastewater recycling from process to process is an

[[Page 9388]]

integral part of a mill in order to reduce fresh water intake.

Emissions from a piece of process equipment are a function of

pollutants released during the processing of the pulp as well as

pollutants volatilized from water recycled to the process equipment.

EPA is inclined to include paper machines and causticizing

equipment in the source definition above. The term paper machine being

used here does not include paper machine additives and solvents, and

their associated air emissions being addressed in the proposed MACT III

standards set forth in Section X of this notice. Paper machine

emissions discussed here for inclusion in the above source definition

are from the HAP's remaining on the pulp from the pulping and bleaching

process and released when processed through the paper machine. EPA

would include paper machines and causticizing equipment since the

emissions from these sources are, like the emission points discussed

above, interrelated with other process emissions. For example, water is

often reused or recycled from pulping processes to the causticizing

processes, and HAP's in the pulp and water slurry from the pulping and

bleaching processes are carried over into the paper machine where they

are emitted. While the causticizing area and the paper machines were

not defined as part of the source at proposal, they were still being

controlled through the wastewater MACT requirements. Treatment of

condensate streams to remove HAP's prior to recycling them would result

in reduced emissions from the equipment to which they are recycled and

from subsequent pieces of equipment due to reductions in HAP carried

over with the pulp and process waters. EPA recognizes the wastewater

contribution to emissions from these processes and as such currently

intends to include these processes in the source definition. A mill

could then take credit for emission reductions from these processes if

it chose to implement the Clean Water Alternative. The Clean Water

Alternative is discussed further in Section VIII (Emissions Averaging).

EPA considered regulating emissions from woodpiles, but did not

find evidence to suggest that woodpiles are sources of HAP emissions.

Therefore, they are excluded from the definition of source.

V. Subcategorization

In the proposed rule, EPA solicited comment on the need for

subcategories. Many commentors responded to this solicitation with

information on why certain mills should be treated differently than

kraft mills. Separate subcategories for kraft, sulfite, soda, and semi-

chemical pulping processes were suggested. Issues raised by commentors

in support of subcategories included the difference in process

emissions and emission control technologies for sulfite, soda, and

semi-chemical mills. Others indicated that the lack of air and

wastewater emissions data on these types of mills prevented a balanced

assessment of the need for subcategories.

Based on comments received, review of the industry data submitted

after proposal, and meetings with industry groups, EPA solicits comment

on establishing four separate subcategories for the pulping processes

at mills based on the type of pulping process (kraft, sulfite, semi-

chemical, and soda) used.

As a result of the differences in digestion methods, the mills

produce different emissions that have resulted in different degrees of

control at baseline and different applicable control technologies. At

proposal, EPA understood that the four types of mills differ in the way

they digest wood to make pulp, but did not have the data to determine

the extent to which these differences influence potential emission

control strategies. Information received after proposal indicated the

significant extent of these differences.

Kraft mills generate significant quantities of TRS compounds.

Emissions of TRS compounds are regulated under the New Source

Performance Standards for Kraft Mills (kraft NSPS). The vent streams

subject to control also contain HAP's. Therefore, a number of kraft

mills already have a control system in place for the LVHC vent streams.

Also, most kraft mills contain the means of combusting other HAP

containing streams, such as high volume-low concentration (HVLC) vent

streams.

While the HAP-containing vents at kraft mills are laden with TRS

compounds, the HAP containing vents at sulfite mills contain sulfur

dioxide (SO2). Sulfite mills collect the emissions from these

vents to recover the SO2, which is necessary to the production of

the cooking liquor. The collection and burning of these vent streams,

as is typically done at kraft mills, would not be practical. Therefore,

a MACT standard with a different technology basis is needed for these

mills, and a separate subcategory warranted.

Emissions data indicate that soda and semi-chemical mills have HAP

emissions in the same range as for kraft mills, although semi-chemical

mill emissions tend to be at the lower end of the kraft range. However,

these mills do not generate significant quantities of TRS compounds.

Therefore, these mills lack the LVHC equipment already installed at

kraft mills, as well as lacking the benefit of controlled odor from

these vent streams. The digestion process in semi-chemical pulping

differs from soda pulping resulting in different emission points and

characteristics. However, EPA intends to set MACT for the semi-chemical

and soda mills as control of the LVHC vent streams. The MACT

requirements are discussed in Section VI (Level of Standards).

Where two or more subcategories are located at the same mill site

and share a piece of equipment, that piece of equipment would be

considered a part of the subcategory with the more stringent MACT

requirements for that piece of equipment. For example, the foul

condensates from an evaporation set processing both kraft weak black

liquor and spent liquor from a semi-chemical process would have to

comply with the kraft subcategory requirements for foul condensate.

This more stringent requirement is appropriate because there is no

viable way to isolate the emissions for each pulping source to

determine compliance separately.

VI. Level of Standards

Changes from the 1993 proposal now being considered by EPA on the

level of the standard (emission limits and points to be controlled) are

presented in this section. At proposal, sulfite, semi-chemical, and

soda mills were not differentiated from kraft pulping mills and

therefore were subject to the same control requirements as kraft mills.

As discussed earlier, EPA is considering subcategorizing kraft,

sulfite, semi-chemical, and soda pulping and associated wastewater

components for the purpose of setting MACT standards. While EPA does

not currently contemplate subcategorizing among bleaching processes,

EPA may distinguish between papergrade and dissolving grade bleaching

processes for purposes of setting chloroform MACT requirements for

bleach plants. The rationale for this distinction is set forth later in

this section.

EPA is also considering naming specific vents and streams subject

to the standard instead of determining affected emission points and

wastewater streams based on broad groups of equipment with exclusions

for small streams currently not being controlled, as was done at

proposal. This change in approach will more accurately specify the

units that should be controlled.

Requirements for enclosures, closed-vent systems, and control

devices for

[[Page 9389]]

those closed vent systems in the pulping process, as set forth in the

proposed NESHAP, would be the same for the pieces of equipment being

named in this action for kraft, semi-chemical, and soda mills. Public

comments received on these 1993 proposed NESHAP requirements are under

review. EPA will consider these comments prior to promulgation of this

rule and will assess whether changes are warranted; however, such

potential changes are not discussed in this notice. Those same

requirements for enclosures and closed-vent systems, as set forth in

the proposed NESHAP, would also apply to the pieces of equipment being

named in this action for sulfite mills; however, EPA is considering

changing the control device requirements for those closed vent systems

at sulfite mills. Requirements for control of emissions from kraft

pulping wastewater prior to treatment, as set forth in the 1993

proposal, would still apply to the kraft pulping condensate streams

being named in this action; however, EPA is considering changing the

treatment limits for these pulping condensates. No control requirements

are now being considered for non-kraft wastewater streams. Requirements

for enclosures, closed-vent systems, and control devices for those

closed vent systems in the bleaching process, as set forth in the 1993

proposed NESHAP, would be the same for the stages using chlorinated

bleaching agents; however, EPA is considering adding some requirements

for the control of chloroform emissions and is considering adding

additional ways to meet the treatment requirements on the closed vent

systems from the chlorinated bleaching stages. Additionally, EPA is

considering dropping the requirement for control of non-chlorinated

HAP's (methanol, etc.) in the bleaching area.

A. Kraft

This section describes the changes to the level of the standard for

kraft mills from the 1993 proposal. These changes include naming the

streams to be controlled; changing and adding additional performance

levels for steam strippers; and re-evaluating controls for pre-washer

knotter and screen systems, and weak black liquor storage tanks.

The proposed standards required owners or operators of new or

existing sources to enclose and vent all pulping component emission

points into a closed vent system routed to a control device. Deckers

and screens at existing mills and small vents or enclosed process

equipment below certain specified volumetric flow rates, mass flow

rates, and mass loadings were not subject to control. Similarly,

pulping wastewater streams with concentrations below 500 ppmw of HAP's

or flow rates below 1.0 liter per minute (lpm) did not require control.

At proposal, EPA had limited data to characterize some of the

smaller emission points and condensate streams within the pulping

component. However, based upon experience and engineering assumptions,

these small vents and condensate streams were assumed to be

uncontrolled at the floor and not reasonable to control beyond the

floor. Therefore, EPA proposed these low volumetric flow rates and

condensate HAP concentrations to differentiate between points currently

being controlled and those that are not controlled. EPA solicited

comments on whether this was a viable approach for identifying emission

points and condensate streams that should be controlled under the MACT

standard.

Based on comments and data received, EPA re-evaluated the method

for establishing control applicability for pulping process equipment

and associated wastewater streams. Using this new information, EPA is

now tentatively intending to establish control applicability for kraft

pulping process equipment systems and associated wastewater streams by

specifically defining the equipment systems and associated wastewater

streams subject to the MACT standard (i.e., only the equipment systems

and wastewater streams specifically enumerated would be subject to the

standard). EPA believes this change will result in the same level of

control at the MACT floor for both wastewater and process equipment

contemplated in the proposal, yet will reduce or eliminate the cost of

testing that would have been required by the 1993 proposal to determine

applicability. The requirements for enclosures, closed vent systems,

and control devices set forth in the 1993 proposal would still apply.

The named pulping process systems that EPA is considering for

control are: the LVHC vent system, pre-washer knotter and screening

system, the brownstock washing system, weak black liquor storage tanks,

and the oxygen delignification system. The following new definitions

are now under consideration:

1. The LVHC vent system includes batch the digester blow heat

recovery vents, batch digester relief steam condenser vents, continuous

digester relief steam vents, turpentine condenser(s) vents, continuous

digest blow tank vent, evaporator vacuum system vents, liquor

concentrator vacuum system vents, pre-evaporator vacuum system vents,

steam stripper feed tank vents, and steam stripper off gas vents.

2. The brownstock washing system includes rotary vacuum drum

washers, pressure washers, diffusion washers, horizontal belt washers,

all filtrate tanks, and intermediate stock chests. The washing system

does not include deckers, screens, stock chests or pulp storage tanks

following the last stage of brownstock washing.

3. The oxygen delignification system includes the blow tank, the

post oxygen washers, filtrate tanks, and any interstage pulp storage

tanks.

4. The pre-washing screening system includes knotters, knotter

drain tanks, screens, and reject tanks prior to brownstock washing.

At proposal, EPA concluded that a sufficient number of weak black

liquor storage tanks are controlled in the industry to constitute a

floor-level of control. However, several commentors stated that weak

black liquor storage tanks could not feasibly be controlled by simply

venting the tanks to a header system and combustion device (the basis

for the 1993 proposal). The commentors stated that a more complex

system involving sweeping air across the tank would be necessary due to

the potential for an older tank to collapse if a vacuum were pulled on

the tank. A sweep air system would generate a larger volumetric flow

rate from these tanks and thus increase the size of the header and the

combustion capacity required of the control device. An alternative

would be to replace the older tanks with newer tanks which could

withstand the vacuum.

Based on the data available regarding current control technology

levels in the industry and the range of emission potential for these

tanks, EPA believes the 1993 proposed MACT requirements for these tanks

should be retained. However, industry has raised concerns that the

information submitted in the NCASI voluntary survey prior to proposal

is providing a misleading picture of current industry control

practices. The industry has also indicated that the emissions data from

the NCASI test program for these tanks is suspect. The industry is

collecting additional information on current operation, age, emissions,

and control practices for these tanks to supplement information already

provided to EPA.

EPA is considering whether distinguishing between types of weak

black liquor storage tanks is appropriate. Specifically, EPA is

considering the appropriateness of a distinction in age since newer

tanks may be structurally able to withstand a vacuum. EPA is

[[Page 9390]]

interested in any data on the age of the controlled tanks and the types

of controls in use. EPA is also interested in comments on whether age

is an appropriate parameter to consider for determining control

applicability.

Questions remain as to what level of control represents the MACT

floor for these different types of tanks. EPA will continue to discuss

these issues with industry and consider all available information to

resolve the MACT floor questions prior to promulgation.

Several commentors also stated that pre-washer knotter and

screening systems should not be controlled. Based on the data available

regarding current control technology levels in the industry and the

range of emission potential for these systems, EPA believes the control

of pre-washer knotter and screening systems represents a floor-level of

control. However, industry has raised concerns about the information

submitted in the NCASI voluntary survey prior to proposal because the

survey respondents were not clear as to their meaning when they

reported knotter systems as controlled, not controlled, or not vented.

The survey responses also did not indicate if the screening systems

were located before or after washing. Therefore, as with black liquor

tanks, questions remain concerning what level of control represents the

MACT floor for these equipment systems. Industry is collecting

additional information concerning the current operation, emissions,

equipment, and control levels in these systems to supplement the

information already provided. EPA is interested in any additional data

or information concerning the type of and control of emission points in

the knotter and screening systems, both pre and post-washer. EPA will

re-evaluate the MACT floor level of control for these sources prior to

promulgation.

At proposal, EPA characterized pulping wastewater and condensate

streams to be controlled as those with HAP concentrations above 500

ppmw. However, commentors said that the 500 ppmw level was an

inappropriate determinant for wastewater streams controlled at the MACT

floor and provided data to name each stream to be treated. Based on

review of these stream definitions and data submitted by the industry

to characterize these streams, EPA is inclined to agree that the 500

ppmv is inappropriate level and that naming the streams better

identifies the streams to be controlled at the MACT floor. EPA now

considers the subject wastewater streams to be foul condensates and is

inclined to adopt the following definitions of foul condensates and

ancillary equipment:

1. Foul condensates--any liquid streams originating from the

following process areas or equipment: batch digester relief and blow

gas system condensates; batch digester blow heat recovery system

condensates; continuous digester system flash steam condensates;

continuous digester chip steaming vessel condensates; turpentine

decanter underflow; non-condensible gas (NCG) system condensates; NCG

system low point drains; and condensates from the weak liquor feed

stage(s) in the evaporator system. Where vapors or gases from the

digester, turpentine recovery, NCG, and/or evaporator systems are

segregated into low-HAP and high-HAP concentration fractions through

multistage, differential, or selective condensation, only the high-HAP

fraction stream is considered foul condensate. If condensate

segregation is not performed on the process areas or equipment

identified above, the entire volume of condensate generated, produced,

or associated with the process area or equipment shall be considered

foul condensate.

2. Evaporator system--any and all equipment associated with

increasing the solids content of spent cooking liquor including, but

not limited to, pre-evaporators, evaporators (direct and indirect

contact), and concentrators.

3. Condensate segregation--the practice of generating, producing,

or isolating a high-HAP concentration-low flow rate condensate stream

from process vent vapors or gases in order to maximize the HAP mass and

minimize the condensate volume sent to subsequent treatment.

4. Segregated condensate stream (high-HAP fraction)--any condensate

stream that contains at least 65 percent by weight of the total HAP

mass (measured as methanol) that is present in the vapor stream prior

to condensation or isolation.

EPA is requesting comment on this named stream approach and on

whether the definitions shown above and on the pulping process

equipment systems discussed earlier, accurately represent the sources

of emissions to be controlled at the MACT floor and clearly define them

for purposes of compliance determinations.

EPA also re-evaluated control requirements for steam stripping--the

technology on which MACT for these wastewater streams is based. The

proposed standards required that the pulping wastewater streams subject

to control must meet one of the following: Recycle to a controlled

piece of process equipment, reduce the HAP concentration to below 500

ppmw, reduce total HAP or methanol by 90 percent, use the proposed

design steam stripper, or hardpipe the stream to biological treatment.

New performance data on all the currently operated steam strippers were

submitted after proposal (Pulp and Paper Water Docket item 20,027

attachment 3). The new data indicates that the best performing steam

strippers representing the floor level of control achieve a combination

of high percent methanol removal, high methanol mass removal, and low

outlet methanol concentration. Because methanol is a good indicator of

total HAP removal for pulping processes and associated wastewater, any

one of these parameters demonstrates that total HAP are being removed

from the condensate streams and therefore are not emitted to the

atmosphere. Based on that data, EPA now considers that mass removal and

outlet concentration are valid parameters to set control limits in

addition to percent removal as at proposal. The rule would allow mills

to: (1) Choose any wastewater treatment device as long as the device

achieves one of the three parameters and as long as the wastewater is

conveyed to the treatment device in an enclosed conveyance system; or

(2) recycle the wastewater streams to a piece of equipment meeting the

control requirements presented below.

EPA has evaluated the data in the NCASI condensate study (docket

item IV-J-32) and agrees with industry that bleached kraft mills

generate more HAP in pulping wastewaters than unbleached kraft mills

primarily because bleached kraft mills tend to digest the pulp longer.

While unbleached kraft mills can achieve the same percent methanol

removed as bleached kraft mills, unbleached kraft mills cannot attain

the same mass removed or outlet concentration as bleached mills.

Therefore, EPA currently intends to distinguish between bleached and

unbleached mills for the purpose of setting MACT level of control for

pulping wastewater.

The new industry data on steam stripping technologies indicates

that the MACT floor level of control for pulping wastewater at both

bleached and unbleached kraft mills is treating the foul condensate

wastewater streams to remove 92 percent of the HAP content (measured as

methanol). The data indicates that steam strippers achieving the 92

percent control also achieve an equivalent outlet concentration of less

than 330 and 210 ppmw measured as methanol, or remove 9.2 and 5.9

pounds of methanol/ADTP across the treatment

[[Page 9391]]

device, respectively for bleached and unbleached wastewater streams.

Mills would be allowed to use one of three equivalent limits to show

compliance.

EPA still intends to keep the provisions for recycling to enclosed

equipment and hardpiping foul condensates to a mill's biological

wastewater treatment plant. EPA is considering soluble BOD as a

compliance parameter alternative for biological treatment compliance

(docket items IV-D1-27, IV-D1-75, IV-D1-79, and IV-E-44). EPA is

interested in any comments concerning this compliance approach. EPA is

also re-considering the need for a design steam stripper.

New source MACT requirements have not changed since proposal. MACT

for new sources is based on the best level of control achieved from

similar sources. In other words, this technology was selected because

it is used by the best controlled similar source, as required by

section 112 (d) (3). The best controlled similar sources have the same

level of control as existing sources. In addition, the best controlled

source also controls deckers and post washer screen systems by not

venting or enclosing and routing vents to a control device.

B. Sulfite

The level of control for the sulfite industry in the December 17,

1993 proposal was the same as for all mill types (see previous

discussion on kraft mills). This section explains the level of the

standard under consideration for the projected sulfite subcategory. In

summary, EPA has reviewed what sources are being controlled, the

performance of the control technologies, and options for implementation

and setting emission standards for the sulfite industry.

EPA has reviewed public comments and industry data to evaluate the

emission sources controlled at the best performing mills for HAP

reductions. Pulping area sources controlled at the best performing

existing mills are the digesters, evaporators, and red stock washer

system vents (later referred to as the ``selected vents''). These

sources are the same vents as proposed except that knotters or deckers

which follow washers in the sulfite mills are now excluded from control

for existing sources because they are not part of the MACT floor.

Additionally, control of pulping wastewater with steam strippers has

been dropped from consideration since sulfite mills do not employ

stream strippers.

Many public comments stated that the control technology basis of

the standard for sulfite mills should not be combustion as proposed,

since very few mills combust emissions from the selected vents. The

data clearly indicate which emission sources are being collected and

vented to reduce or capture and recover SO2 emissions, which in

turn reduces HAP emissions by some degree. Sulfite mills use a

combination of the acid plant and separate scrubbing systems (e.g.,

nuisance scrubbers) to control and capture SO2 emissions. EPA and

industry have been meeting, collecting, and analyzing data to determine

the degree of HAP emission reduction achieved in these control devices

or systems designed to collect SO2 emissions. Recently, NCASI

provided a summary of the available industry emissions data and

American Forest and Paper Association (AF&PA) made recommendations to

EPA on the MACT standards for sulfite mills (docket items IV-D1-87, IV-

D1-88, and IV-D1-94). In summary, AF&PA recommended that certain named

air emission sources be vented to existing SO2 recovery systems

and that ammonium- and magnesium-based sulfite mills could not recycle

condensates with annual average methanol concentrations exceeding 500

ppmw to pulping and chemical recovery equipment unless the equipment

was being vented to an SO2 recovery device or unless the total

emissions from the all pulping and chemical recovery equipment do not

exceed 2.5 pounds methanol per ton of oven-dried pulp (lb/ODTP).

EPA has used the concept of naming both the sources to be

controlled and the control device on all the other pulping

subcategories. However, for those other subcategories, the named

controls are well understood and emission reduction performance was

well documented. Named control devices for the other subcategories were

specified to meet either a known percent reduction standard, equipment

design standard (e.g., 98 percent control or operate at 1600 degrees

Fahrenheit and 0.75 second residence time for incinerators), or the

named control device is known to operate in a manner to destroy the

emissions to a certain level (i.e., venting to lime kilns or recovery

boilers reduces emissions by at least 98 percent due to very high

operating temperatures). However, for SO2 recovery devices or

systems at sulfite mills there are many combinations of systems used

with various desired SO2 capture efficiencies. Some of these

systems have been shown to be better than others in reducing HAP

emissions. Therefore, simply naming existing SO2 control systems

as the HAP control device does not set a known HAP level of performance

for sulfite mills. EPA must evaluate and set the HAP emission limits

achieved by the best performing existing sources (in this case, the

best performing five mills since there are less than 30 sources

(section 112(d)(3))).

For this evaluation, EPA considered various types of performance

measurement standards for the sulfite industry. Options include

equipment and work practice standards, percent reduction standards,

and/or emission limit (concentration or mass) standards for each or a

combination of streams. As discussed earlier an equipment and work

practice standard is not appropriate. Also, EPA considers that using a

standard that combines emission streams instead of setting individual

stream limits provides the best fit, least expensive, and most flexible

standard since existing mills already use various combinations of

SO2 control technologies for different and varying types of

emission streams. Thus, a mill could use any combination of controls

plus add-on controls or process changes that best fit the existing

facility to get the same emission reduction. EPA evaluated percent

reduction and emission limit standards and found that limits could be

set, based on the best available information. The discussion on how

those limits were determined is found later in this section.

Based on EPA's review of the quantity and quality of data and the

variability in the industry, EPA does not intend to set these limits as

continuous emission limits. Rather, EPA intends that several initial

performance tests be performed using the average of three one-hour

tests when the mill is operating under normal operating conditions to

determine if the control system meets the emission standard. During the

performance test, process and control equipment parameters will be

required to be monitored and matched with the emission limits to

determine the operating and monitoring conditions to be monitored for

long-term compliance with the standard. EPA has used this approach on

other standards to provide flexibility in process operation while

assuring compliance.

Under this program, the owner or operator of the source will

recommend and demonstrate to the permitting authority the appropriate

equipment parameters to be monitored, and the allowable range for those

parameters to demonstrate compliance with the emission standard. This

recommendation would include the data collected during the performance

test supplemented by engineering

[[Page 9392]]

assessments and equipment manufacturer's recommendations. The source

would not be out of compliance with the standard when the source

operates outside those operating conditions if the source reports

(prior to any EPA compliance or enforcement action) and documents that

the episode is during a start-up, shut down, or malfunction as defined

in section 63.2 of the General Provisions. And, the source must

demonstrate that conditions have changed and a retest of the initial

performance test shows compliance with the emission standard.

EPA is considering establishing two emission limit strategies to

demonstrate compliance: mass balance and percent reduction of the

selected vents. Since only methanol data was available for determining

either standard, methanol would be used in this case as a surrogate for

total or individual HAP emission standards. From the recent NCASI

summary of sulfite data, it is clear that calcium-based sulfite mills

have lower emissions because they do not have the extensive recovery

system that ammonium and magnesium-based mills require. Therefore,

emission standards for calcium-based mills will be considered

separately from ammonium and magnesium-based mills.

Section 112 of the Act requires EPA to establish limits based on at

least the average of the five best controlled mills when there are less

than 30 mills. The data set available to EPA to set a mass limit and

percent reduction limit is limited; however the available data

indicates that the average of the three existing calcium-based mills

emit a total of 0.02 lb methanol/ODTP from vents where the selected

sulfite vent emissions are collected and processed. The data set

indicates that the average emissions from the top five ammonium-based

and magnesium-based mills are a total of 0.45 lb methanol/ODTP from the

vents where the selected sulfite vents are collected and processed.

Additionally, the total of the selected vent emissions does not account

for the total air emissions from these systems since scrubbers are used

in the SO2 recovery systems. The scrubbers transfer some of the

HAP from the vents to wastewater that is subsequently sewered. Air

emissions from the sewered recovery system wastewater occur in the

mill's open wastewater collection and processing equipment due to

volatilization. These air emissions from wastewater can be calculated

using EPA's WATER8 Emission Model available on the TTN (under Chief

BBS, Emission Estimation Software, file: water8.zip).

EPA reviewed all the sulfite wastewater data available and the

amount volatilized from an average wastewater system (calculated to be

6 percent lost for methanol using WATER8) and estimates that an average

sulfite mill emits 0.63 lb methanol/ODTP. Estimates from industry

provided earlier in the year also indicated similar results. Industry

has agreed to provide details on sulfite mill wastewater collection and

treatment systems to better estimate the emissions from those systems

since wastewater emissions may be a significant portion of the total

HAP mass emission rate. The total average mass emissions from the

selected sulfite mill vent control systems at the best performing mills

(including vents and wastewater air emissions) are estimated to be 0.65

and 1.10 lb methanol/ODTP for calcium-based and ammonium and magnesium-

based mills, respectively. Using the appropriate value, a mill could

then achieve the emissions reduction under this total mass emission

standard across the selected vents, and the connected recovery system

vent and wastewater emissions.

As noted earlier, industry recommended a much higher vent mass

emission limit of 2.5 lb methanol/ODTP in the industry's sulfite mill

recommendation on limits for recycling wastewater. Industry

representatives stated that the 2.5 lb methanol/ODTP estimate was

derived from the same data set and they derived a similar estimate as

the 0.45 lb methanol/ODTP value discussed above. However, the industry

representatives increased the value (from 0.45 to 2.5) to take into

account variability of testing procedures, mill operating conditions,

and the types of products produced. Industry is currently documenting

their variability calculations and rationale and providing it to EPA

and the rulemaking docket. EPA currently believes that the approach

discussed earlier for implementing these emission limits will

adequately account for variability. However, EPA will consider the

industry rationale and data.

EPA does not have data to support or deny the industry's 500 ppmw

recommendation. Industry is recommending condensate streams exceeding

500 ppmw of methanol should not be allowed to be used/recycled in the

pulping or chemical recovery area to process equipment vented directly

to the atmosphere unless it meets 2.5 lb methanol/ODTP. EPA requests

data and comments on this approach.

The second emission limit approach under consideration for sulfite

mills is setting a mass reduction of HAP emissions from the applicable

emission points. Industry tested two SO2 nuisance scrubbers and

found that while one reduced vent emissions of methanol by 95 percent

and emissions of total HAP by 94 percent, the other SO2 scrubber

increased HAP emissions. Since nuisance scrubbers are only one part of

the recovery system for most mills, the scrubber efficiency alone does

not represent what the total system is controlling. A second approach

was developed that used the mass emission limit derived above and data

on the amount of methanol generated. An industry engineering estimate

indicates that between 15 and 20 lb methanol/ODTP generated in the

sulfite process. Of the amount generated, as much as 8 lbs methanol/

ODTP may be emitted from the selected vents as shown in the recent

NCASI summary of sulfite data. Comparing this amount to the mass

emission rates (0.65 and 1.1 lbs methanol/ODTP) discussed above at the

best performing mills, 92 and 87 percent of the methanol is removed

across the total selected sulfite mill vent control system for calcium-

based and ammonium and magnesium-based mills, respectively. In

conclusion, mills would have to meet either the mass emission or the

mass percent reduction standard across their control system to be in

compliance.

Industry has indicated concern over the numerical mass limits and

percent reductions discussed in this notice because they are based on a

limited data set and because HAP reductions resulting from control

devices installed originally for SO2 control is not well

understood. EPA will review and consider additional data being

collected by this industry and other public commentors to set a HAP

level of performance for sulfite mills prior to promulgation and will

adjust these numerical values as necessary. EPA solicits comments on

the two emission limit strategies for sulfite mills discussed above and

solicits comments on the appropriate numerical values for these

strategies.

New source MACT is based on the best level of control achieved at

baseline. The data shows the best controlled sulfite mills control the

same emission sources as the requirements for existing sources and also

control weak or spent liquor tanks, strong liquor storage tanks, and

acid condensate storage tanks. The best sulfite mills also have non-

venting knotter and screening systems. Therefore, new source MACT is

the same as existing source MACT, as well as, the control of the

aforementioned storage tanks and the

[[Page 9393]]

installation of non-venting knotter and screening systems. EPA

currently plans to require new sources to meet the same mass emission

limit or percent reduction as discussed for existing sources.

C. Semi-chemical

The proposed standards did not differentiate between pulping types;

therefore, the owners or operators of new or existing semi-chemical

mill sources were required to comply with the same standards as kraft

pulping. EPA is considering changing the MACT requirements for semi-

chemical mills to be the control of LVHC vents only (as defined in

section VI.A). Data show that the MACT floor level of control at semi-

chemical mills is collecting LVHC vent emissions and reducing emissions

to the same level as previously proposed in 1993 and discussed earlier

in this notice for kraft mills.

EPA considered whether it would be appropriate to go beyond the

MACT floor at semi-chemical mills to control some of the additional

larger emitting process systems, such as pulp washer systems, that

would be controlled at kraft mills. However, data indicates that

emissions from semi-chemical mills are generally much less than at

kraft mills. Therefore, considering the smaller emission reduction and

the costs to control units beyond the floor, EPA is inclined to set

MACT for semi-chemical mills at the floor (controlling LVHC vent

emissions).

In evaluating the information and through discussions with

representatives from semi-chemical mills, EPA is aware that the best

controlled mills collecting and controlling LVHC vents tend to be

collocated with kraft mills. EPA considered whether a distinction

between collocated and stand-alone semi-chemical mills should be made

for the purpose of setting MACT requirements. EPA determined that there

is no difference in the nature of the vents being collected, and the

level of control is technically feasible and can be achieved at a

reasonable cost; therefore, there is no need to distinguish between

these types of mills. EPA estimates that the control of the LVHC vents

at a typical semi-chemical mill will reduce emissions by 160 Mg of HAP

per year and 1,700 Mg of VOC per year; the cost-effectiveness for a

typical stand-alone semi-chemical mill will range from $1,000 to

$3,000/Mg of HAP. Industry cost estimates fall within that range

(docket item IV-D1-62, IV-D1-86, IV-D1-89, IV-D1-90, and IV-D1-92).

Semi-chemical mill representatives also believe the control of LVHC

vents is a reasonable level of control for stand-alone mills as well

(docket item IV-D1-72 and IV-E-68). Therefore, EPA now considers the

control of the LVHC vents at both types of mills to be MACT and a

distinction is not warranted.

The MACT level of control for HAP emissions from semi-chemical mill

wastewater is no control. EPA is not aware of any semi-chemical mills

treating process wastewaters with steam strippers as is found in the

kraft industry. Since semi-chemical mills generate less HAP than the

kraft process, and therefore, lower HAP-containing streams, EPA does

not consider going beyond the floor to control semi-chemical wastewater

streams to be appropriate.

New source MACT is based on the best level of control at similar

sources. Data indicate the best controlled semi-chemical mills combust

the same LVHC emissions plus the pulp washing system emissions. EPA

anticipates the trend in industry will be to install washer systems

with lower flow rates. This in turn allows for less expensive control

systems. The costs are also reduced at new sources since the controls

can be considered and planned into new equipment installation as

opposed to retrofitted.

Therefore, new source MACT would be the same as existing source

MACT plus the control of the pulp washing systems. EPA has not had a

recent opportunity to discuss this contemplated new source control

level with the affected mills and public and solicits comments and data

on the appropriate levels of control for new sources at these mills.

D. Soda

As discussed previously in section V, subcategorization, EPA

currently plans to establish separate MACT standards for soda mills.

Based on information and data obtained since proposal, EPA now

considers the control of LVHC vents (as defined in section VI. A) at

these mills to be MACT.

Data available to EPA indicate that soda mills do not currently

control any of the equipment that is subject to the MACT requirements

for kraft mills. However, EPA has determined that the emissions from

soda mills are similar to kraft mills and the control costs are similar

to stand-alone semi-chemical mills. Therefore, EPA considers going

beyond the floor to control LVHC vent emissions at soda mills to be an

appropriate level of control for MACT for these mills, taking into

consideration the costs of achieving the controls as well as the other

factors enumerated in section 112(d)(2). EPA estimates that control of

the soda mill LVHC system vents, at a typical mill, will reduce

emissions by 130 Mg of HAP per year and 1,500 Mg of VOC per year.

Data show that no soda mills currently practice steam stripping to

control HAP's in wastewater. EPA initially does not believe the costs

of control of these streams to be warranted, within the meaning of

section 112(d)(2). Therefore, the MACT for the control of HAP in

wastewater would be no control.

The new source requirements are based on the best level of control

at similar sources. Data show that no soda mills are currently

practicing any level of HAP control. However, the control of washing

systems is demonstrated at similar sources (i.e., semi-chemical and

kraft washing systems). Therefore, as discussed in section VI.C for

semi-chemical mills, EPA now considers the control of washing systems

for new sources to be part of MACT. Therefore, new source MACT for soda

mills would be the same as new source MACT for semi-chemical mills

(LVHC and washing system controls). EPA has not had a recent

opportunity to discuss these contemplated new and existing source

control levels with the affected mills and public, and solicits

comments and data on the appropriate levels of control at these mills.

E. Bleaching

EPA is considering changing the proposed MACT requirements for

bleach plants. EPA is also considering making a distinction between

requirements for papergrade versus dissolving grade mills. Changes to

the proposed MACT standard would include only requiring controls for

chlorinated HAP's. The control requirements to achieve chloroform

reductions would be based on a combination of compliance with the

future BAT requirements imposed under the Clean Water Act (only for

papergrade bleach mills) and the enclosure of all bleaching equipment

and routing the vents to a scrubber for all bleach stages where

chlorinated bleaching agents are introduced to control the other

chlorinated HAP's (at all bleach mills). As at proposal, a mill would

be allowed to use chlorine as a surrogate for compliance with these

other chlorinated HAP's around the scrubber. Control of non-chlorinated

HAP's (with methanol as a surrogate), as required at proposal, would be

dropped because data indicate that the best controlled mills do not, in

fact, achieve control of these pollutants. The rationale for these

changes under consideration is set forth below.

[[Page 9394]]

The proposed standards require owners or operators of new or

existing sources to enclose and vent all bleaching component emission

points into a closed vent system routed to a control device. The

proposed MACT was based on caustic scrubbing as the control device.

Vents or enclosed process equipment with volumetric flow rates or total

HAP concentration below certain specified limits were not subject to

control. EPA requested comment on whether MACT should also include

process changes and if a separate MACT standard for chloroform is

appropriate. Based on data received, EPA now considers the chlorinated

HAP limit to be based on the emissions reduction achieved using a

combination of scrubbing and process modifications. Therefore, EPA is

considering setting a MACT standard for both chloroform and other

chlorinated HAP's (chlorine as a surrogate).

Industry provided data for existing bleach plant emission estimates

and scrubber efficiencies. The data clearly indicates that mills

practice significant control of chlorine and chlorine dioxide through

the use of caustic scrubbing (docket item II-I-24). However, existing

bleach plant scrubbers are operated with high recirculation rates which

result in no removal for methanol and other organic HAP compounds

(docket item IV-D1-34). The data also shows reduced chloroform and

other chlorinated HAP emissions with process changes (docket item II-I-

10); however, the data indicate that there are no significant increases

in non-chlorinated HAP emissions. Therefore, EPA currently plans to

drop the total HAP percent reduction limit for methanol and other

nonclorinated organic HAP's.

As discussed earlier, EPA is evaluating two types of bleaching

processes; the distinction is necessary for the purpose of setting

standards for chloroform. These two types of processes are papergrade

bleaching and dissolving grade bleaching, to be defined the effluent

guidelines portion of the cluster rule. The average emission limitation

of the best controlled papergrade bleaching processes result from

control of chloroform and the other chlorinated HAP emissions through a

combination of caustic scrubbing, high levels of chorine dioxide

substitution, and eliminating the use of hypochlorite. The average

emission limitation of the best controlled dissolving grade bleaching

processes also control emissions of the other chlorinated HAP through

caustic scrubbing but tend to use hypochlorite and lower levels of

chlorine dioxide substitution. Therefore at this time, EPA has been

unable to identify the appropriate process modifications for which to

base the chloroform emission control level.

EPA's Office of Water (OW) is currently planning to revise its

technology basis for limits based on results of ongoing studies by

dissolving mills of alternative process technologies different from

those which served as the proposed effluent guidelines. Significant

objectives of these studies include the extent to which hypochlorite

use can be reduced and chlorine dioxide substitution increased in order

to reduce generation and release of chlorinated organic pollutants,

such as chloroform, while maintaining dissolving pulp properties

acceptable to end users of these pulps. When data for these studies

become available, EPA will revise its proposed effluent limitations and

BAT technology option as appropriate, and evaluate data to set

chloroform MACT standards for dissolving grade mills. EPA is interested

in any data concerning chloroform emissions from dissolving grade

bleaching processes and requests comment on an appropriate chloroform

MACT for new or existing dissolving-grade bleach plants.

As proposed, emissions of the other chlorinated HAP (or chlorine as

a surrogate) are to be reduced by 99 percent. EPA is considering also

allowing mills to meet an outlet concentration below 10 parts per

million by volume (ppmv) of HAP from the scrubber exhaust as an

alternative to the 99 percent reduction standard. Commentors asked for

an alternative level to the 99 percent reduction standard because high

substitution rates reduce the bleach vent emissions to the extent that

99 percent reduction across the scrubber is not attainable. Based on

the review of data, the 10 ppmv standard is considered equivalent to

the outlet of scrubbers achieving 99 percent removal (docket item II-I-

24). EPA also is considering whether a mass limit on the scrubber

exhaust would be an appropriate equivalent alternative, and solicits

comment and data on the need and appropriate level for a mass limit.

For papergrade bleaching processes, compliance with OW's BAT option

for papergrade bleaching (anticipated to be based on at least 100

percent chlorine dioxide substitution and no hypochlorite use) is at

least as stringent as the MACT floor (high chlorine dioxide

substitution). Therefore, EPA plans to specify papergrade BAT as

compliance for chloroform at paper grade bleach plants. EPA requests

comments on whether an alternative equivalent numerical limit for

chloroform is needed for papergrade bleaching processes.

EPA's intent for bleaching wastewater is unchanged from proposal

(i.e., no control). New source MACT for bleach plants would be the same

as existing source MACT for both papergrade and dissolving grade bleach

plants. The installation and operation of the totally chlorine free

(TCF) bleaching process meets all the bleaching process MACT standards

for papergrade bleaching and would constitute compliance.

VII. Compliance Extension for Kraft Mills

EPA is committed to the goals of the cluster rule, and believes

that the cluster rule will ultimately result in lower overall

compliance costs, while still providing environmental and human health

protection. However, EPA recognizes the unique compliance and timing

issues that the cluster rule may create. EPA has identified one

situation that may warrant additional compliance time to fully realize

the goals of this rule. EPA is inclined to agree with industry

representatives who have stated that additional time is warranted for

brownstock washers and oxygen delignification units at kraft mills. EPA

believes the additional time would ensure that the maximum degree of

overall multi-media pollution reduction is achieved, without requiring

unnecessary compliance costs.

Many kraft mills are currently considering the addition of oxygen

delignification (OD) to their pulping process lines by the year 2000.

The addition of OD has been shown to have significant environmental

benefit. An OD unit reduces the need for chlorinated chemical

application in the bleaching process, which results in reduced loadings

of chlorinated pollutants to the air and into the bleach plant

effluent. Less water is required in the bleaching process which, in

turn, brings a mill closer to the ``closed mill'' design, with zero

water discharge. EPA is strongly committed to pollution prevention

efforts such as these. There is also a cost savings for the industry by

using OD in the form of reduced chemical usage and less net energy

usage.

To gain the maximum benefit from adding OD units, the brownstock

washers typically need to be redesigned to improve pulp washing. The

trend in the industry is toward newer washing technologies that are

more efficient, require smaller space in the mill, are less polluting

and easier to control. EPA encourages the use of these pollution

prevention technologies, but recognizes the evaluation and

implementation of

[[Page 9395]]

these technologies would add time and expense to the compliance

activities for these sources.

EPA is particularly concerned that if mills had to control vents on

brownstock washers within the 3-year compliance period, time

constraints would dictate that they retrofit their current washers with

a vent gas collection system. Once such a collection system is

installed, mills would likely postpone installation of OD or choose not

to install it at all; as discussed earlier, installation of OD

generally requires brownstock washer upgrades. The upgraded washers

plus the new OD system would require a differently designed gas

collection system. Once mills commit capital to retrofit their current

equipment, they would be very unlikely to entertain technologies such

as OD that would require tearing out and rebuilding or replacing the

gas collection system within a few years. (In such a case, there is a

serious question whether imposition of a standard that results in

foregoing substantial cross-media environmental benefits could be MACT.

Portland Cement Association v. Ruckelshaus, 486 F.2d 375, 385-86 at

n.42 (DC Cir. 1973); Essex Chemical Corp. v Ruckelshaus, 486 F.2d 427,

439 (DC Cir. 1973), EPA must consider non-air environmental impacts in

determining what constitutes a ``best'' technology.)

EPA considers the installation of improved washers and OD to be an

important step toward totally chlorine free bleaching. Total chlorine

free bleaching, while still evolving, provides significant benefits

such as elimination of chlorinated pollutants to the environment and

allows bleach plant effluents to be recycled to the mill. These

benefits result in a large reduction in mill water intake and moves a

mill further toward the closed mill concept.

This additional design and mill modification can be a lengthy

process. EPA wants to allow sufficient time for each mill to fully

consider all pollution control options. EPA also recognizes that the

pulp and paper industry will be implementing both water and air rules

essentially at the same time; many of the changes a mill will need to

implement to comply with the water requirements must be considered

before control of air emissions from the washer and OD systems can be

enacted. Given the engineering requirements, capital expenditures,

permitting requirements, and the time necessary to implement the water

standards, EPA questions whether it is even possible to install

controls for air emissions from OD and washers currently in place

within 3 years.

Much of the discussion in this section is centered around OD. It

must be pointed out that while OD may not be included in the control

basis for BAT at kraft mills, EPA is considering taking a number of

steps, this compliance extension being one, to encourage mills to adopt

the technology. EPA's Office of Water, in a separate Federal Register

notice to follow shortly, will address the process technologies that

are likely to be considered as the underlying basis for BAT effluent

limitations. EPA also will present a plan for incentives being

considered for mills that have installed or will install technologies

that achieve more stringent removal of pollutants from wastewater than

is likely to be required based on BAT.

EPA is thus considering providing an additional 5 years beyond the

3-year compliance time for the remaining units for a total compliance

time of 8 years from the date of promulgation. EPA believes this would

allow sufficient time for a complete evaluation of all pollution

control options. Some limited information on the status of their

compliance activities for these sources would likely be required in

their annual compliance report.

EPA is, of course, aware that section 112 (i) (3) (A) states that

compliance with a MACT standard shall be no later than 3 years from the

standard's effective date. EPA notes, however, that there are special

circumstances present in this instance. First, as described above, a

three year compliance period raises the likelihood of mills which might

otherwise choose to install OD foregoing water quality and pollution

prevention benefits if they are forced to retain their existing

brownstock washing system in order to justify the capital cost of vent

controls on that system. Second, as a legal matter, EPA could develop a

rule with the same contemplated compliance date (i.e. of 2004) by

simply rescheduling this part of the pulp and paper air rule into the

so-called 10-year bin under section 112 (e) (1) (E), and rescheduling a

10-year rule. (Section 112 (c) (1) contemplates revisions in EPA's

initial schedule, and EPA has been held to have continuing discretion

to reschedule under a similar scheduling scheme in the Resource

Conservation and Recovery Act. Chemical Waste Management v. EPA, 869 F.

2d 1526 at n. 2 (D.C. Cir. 1989).) Because of the benefits of the

cluster rulemaking process, which allows EPA to develop and affected

companies and members of the public to gauge the multi-media effect of

contemplated rules at one time, EPA prefers to promulgate the standards

at the same (or close to the same) time. EPA does not believe the

cluster process needs to be abandoned to provide a compliance date it

could achieve by other means.

Much of the rationale for the compliance extension is to encourage

kraft mills to install superior water pollution-control technology, yet

the extended compliance time line contemplated in this notice would be

available to all kraft mills, whether or not they choose to adopt that

superior technology. EPA solicits comments on whether such a compliance

extension should only be available to mills that commit to install

technologies that achieve more stringent removal of pollutants from

wastewater than is likely to be required based on BAT.

VIII. Emissions Averaging

The proposed regulations did not contain provisions for emissions

averaging; however EPA requested comments on the subject. EPA is

interested in emissions averaging because it is equally protective,

adds flexibility, and can also reduce the costs of compliance and

testing. At proposal, EPA did not include an emissions averaging

approach because of data limitations and concerns over how to implement

an averaging approach due to concerns about process variability.

Several commentors indicated support for emissions averaging on the

basis of providing compliance flexibility for the industry, but stated

that an individual approach to emissions averaging, such as

contemplated at proposal, would be too burdensome and inappropriate for

this industry. Conversely, some commentors indicated that emissions

averaging would be difficult to enforce.

After proposal, the industry submitted a concept for compliance

with the proposed NESHAP regulations that is an alternative type of

emissions averaging that is unique and potentially more appropriate for

this industry. While the proposed NESHAP regulations focus primarily on

combustion of specific process vents, the industry provided preliminary

information detailing an alternative compliance plan designed to reduce

the amount of HAP's present in pulping condensate streams that are

recycled to other process areas in the mill (docket item IV-D1-95).

Recent industry data has indicated that a significant portion of

emissions from process areas such as brownstock washing and

causticizing area could be attributed to volatilization of compounds

present in the recycled condensates. Reducing the pollutant

concentration in the recycled condensates would, in turn, lower the

amount of pollutants volatilized from process areas that receive

recycled

[[Page 9396]]

condensates and reduce emissions from bleach plants and paper machines

associated with HAP carry over from pulp washing processes.

The industry's compliance alternative, referred to as the ``Clean

Water Alternative,'' consists of routing pulping area condensates to a

biological reactor to remove the HAP's. The effluent from the reactor

could then be used in other process areas in the mill (e.g., brownstock

washing, causticizing area, etc.). The emission reduction achieved by

the alternative would be associated with using condensates with lowered

HAP concentrations throughout the mill.

The industry believes that significantly reducing the HAP

concentration in recycle process waters using the biological reactor

would achieve greater HAP emissions reduction across the whole source

than the proposed NESHAP. EPA is currently evaluating whether the

industry's clean water alternative would achieve or exceed the HAP

emissions reduction achievable using the control techniques on which

the proposed regulations are based. In addition, EPA will be evaluating

secondary impacts associated with using the clean water alternative.

Conceptually, the industry's proposal would reduce emissions from

process units that receive recycled condensates. Biodegradation of HAP

compounds has been widely documented; however, this approach to

emissions reduction has not been demonstrated in the pulp and paper

industry.

While the industry's clean water alternative is innovative,

additional information must be provided in order to make this proposal

a viable compliance option. Industry supplied additional data to

improve the emission factors (docket item IV-D1-59), but the data was

not sufficient to address EPA's concerns about process variability. The

types of information EPA is interested in obtaining to address these

concerns are: (1) Detailed information, such as: emission calculations;

assumptions used; references; typical process/condensate flow diagrams

(if needed); data supporting relationship between stream concentration

and air emissions; any other data/information necessary to support an

independent evaluation of the industry's claims of performance; (2)

strategies for demonstrating compliance with the NESHAP regulations,

such as the specific reactor performance parameters to be monitored

(e.g., inlet and outlet HAP concentration, hot water tank outlet HAP

concentration, temperature of recycled water; identification of process

equipment receiving treated condensates); and (3) methods for enforcing

compliance with the NESHAP regulations using the industry's

alternative, such as sufficient recordkeeping and reporting

requirements associated with reactor operation.

IX. Relationship to Other Rules

A. New Source Review/Prevention of Significant Deterioration

Applicability

To comply with the MACT portion of the pulp and paper cluster rule

under development, mills will route vent gases from specified pulping

emission points to a combustion control device for destruction. Mills

may use steam strippers to reduce emissions from pulping wastewater.

The incineration of sulfur-laden gases from pulping vents and/or steam

stripper overheads has the potential to generate sulfur dioxide

(SO2). To a lesser degree, the use of supplemental fuels to

support vent gas combustion and the generation of additional steam for

steam strippers may increase emissions of SO2, nitrogen oxides,

particulate matter (PM and PM10), and carbon monoxide.1 For

these reasons, commentors have indicated that compliance with the

proposed cluster rule could trigger major NSR or PSD review.

\1\ Commentors raised similar concerns with respect to the

technologies that would be installed to meet the proposed effluent

limitations in the cluster rule. These issues will be addressed in

the forthcoming water notice.

---------------------------------------------------------------------------

Industry and some States have commented extensively on the

potential problems resulting from the interaction of the cluster rule

under development and NSR. They have indicated that in developing the

rule, EPA did not take into account the impacts that would be incurred

in triggering NSR. Commentors indicated that PSD or NSR review

processes would: (1) Cost the pulp and paper industry significantly

more for permitting and implementation of NSR and PSD requirements than

predicted by EPA; (2) impose a large permitting review burden on State

air quality offices; and (3) present difficulties for mills to meet the

proposed NESHAP compliance schedule of three years due to the time

required to obtain a pre-construction permit. Commentors indicated that

compliance with the proposed rule would make permitting extremely

complex, pointing out that in some cases, sources would be required by

one set of regulations to install emissions controls and constrained

from beginning construction on those controls in the absence of a

permit by another set of regulations. The commentors also suggested

that EPA provide an exemption from major source NSR and PSD review,

preferably using the pollution control project exclusion.2

\2\ A similar issue was resolved in the 1992 WEPCO rulemaking,

where EPA amended its PSD and nonattainment NSR regulations as they

pertain to electric utilities, by adding certain pollution control

projects to the list of activities excluded from the definition of

physical or operational changes, subject to certain safeguards.

Pollution control projects were defined as ``any activity or project

undertaken [at an existing electric utility steam generating unit]

for purposes of reducing emissions from such a unit.''

In a July 1, 1994 guidance memorandum issued by EPA (available

on the TTN Bulletin Board), EPA extended a limited pollution control

project exclusion for source categories other than electric

utilities. The guidance indicated that unless information regarding

a specific case indicates otherwise, add-on controls and fuel

switches to less polluting fuels can be presumed, by their nature,

to be environmentally beneficial.

---------------------------------------------------------------------------

Based on evaluation of pollutant reductions, environmental, and

energy impacts, EPA considers projects implemented to comply with the

MACT portion of the cluster rule to be environmentally beneficial. EPA

therefore considers these projects to be pollution control projects

under current policy guidance issued in an EPA memorandum dated July 1,

1994. As discussed in the guidance, the exclusion does not affect any

minor NSR permitting requirements in a State implementation plan, which

also facilitates the safeguards outlined in the policy guidance.

Further, EPA expects that projects undertaken to meet the MACT portion

of the cluster rule will also qualify as PCP's under forthcoming NSR

reform regulations.

EPA solicits public comment on its determination that control

device projects installed to comply with the MACT portion of the

cluster rule are environmentally beneficial and eligible for exemption

from major NSR as PCP's under current policy guidance. EPA also

solicits public comments on providing a specific exclusion in the major

NSR rules for these types of controls installed to comply with the MACT

portion of the cluster rule.

B. Boiler/Industrial Furnace/Resource Conservation and Recovery Act

Applicability

The proposed pulp and paper NESHAP requires the use of steam

stripping to remove HAP's, primarily methanol, from wastewater. After

removal, the NESHAP would require the HAP-laden vent gases from the

steam stripper to be sent to a combustion device for destruction.

Several commentors indicated that sending the steam stripper overheads

to a combustion device was not the most efficient and cost effective

way to destroy vent gases due to the high

[[Page 9397]]

moisture content and variable heat value of these vent gases. The

commentors recommended sending the stripper vent gases to a

rectification column followed by condensation to obtain a concentrated

condensate (primarily methanol). The concentrated condensate could then

be burned in an on-site combustion device as fuel.

This approach to condense and burn the concentrated condensate

takes advantage of the condensate's energy value and should assure

substantial destruction of HAP's due to the MACT standard. However, as

explained below, under current rules, condensing the steam stripper

vent gases could result in RCRA regulation of the condensate, including

regulation of the combustion unit.

As proposed, the combustion of steam stripper vent gas does not

trigger the BIF regulations because the methanol-laden vent gas is not

a RCRA hazardous waste--it is not listed as a hazardous waste, nor does

it exhibit a hazardous waste characteristic. However, if the methanol

from the steam stripper overheads is condensed before burning, the

flash point of the liquid drops to below 140 degrees Fahrenheit, and

the liquid may therefore be identified as hazardous waste because it

exhibits the ignitability characteristic (set out in 40 CFR

Sec. 261.21). To avoid the imposition of RCRA BIF regulations,

commentors recommended incorporating a ``clean fuels'' exemption into

the pulp and paper NESHAP so that the condensate can be burned for

energy recovery without the combustion unit also being subject to the

RCRA rules.

The ``clean fuels'' exemption is a recommendation from EPA's Solid

Waste Task Force (SWTF) to allow recovery of energy from ``clean''

waste-derived fuels such as ethanol, methanol, and hexane. The

recommendation is contained in ``Re-engineering RCRA for Recycling''

(EPA 530-R-94-016, November 1994). The ``clean fuels'' exemption was

developed by the SWTF to promote burning for energy recovery hazardous

waste fuels that are considered hazardous only because they exhibit the

ignitability characteristic (i.e., have a flash point below 140 degrees

Fahrenheit).

The industry submitted information detailing the composition of

condensates derived from steam stripper overhead gases (docket items

IV-D1-51 and IV-D1-56). However, the determination if the condensates

meet the requirements for the clean fuels exemption has not yet been

conducted by EPA's Office of Solid Waste. Indeed, the soon-to-be

proposed standard for hazardous waste combustion units proposes

exclusions based on a comparable fuel test (rather than a risk-based

test of how ``clean'' the fuel is) involving a comparison with fossil

fuels.

EPA does not believe as an initial matter that RCRA regulation of

combustion of the condensate is needed. Although the clean fuel and

comparable fuel approaches are too nascent for immediate national

application, it still appears that this condensate could be combusted

pursuant to the MACT standard without presenting risks warranting

immediate RCRA control. The condensate does not appear to contain metal

or chlorinated organic HAP's; a volatile HAP (methyl ethyl ketone at

1638 milligrams per liter (mg/l)) and a volatile compound (acetone at

2364 mg/l) were the maximum concentrations detected, and they would be

substantially destroyed under the MACT standard. In addition, EPA

believes that allowing the burning of this condensate does not produce

any additional HAP's due to the high temperatures and residence times

found in pulp and paper combustion devices that would be used to comply

with the proposed MACT standard. Moreover, burning condensate will not

increase the potential environmental risk over the burning of the steam

stripper vent gases prior to condensation. Additionally, the use of the

condensate as a fuel could reduce or eliminate the need for

supplemental firing of fossil fuels in such combustion devices, thereby

decreasing the emission of criteria pollutants (NOX, PM, SO2,

CO). Consequently, EPA believes that regulation under RCRA is not

necessary since the practice would not increase environmental risk,

reduces secondary impacts, and would provide a cost savings. Further

considerations of risk can appropriately be handled as part of the

section 112(f) residual risk determination. For these reasons, EPA is

proposing to exempt specific sources at kraft mills that burn

condensates derived from steam stripper overheads from the BIF

requirements of RCRA.

This decision is consistent with RCRA section 1006, which requires

EPA to ``integrate all provisions of [RCRA] for purposes of

administration and enforcement and * * * avoid duplication, to the

extent practicable, with the appropriate provisions of the Clean Air

Act * * *.'' EPA believes that the imposition of RCRA regulations in

this instance could result in the types of unnecessary duplication that

section 1006 is intended to prevent. EPA now considers that steam

stripping with rectification followed by combustion of the concentrated

condensate is MACT considering energy, economics, and air environmental

impacts. Additional regulation under RCRA is redundant and not likely

to result in any additional emission or risk reduction. Any further

concerns on this issue would more properly be addressed through the

section 112(f) residual risk process which requires EPA to assess the

risk to public health remaining after implementation of the NESHAP

under section 112(d). See generally 60 FR 32587, 32593 (June 23, 1995),

and 59 FR 29570, 29776 (June 9, 1994) where EPA similarly found that

RCRA regulation of secondary lead smelter emissions was unnecessary, at

least until completion of the residual risk process.

EPA believes the potential cost savings produced by allowing the

burning of condensed steam stripper vent gases would be significant.

Industry estimates that annual cost savings would be approximately

$850,000 per mill, or $100 million for the entire kraft industry. Cost

savings would come primarily through the reduction in fossil fuel

purchases.

C. Kraft New Source Performance Standards

EPA is considering whether the New Source Performance Standards

(NSPS) for kraft mills and the proposed pulp and paper NESHAP standards

may have some overlapping or redundant requirements. Possible areas of

overlap in the two regulations are affected sources or emission points,

monitoring, recordkeeping, and reporting requirements. EPA solicits

comments on the potential overlap of the kraft NSPS and the proposed

NESHAP standards.

The kraft NSPS established emission limits for PM and total reduced

sulfur TRS compounds for the following new or modified emission sources

located at kraft mills: recovery furnaces, digesters, multiple effect

evaporators, lime kilns, brownstock washers, black liquor oxidation

systems, condensate stripper systems, and smelt dissolving tanks. The

pulp and paper NESHAP will establish national limits for total HAP

emissions from the following sources at all types of new or existing

chemical pulping mills: digester, evaporator, turpentine recovery,

brown stock washer, and condensate stripper systems. Total reduced

sulfur and HAP compounds are found in the process vents affected by

both the NSPS and NESHAP regulations.

The kraft NSPS requires monitoring of the following parameters:

opacity from the recovery furnace, TRS emissions from affected points,

incinerator temperature, and process variables for any scrubber used

for controlling

[[Page 9398]]

emissions from a lime kiln or smelt dissolving tank. The NESHAP

requires monitoring of the following parameters or pieces of equipment:

closed vent system, combustion device temperature, scrubber, steam

stripper, biological treatment, and the wastewater collection system.

While the NSPS requires monitoring of TRS emissions for the most part,

the NESHAP focuses on monitoring the performance of specific pieces of

equipment.

Recordkeeping duties specified in the NSPS include logging of daily

opacity and TRS emissions data. For the specified collection or control

devices used to comply with the NESHAP, the monitoring parameters

identified in the rule must be recorded in a manner consistent with the

General Provisions. EPA solicits data and comments on whether these

different approaches create unnecessarily redundant or overburdensome

monitoring or recording requirements.

The NSPS requires semi-annual reporting detailing the periods of

excess emissions. Quarterly reports regarding excess emissions and

continuous monitoring system performance are currently required by the

proposed NESHAP. The NESHAP reporting frequencies are currently under

review and will be revised to be no more stringent than the

requirements specified in the General Provisions. Additionally, the

NESHAP requires exceedance reports for startups, shutdowns, or

malfunctions that are inconsistent with the source's specified

operating procedures. One option under consideration by EPA is to allow

the facility to comply with the NESHAP in lieu of complying with the

NSPS for certain pieces of process equipment. EPA solicits data and

comments on the extent to which these reporting requirements could or

should be combined or reduced.

X. Standards for Mechanical Mills, Secondary Fiber Mills, Nonwood Mills

and Paper Machines

A. Presumptive MACT Process

As previously mentioned in the Background Section, a Presumptive

MACT was issued for the MACT III (i.e. mechanical wood pulping mills,

secondary fiber deinking and nondeinking mills, nonwood pulping mills,

and paper machines) source category in September of 1995. Presumptive

MACT is an estimate of MACT based on an assessment of readily available

information and through consultation with experts in State and local

agencies, EPA, environmental groups, and the regulated industry. A

primary purpose for Presumptive MACT is to assist State and local

agencies, industry, and the public in Section 112(g) case-by-case MACT

determinations and with the Section 112(j) hammer provision standards.

The process is useful to enhance planning in the standards development

process. Through the Presumptive MACT process issues can be identified

and resolved early in the standards development process; the

``stakeholders'' can be identified; and the best method to develop MACT

can be determined (e.g., traditional regulatory development, Adopt-A-

MACT, Share-A-MACT, or proposing the Presumptive MACT as MACT).

B. Summary of the Presumptive MACT for MACT III Sources

For the MACT III source category, EPA contacted representatives of

major industry, State, and environmental groups and held discussions

with a team of State and industry representatives. The team evaluated

the information that was available and established the Presumptive

MACT. The pulp and paper Presumptive MACT is available on the Office of

Air Quality Planning and Standards Technology Transfer Network (TTN)

under the Clean Air Act Amendments, Title III Policy and Guidance

Bulletin Board. The Presumptive MACT document is also available in the

docket (see SUPPLEMENTARY INFORMATION section).

Limited information on the source category was identified during

the Presumptive MACT process. The available information identified four

potential sources for HAP emissions: pulping, wastewater from the

pulping process, bleaching, and paper making. Of these, chlorine

bleaching would be a likely source of HAP emissions, assuming

operations in use are similar to those used by bleach plants at

chemical wood pulping mills. Paper machines were also considered an

emission source because of the use of paper additives and solvents.

Nonwood pulping processes and the associated wastewater are potential

sources of HAP emissions based on similarities between these and

chemical wood pulping operations; however, the magnitude of the

emissions could not be determined for these or the other potential

sources from the available information. Information indicated secondary

fiber deinking and nondeinking mills are not a significant source of

HAP emissions (Docket A-95-31 item II-B-1).

Information on current control practices suggests the mills have no

add-on controls in place for HAP emissions except on chlorine

bleaching. There are, however, a number of control options that can be

considered. Besides the add-on controls at bleach plants (scrubbers

that remove chlorine and hydrogen chloride) chlorine-free bleaching may

be in use at some mills. Methanol emissions from paper machines

resulting from recycled water from the pulping process are to be

addressed by the chemical wood pulping standards (see section IV

Definition of Source); however, emissions from paper machines that

result from the use of paper additives and solvents were addressed by

the Presumptive MACT. The Presumptive MACT suggested these emissions

may be reduced through substituting additives and solvent for nonHAP or

lower-HAP alternatives. MACT III for pulping operations, low volume-

high concentration gas streams may be routed to a combustion device (as

would be required in the MACT I discussed earlier in this notice).

Lastly, high concentration wastewater streams may be treated through

biological treatment or by steam stripping of the HAP and controlling

emissions from the steam stripper.

One of the conclusions of the Presumptive MACT was to proceed with

MACT standard development through the traditional rulemaking process.

EPA has since reconsidered this position, given the findings during the

Presumptive MACT process and EPA's current budget limitations. EPA has

now decided to propose the Presumptive MACT as MACT.

C. Area/Major Source Discussion

No information was identified during the Presumptive MACT process

to suggest area sources associated with the MACT III source category

warrant listing as a category of area sources, pursuant to Section

112(c)(3) of the Act. Consequently, only major sources were evaluated

for this category. EPA also has no evidence that any facilities that

are solely nonwood mills are major emission sources in and of

themselves. Major sources are sources within a contiguous area that

emit or have a potential to emit, 10 tpy or more of any HAP or 25 tpy

or more of any combination of HAP. Industry has published information

in an NCASI Technical Bulletin, Number 677 (Docket A-95-31 item II-D-

13), on two emission points at a thermomechanical pulping mill. The two

emission points were the refiner condenser vent and the chip steaming

condenser vent. Total HAP emissions estimated from the two points

tested at this mill were approximately 8 tons per year. It is not

[[Page 9399]]

known if remaining emission points not tested at this mill emit enough

additional HAP to be a major source, or if a larger thermomechanical

mill would be a major source. NCASI also published a Technical

Bulletin, Number 649 (Docket A-95-31 item II-D-12) on emissions from

operations that bleach and brighten secondary fibers. This bulletin was

based on sampling conducted in 1991 and 1992. Due to an increase in the

demand for secondary fiber, these mills have increased in size since

the 1991/1992 sampling program. Therefore, large stand alone secondary

fiber mills may exist that have HAP emissions large enough to be major

sources. Where these MACT III mills are collocated at kraft, sulfite,

semi-chemical, and soda mills that are major sources, they will be

subject to MACT standards; however, the only emission sources that

would be affected by the MACT III proposed standard are the MACT III

bleach plants and possibly the paper machines (for emissions resulting

from solvent or additive use). EPA knows of no additional bleach plants

that would be subject to MACT standards because of their collocation at

a MACT I mill that is a major source. Paper machines will only be

affected if EPA decides to establish additive and/or solvent

substitution as MACT.

D. Proposed MACT III

The information gathered during the Presumptive MACT process

indicates that there are no air pollution control devices in place on

MACT III sources except for chlorine bleaching processes. Based on this

finding, the floor for these sources is no control. Further, available

information indicates any add-on controls would not be cost effective

for these sources. Therefore, EPA has decided not to require controls

beyond the floor. The MACT proposed here for the MACT III sources is no

add-on controls for pulping and the associated wastewater, paper

machines, and nonchlorine bleaching.

Bleach plants at MACT III sources collocated with MACT I sources

are presently regulated under the MACT I standard (see Section VI.E,

Level of Standards). Based on information provided by industry, EPA

believes traditional bleach plants using chlorinated bleaching agents,

such as those found at Kraft mills, that are located at stand-alone

MACT III mills are presently controlled with scrubbers that remove

chlorine and hydrogen chloride for process or worker safety reasons.

EPA is not aware of any better control that could be used. Therefore,

control of air emissions from these bleach plants is already in place

and the proposed MACT for bleach plants at stand-alone MACT III

facilities is no additional control.

EPA is proposing no MACT standard for chemical additives and

solvents at paper machines at this time. EPA continues to investigate

the use of HAP chemicals in papermaking, the magnitude of HAP

emissions, and the viability of chemical substitution that would reduce

HAP emissions. An example of chemical substitution is substitution of

HAP-containing additives and solvents with lower HAP or non-HAP organic

compounds. If information becomes available regarding the floor or

cost-effective HAP controls beyond the floor, EPA will propose a MACT

standard for additive and solvent usage on paper machines in the

future.

E. Request for Information

Additional information is being collected by industry groups, which

began a testing program in September 1995. This program is designed to

evaluate emissions from mechanical pulping processes, secondary fibers

pulping processes, and paper machines. Industry plans to have the

report on this sampling program available in January of 1997. EPA has

also requested any available information on HAP emissions from nonwood

mills from States with these mills; however, limited data are expected

to be available. EPA is requesting any information on uncontrolled

bleaching using chlorinated bleaching agents at stand-alone MACT III

sources. To supplement the information collected during the Presumptive

MACT and the more recent industry and EPA efforts, EPA is requesting

data and comments on its proposal for the MACT III source category.

List of Subjects in 40 CFR Part 63

Air pollution control, Hazardous air pollutants, Pulp and paper

mills.

Dated: March 1, 1996.

Richard S. Wilson,

Assistant Administrator for Air and Radiation.

[FR Doc. 96-5397 Filed 3-7-96; 8:45 am]

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