NESHAP for Pulp Mills

On January 12, 2001 EPA promulgated final National Emission Standards for Hazardous Air Pollutants (NESHAP) for chemical recovery combustion sources (new and existing) at kraft, soda, sulfite and stand-alone semichemical pulp mills. HAPs regulated by this rule include gaseous organic HAPs and HAP metals. Emissions limits, as well as monitoring, performance testing, recordkeeping and reporting requirements are included in the rule.

The rule promulgates particulate matter (PM) emissions limits as a surrogate for HAP metals for new and existing recovery furnaces, smelt dissolving tanks (SDTs) and lime kilns at kraft and soda pulp mills. The final rule also allows the use of a “bubble compliance alternative” for determining compliance with the HAP metals standards for existing process units (i.e., recovery furnaces, SDTs and lime kilns) in the chemical recovery system at kraft and soda pulp mills. The “BCA” allows mills to set PM emissions limits for each existing process unit in the chemical recovery system at the mill such that, if these limits are met, the total emissions from all existing process units do not exceed a mill-specific “bubble” limit. As in the proposed rule, the “BCA” bubble is not applicable to new sources. Existing process units subject to the New Source Performance Standards (NSPS) for kraft pulp mills are still required to meet the PM emissions standards of the NSPS, regardless of which option they choose for complying with the HAP metals standards.

The new rule also promulgates a gaseous organic HAP standard for new recovery furnaces using methanol as a surrogate. The limit, as measured by methanol, is 0.012 kg/Mg (0.025 lb/ton) of black liquor solids fired.

In addition, the rule promulgates PM emissions limits as a surrogate for HAP metals for new and existing sulfite combustion units and gaseous organic HAP standards for existing and new semichemical combustion units using total hydrocarbon (THC) as a surrogate for gaseous organic HAPs.

Existing kraft or soda recovery furnaces equipped with an ESP for PM control must have a continuous opacity monitoring system (COMS). New kraft or soda recovery furnaces and new or existing kraft or soda lime kilns equipped with an ESP for PM control must also employ COMS. The entire rule is available from the McIlvaine library: MO 010316.