Following its first review of the Clean Air Act’s New Source Performance Standards (NSPS) for kraft pulp mills since 1986, the EPA has issued a package of updated standards for facilities for which construction, modification, or reconstruction commences after May 23, 2013. 

Emissions limits have been revised for filterable particulate matter (PM), opacity, and total reduced sulfur (TRS).  Updates have also been made to testing, monitoring, recordkeeping, and reporting requirements.  In addition, the action removes the exemption from emissions standards during periods of start-up, shutdown, and malfunction, although an affirmative defense is written into the requirements for “unavoidable failures” that result in emissions exceedances. 

According to the EPA, there are approximately 99 kraft pulp mills in the United States subject to the current NSPS.  The Agency estimates that 10 mills will construct, reconstruct, or modify emissions units and become subject to the NSPS in the next 5 years.  

Affected sources

The affected sources at kraft pulp mills subject to the amended NSPS are recovery furnaces, smelt dissolving tanks, and lime kilns.  Each of these sources must meet PM limits; those limits differ depending on whether the source is either modified or new/reconstructed.  Recovery furnaces and lime kilns must meet opacity requirements.  A fourth group of affected sources, which includes digester systems, brown stock washer systems, evaporator systems, and condensate stripper systems, have no PM requirements, but must meet a TRS limit unless other systems of emissions collection or combustion are used.  TRS limits also apply to each of the other affected sources.   

Monitoring

Continuous monitoring of opacity is required for recovery furnaces and lime kilns that are not using wet scrubbers or combined electrostatic precipitator (ESP)/scrubber systems. Continuous monitoring of TRS emissions is required for recovery furnaces, lime kilns, and other affected sources that comply with the TRS concentration limits.  Parameter monitoring is required for ESPs, wet scrubbers, and combined ESP/scrubber systems.

Performance testing

Initial and repeat performance testing is required once every 5 years for filterable PM and TRS for new, modified, and reconstructed affected sources.  The EPA is also requiring initial and repeat performance testing for condensable PM to gather emissions data that will enable a broader understanding of condensable PM emissions from pulp and paper combustion sources.  Mills must submit electronic copies of their performance test reports using EPA’s Electronic Reporting Tool. 

The EPA is also making certain technical and editorial changes, clarifying the location of applicable test methods in the Code of Federal Regulations, incorporating by reference two non-EPA test methods, and adding definitions pertinent to 40 CFR Part 60, Subpart BBa, a new subpart that was created to contain the modified requirements. 

The amended NSPS were published in the April 4, 2014, FR.