Pulp & Paper
Trinity has extensive environmental management consulting experience assisting the pulp and paper industry with its regulatory compliance and environmental management requirements, completing more than 700 projects for pulp and paper clients in the last 10 years. Our significant project experience combined with our active participation in associations such as the National Council for Air and Stream Improvement (NCASI) and the Technical Association for the Pulp and Paper Industry (TAPPI) gives us the expertise to assist you with your environmental compliance needs.
"Thanks for all of your efforts. [The project} went very smooth and a lot of that was thanks to your good analysis and presentation of the project."
Todd Asselborn, PE - Grief Packaging, Riverside Mill
Regulatory Round Up
- Residual Risk Section 114 Requests - The U.S. Environmental Protection Agency (EPA) is preparing to initiate a Clean Air Act (CAA) Section 114 request for pulp and paper mills related to reviewing the industry’s New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) emission standards. The three federal emission standards that are the subject of this information collection include:
- Standards of Performance for Kraft Pulp Mills (40 CFR part 60, subpart BB)
- National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry (40 CFR part 63, subpart S)
- National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semi-chemical Pulp Mills (40 CFR part 63, subpart MM)
- NSR Reform - Since many of the PSD projects completed nationwide are for pulp and paper facilities, the NSR reform rules have tremendous implications for the industry. Fundamental changes related to the method for calculating baseline emissions and emissions increases should allow smaller capital projects, particularly those that will not significantly affect overall utilization, to proceed without triggering NSR; however, states are interpreting the demand growth exclusion and previously accommodated concepts in different manners, reducing some of the flexibility EPA intended to provide with the NSR reform changes. In other NSR news, EPA issued a final rule in the January 12, 2009 Federal Register that officially modified the agency's position on project aggregation. The final rule, which is expected to be scrutinized by the new Administration and potentially overturned, retains the existing rules and notes that emissions should be combined when changes are “substantially related” from either an economic or technical standpoint. The final rule also specifies that a source cannot group changes based on timing alone, changes must have more in common than just supporting the plant's overall basic function to be aggregated, and modifications that are separated by three or more years are presumed not to be substantially related (unless proven otherwise) and do not have to be aggregated. In the same final rule, EPA withdrew the options for debottlenecking and project netting that were included in the same September 2006 proposal as the aggregation rules.
- Boiler MACT - The Industrial Boiler and Process Heaters NESHAP (Boiler MACT) will potentially have a large impact on boilers operating at pulp and paper facilities. As originally promulgated, units were to comply with the requirements of the Boiler MACT by September 13, 2007. However, on June 8, 2007, the D.C. Circuit Court of Appeals issued a decision vacating and remanding the Commercial and Industrial Solid Waste Incineration (CISWI) Unit Rule and the Boiler MACT for further action, and on July 30, 2007, the court mandated EPA to vacate the Boiler MACT and the CISWI Rule and to take further action consistent with the court’s opinion. Although the Boiler MACT is officially vacated and some states are moving forward with Clean Air Act section 112(j) and 112(g) implementation (the “MACT Hammer” or “case-by-case MACT”), others are still considering the Boiler MACT rule as the basis for compliance. A revised Boiler MACT is expected to be proposed in 2009 and promulgated in 2010. It is uncertain whether boilers combusting certain non-fossil fuels will be regulated under the Boiler MACT or the CISWI Unit Rule (NSPS Subpart CCCC). As originally promulgated, the CISWI Unit Rule defined commercial and industrial waste as solid waste (including sludge and TDF) combusted in a unit whose design does not provide for energy recovery (steam generation or process heating); thus, this definition explicitly excluded boilers based on their energy recovery design. However, as part of the June 8, 2007 decision, the Court ruled that the definition of CISWI did not match the 1990 Clean Air Act Amendments Section 129 definition of a solid waste incineration unit (the Section 129 definition does not exclude units recovering energy) and vacated the definitions. The Court also vacated the Boiler MACT since many sources that were going to originally be subject to Boiler MACT would most likely be subject to CISWI Unit Rule requirements once the CISWI definitions are revised. Given the Court’s ruling, it is uncertain as to whether EPA will be able to exclude any boiler combusting solid waste (i.e., sludge, TDF) from being regulated as an incinerator rather than a boiler. The outcome of the classification of boiler or incinerator will impact all existing and new boilers combusting any solid waste.
- New Source Performance Standards - NSPS Subparts IIII and JJJJ, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines and Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, respectively, were promulgated in July 2006 and January 2008. These subparts are potentially applicable to stationary internal combustion engines based on the date each engine was constructed, reconstructed, or modified. Facilities must evaluate the requirements of these rules and obtain the necessary air permits prior to bringing a new engine on-site or modifying/reconstructing an existing engine.
- RICE MACT - With the promulgation of NSPS Subpart JJJJ in January 2008, EPA also revised the Reciprocating Internal Combustion Engine NESHAP (RICE MACT) to include requirements for minor HAP sources (the existing rule only covered engines at HAP major sources). At facilities that are major sources of HAP, this standard establishes limits for existing four stroke rich burn engines (e.g., gasoline or LPG) and all new engines greater than 500 hp. New engines that are used in emergency service or burn primarily digester and landfill gases are subject to initial notification requirements only. Existing engines (those constructed or reconstructed prior to December 19, 2002) other than four stroke rich burn engines, currently have no specific requirements. However, in a January 2008 Advanced Notice of Proposed Rulemaking, EPA indicated that it would be proposing changes to this rule to include requirements for most existing RICE, soliciting comments on potential requirements for pre-1996, non-emergency diesel engines larger than 300 hp.
The purpose of this effort is to determine the affected population of pulp and paper processes and re-evaluate emissions standards for these sources. Learn more...
- For an international paper manufacturer and distributor, Trinity Consultants prepared a PSD application for upgrades to equipment at one of its facilities. The project included BACT evaluations, emissions inventories, near- and far-field dispersion modeling including the use of the CALPUFF dispersion model to evaluate visibility and deposition impacts on Class I areas, and assistance in drafting and negotiating the final PSD permit for the project. As a result, the facility completed its equipment upgrades within permit limits.
- For an international forest products company, Trinity developed an SSM plan, an LDAR Inspection Plan, and a Compliance Assurance Plan to comply with the Cluster Rule (40 CFR 63, Subpart S). These plans augmented the company’s compliance management capabilities.
- Trinity assisted a major forest products company in developing a permitting strategy for several pollution control projects required to comply with the MACT I and MACT II standards for pulp and paper mills. The pollution control projects included upgrading controls on the existing lime kiln and routing dilute TRS gases to the recovery boiler.
- Trinity has provided strategic permitting assistance for several proposed recovery boiler and/or lime kiln modification projects for various clients. Trinity compiled the necessary information to complete an emission increase analysis relying on the provisions of the NSR reform regulations, such as “could have accommodated” and “projected actual emissions.”