Air Quality Support – Pulp and Paper Mill (US)
Our client is one of the world’s leading manufacturers and marketers of tissue, packaging, paper, pulp, and building products and related chemicals. The company employs more than 40,000 people at approximately 300 locations in North America, South America and Europe.
Pursuant to the U.S. Environmental Protection Agency’s (EPA’s) authority under Section 114 of the Clean Air Act (CAA), EPA issued a three-part information collection request (ICR) for the pulp and paper manufacturing industry for major sources or synthetic area sources of hazardous air pollutant (HAP) emissions. SLR assisted this Pulp and Paper Facility with their three-part response to the ICR.
The ICR was being conducted to determine the current affected population of pulp and paper processes and to re-evaluate emission standards for this source category. The three federal emission standards that are the subject of this ICR include:
- Standards of Performance for 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), and
- National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (40 CFR part 63, subpart MM).
SLR undertook the following works:
- Performed detailed research into the facility’s operations, equipment, emissions and permitting history.
- Prepared each of the three ICR responses which included detail information on the pulp, paper, bleaching, and recovery equipment, mission sources, and control equipment.
- Developed a detailed actual annual emissions inventory of all HAP emission sources at the site for Part II of the ICR response.
- Took part in numerous conference calls with EPA, industry trade-groups, and internal company contacts to determine response strategies.