Low Volume High Concentration (LVHC) and Thermal Oxidation, 1998 Cluster Rule Symposium Proceedings

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Pulp and Paper Source Category have been proposed, negotiated and finalized. The process that lasted over seven years is now, or should soon be, over and the regulation finally promulgated. These standards require the collection of LVHC vent gases and subsequent control of these gases within three years following the effective date of the regulation, i.e. publication in the Federal Register. Control of HVLC vent gases is required within eight years following publication.

The three-year compliance time may seem adequate for engineering, construction and start-up. However, the Paper Industry and some States commented extensively that if these standards caused mills to increase SO2 or NO, emissions over the PSD significant level, that compliance within three years might not be possible. Requirements to obtain a preconstruction permit under the nonattainment NSR and PSD programs would also cause an undue burden on the affected facilities and permitting authorities. The EPA responded by discussing the July 1, 1994 EPA guidance memorandum and that the use of the pollution control project (PCP) exemption was appropriate. Permitting authorities would be expected to provide adequate safeguards against NAAQS and increment violations and adverse impacts on AQRVs in Federal Class I areas.

This presentation will review the requirements of the NSR/PSD regulations and show the effect that requiring a major source NSR permit may have on the three-year compliance window. The issue of the time required for capital project tasks including conceptual engineering, appropriation of funding, detail design, construction, start-up and compliance demonstration will be discussed. In addition, the presentation will highlight the potential issues of NSPS applicability for modifications to the digester, washer and evaporator systems.