Mill Experience with Development and Implementation of Best Management Practices Under Proposed Cluster Rule, 1996 Minimum Effluent Mills Symposium Proceedings
R. C. Carroll
Simons Engineering, Inc.
K. A. Girard & A. F. Jaegel
Louisiana-Pacific Corporation
Louisiana-Pacific operates a totally chlorine free (TCF) bleached kraft pulp mill in Samoa, California. A provision of their 1994 NPDES permit required the mill to prepare a Best Management Practices (BMP) plan to control spills and other releases of liquors and process chemicals. The plan was prepared in accordance with guidelines proposed by EPA in the Cluster Rule (December 17, 1993). The plan includes an engineering analysis to identify the spill potential from start-ups, shutdowns, maintenance, storm events, and normal operation. The mill developed a philosophy to prevent, contain and recover liquor and chemical spills. Improvements were made to operating procedures and systems with a three-year schedule for implementation. The project was significant in that it allowed an in-depth critique of the still-developing rules using real-world examples.