Startup, Shutdown and Malfunction (SSM) Plan For an Integrated Pulp and Paper Mill, 2000 Environmental Conference Proceedings

- G. R. Mueller, S. Brewer -- The NESHAPS of the CAA requires certain major sources within the pulp, paper, and paperboard industry to develop a Startup, Shutdown and Malfunction (SSM) Plan and have the plan in place by April 16, 2001. This written plan forms part of the compliance requirements for the pulp & paper Cluster Rule (MACT) under 40 CFR Part 63.6(e). The SSM Plan is intended to document the procedures a mill must take during times of startup, shutdown, and malfunction that will minimize release of hazardous air pollutants (HAPs) as excess emissions. The St. Laurent Paper Products Corp. operates a Kraft pulping and bleaching mill in West Point, Virginia. The mill is in the process of rewriting its existing operating procedures and developing new procedures as they are identified. These procedures will form the basis of the mill’s SSM Plan. The mill is well underway in developing its SSM Plan and will have it completed well before the April 2001 compliance deadline. The approach being taken in developing the mill’s SSM Plan is to interview knowledgeable plant process personnel and document events and circumstances that could be expected to disrupt the normal collection and control of HAP emissions from the permitted processes.