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Don Butkus, Jeff Sorensen, Don Spivey, P.E.--The general provisions for MACT I require pulp mills to prepare and implement startup, shutdown, and malfunction plans for MACT I process and air pollution control equipment. The mill prepared a written SSM plan for the mill’s LVHC, bleaching, and pulping condensate collection and treatment systems. To prepare for compliance with the SSM plan requirements and to develop operating experience with the written plan, the mill launched a trial implementation of the SSM program three months prior to the regulatory deadline set for April 16, 2001. This paper identifies several of the key challenges and lessons learned during the trial implementation of the SSM plan.
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Implementation of the MACT I SSM Plan for St. Helens Paper Manufacturing, 2001 Environmental Confere