Michael M. Kravett, Earl L. Hanson
Title I of the 1990 Clean Air Act Amendments requires that states develop and impose new Reasonably Available Control Technology (RACT) requirements on existing major sources of NOx emissions in ozone nonattainment areas. This requirement will affect many U.S. pulp and paper mills, because (1) many pulp and paper mills are located in ozone nonattainment areas or ozone transport regions, (2) the NOx emissions from most mills exceed the threshold for “major source” designation, and (2) most pulp and paper mills include utility-sized fossil fuel-fired combustion units, which constitute the primary source of NOx emissions which will be affected.
As a result of the new requirements, industry members will be forced to conduct detailed assessments of NOx emission control technologies to determine what they must do to achieve compliance. This could be a difficult undertaking, particularly at the outset, because neither the USEPA nor many states have developed clear guidance indicating the methodology for conducting such assessments or the criteria on which determinations will be based. Further, there is very little precedent for NOx control assessments for existing sources outside of the very few states that require an evaluation of air pollution controls on existing sources as part of a regular permit renewal program.
This paper will detail the experience gained in conducting several recent NOx control technology assessments for pulp and paper mill sources that will be subject to NOx RACT requirements. More specifically, this paper will present the following:
1. A review of the key requirements of the NOx RACT regulations being developed by several states in which pulp and paper mills are located.
2. A summary of NOx control technologies, including add-on control equipment and operating practices, capable of reducing NOx emissions from the pulp and paper mill unit operations considered most likely to be affected by these requirements, including industrial boilers, recovery boilers, lime kilns, calciners, and incinerators.
3. A review of the NOx emission reduction capabilites of those technologies.
4. A review of the technological limitations, retrofit experience, environmental and energy impacts, and costs associated with those technologies.
The primary objective of this paper is to provide both valuable information and data that industry members can draw upon to compile their own NOx control assessments.