Simultaneously Satisfying CAAA Title V, MACT, RACT, and HVLC Gas Control Design Requirements in Developing an air Emissions Inventory for a..., 1995 Environmental Conference Proceedings

Z. Y. Maserejian, P.E., Tom Saviello, Ph.D. , J. S. Gogolos, P.E., J. Neptune, P.E. & C. Brown -- The International Paper (IP) Androscoggin mill in Jay, Maine is required to install a high volume low concentration (HVLC) noncondensible gas (NCG) system in order to comply with the Town of Jay and the State of Maine Department of Environmental Protection (DEP) regulations requiring the collection and destruction of gases from sources in the mill that emit 5 parts per million (ppm) or more of total reduced sulfur (TRS) compounds by 1996. IP must also meet the following requirements: (1) Title V operating permit with an undetermined deadline, (2) EPA proposed NESHAPS (MACT) with an official deadline for final promulgation of 1997, and (3) state VOC RACT with a compliance deadline of 1995. The basic information IP needed to understand these requirements and plan for compliance was an inventory of all air emissions at the mill. The inventory had to meet IP needs for assessment of regulatory burdens and compliance, engineering design basis of emission controls, as well as future regulatory reporting. The TRS/HAP emission sources covered under the applicable regulations were characterized and design criteria for a collection system and control technology are presented. IP has selected a regenerative thermal oxidizer (RTO) for destruction of TRS/HAP gases. The project is under the design phase.