Comprehensive BMP Plan for a Pulp Mill With Chemical Recovery: The Process and Components, 1996 Environmental Conference Proceedings

Ketchikan Pulp Company, a dissolving sulfite mill, was required to complete a comprehensive best management practices (BMP) plan as a part of their reissued NPDES permit. The BMP process was based on 1993 EPA guidance and requirements outlined in the NPDES permit. The process included two in-depth evaluations of the mill: (1) engineering evaluations of the chemical recovery process and (2) a release identification and assessment (RIA). The three engineering evaluations of the chemical recov-ery process included:

- An evaluation of each component of the chemical recovery process for potential releases during mill shutdown and start-up, maintenance, grade changes, and normal operation.

- An evaluation of spill containment systems in the chemical recovery areas.

- An evaluation of monitoring and alarm systems

The release identification and assessment re-quired detailed review of all of the mill proc-esses, evaluation of historical release data and an evaluation of the potential for spills from each area of the mill. The engineering evalua-tions and the RIA were the primary sources of site specific BMPs for the mill. The BMP proc-ess also included general BMPs, such as good housekeeping, security, preventive maintenance, material compatibility, and employee training.