RACT and MACT Compliance at a North East Pulp and Paper Mill, 1996 Environmental Conference Proceedings

Completion of the RACT process for pulp and paper mills was made difficult due to the lack of adequate data on emissions, and uncertainty regarding the extent and timing of upcoming MACT requirements. Results from an engineering design effort for a system of RACT controls that would also meet proposed MACT requirements for a major mill located in eastern PA are presented. The effort considered the options of using a dedicated incinerator versus existing combustion devices for destruction of pulp mill VOCs and HAPS, and also addressed air quality impact and licensing issues. Emissions data were collected in order to assist in the effort. Substantial benefit was derived from the evaluation of these control options, and it was demonstrated that large savings (more than $lMM annually) might be realized by implementing the preferred option (combustion in an existing power boiler) versus the alternative (a dedicated incinerator). This preferred option also proved to be the most beneficial from the viewpoint of environmental impact. First it was demonstrated that the existing power boiler would have less potential for impact than the incinerator alternative. Next, it was shown that utilization of the existing boiler would actually result in a reduction to potential air quality impact, when compared to potential impacts of currently permitted operations.