Retrospective Permitting for Ract and Mact Compliance at a Northeast Pulp and Paper Mill, 1997 Environmental Conference Proceedings

This paper reviews an innovative permitting process associated with bringing a stand-by power boiler back into full service to implement a preferred RACT and MACT control strategy. The subject mill produces approximately 560 bleached-air-dried-tons-per-day (BADT/d) of pulp. Originally, an engineering feasibility study and cost benefit analysis had indicated that large savings (about $2MM annually) could be realized if the preferred option were to be implemented for pulp mill VOC control. This option, combustion of VOCs in an existing power boiler, was far less expensive than the alternative of utilizing a dedicated regenerative thermal oxidizer (RTO).

A summary of recent regulatory submissions that were aimed at obtaining approvals for all aspects of the proposed pollution control project is provided. Previous PSD permit applications had included “netting” analyses that relied on placing the older boiler on stand-by status as a way to expedite the permit approvals for new equipment (a larger CFB power boiler and recovery boiler). The original permitting record had to be revised to reflect completion of permitting requirements that would have been encountered had the older boiler not been placed on stand-by status.

Following this, the new permitting requirements also included an analysis to demonstrate that the proposed pollution control project would qualify for a “pollution control project exclusion” from New Source Review (NSR) as described in recent EPA guidance. This would help avoid the potential additional delay and expense of NSR and PSD permitting for the RACT/MACT compliance project.