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Daniel A. Curry
RMT, Inc.
Earl Hanson & William J. Gibson
Fort James Corporation
This paper discusses an approach for developing a Startup, Shutdown, Malfunction (SSM) Plan for a Low Volume, High Concentration (LVHC), Noncondensable Gas (NCG) System. It covers the following: reviewing National Emission Standards for Hazardous Air Pollutants (NESHAPs) General Requirements; reviewing the Cluster Rule specific requirements; defining SSM; identifying potential release points; identifying potential malfunctions; defining excess emission exemptions (1 percent); discussing record keeping requirements; defining reporting requirements; and presenting the material in a manner acceptable to the regulatory agencies. This specific plan is being developed for the Fort James Bleached Kraft Mill in Pennington, Alabama. The paper will also discuss implementation of the plan including modifications required to the operating procedures and the system.
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Development of a Startup, Shutdown, Malfunction Plan for a Low Volume High Concentration Noncndensab