Air Permitting and Compliance Challenges of Restarting Kraft Pulp and Paper Mill, 2003 Environmental Conference Proceedings

Nexfor Fraser Papers (Fraser) are the new owners of an integrated kraft pulp and paper mill located in Berlin and Gorham, New Hampshire, which had been shut down upon the bankruptcy filing of its former parent company. The new owners faced several air permitting and compliance challenges related to acquiring and starting up the mill. Environmental compliance concerns were paramount as the pulp mill had been unable to implement a planned Cluster Rule (40 CFR Part 63 Subpart S) compliance project prior to the shutdown.

This case study reviews the unique challenges faced by Fraser, the New Hampshire Department of Environmental Services, Air Resources Division (NHDES-ARD) and the U.S. EPA as they worked together to establish appropriate permitting and compliance deadlines. The negotiated consent agreement required 1) submittal of a construction permit application and revised Title V operating permit application within two and a half months of the sale; 2) commencement of construction targeted within three months of the application submittal; and 3) compliance with Cluster Rules within one year of start up of the pulp mill.

Challenges faced by the mill included designing a project for achieving compliance with the condensate collection and process vent treatment standards of the Cluster Rule that also allowed the mill to retire existing utility assets, become self-sufficient from an energy perspective, but also avoid federal Prevention of Significant Deterioration (PSD) permitting due to the aggressive timetable involved. This effort was further complicated by existing facilitywide caps that had been established as part of a PSD-avoidance strategy for a recovery boiler rebuild project in the mid-1990s and the proximity of two federal Class I Areas.