0287-AOP-R7

385 Pages·2008·13.81 MB·English

Domtar Industries Inc.
285 Highway 71 South
Ashdown, Arkansas 71822
AFIN: 41-00002
Response to Comments on DraftAir Operating Permit
0287-AOP-R7
On orabout December6,2007, the Directorofthe Arkansas Department of
Environmental Quality gave notice ofthe draft permitting decision for the above
referenced facility. Duringthe comment period one interested person submittedwritten
comments, data views, or arguments on the draft permittingdecision. The Department's
response to these issues and comments follows.
Comment 1:
Section II: Permit Historypage 7 first paragraph fifth line "for" is misspelled.
Response:
The typographical error has been corrected.
Comment 2:
Typo- pg 16 has a line missing under the second item, "Napthalene" (sic) in the Emission
Summarytable in the 3rd column afterthe heading Pollutant.
Response:
The typographical error has been corrected.
Comment 3:
Emission Summary Sourcenumber 30page 19. Source number needs to be changed to
30 A-F and the PM emission rate changed to 4.8 Iblhr.
IO
Response:
The Department agrees. The changes have been made.
Comment 4:
Remove section"MACT Rules with Future ComplianceDates" on page 131 and
Plantwide Conditions 30 and 31.
Response:
TheDepartment agrees. The BoilerMACT has beenvacated and the compliance date for
40 CFRPart 63, Subpart S (April 17, 2006), has passed. The changes have beenmade.
Comment 5:
Suggestnot changingthe PM limit to the MACT limit for source number 3, PowerBoiler
No. 1onpage 39 and the requirement to establishthe operating parameters for the
WESPs SC 42 on page 41.
Response:
The Department disagrees. The reduction in particulatematter emissionresulting from
installation ofthe WESPs was used in the air dispersion modeling performed to
demonstrate compliance with the National Ambient AirQuality Standards (NAAQS) at
this facility. Inorderto insure compliancewith the NAAQS, the permitted emissionrates
must be verified and the operating parameters for the control equipmentmustbe
established. The permit shall remain as written.
Comment 6:
PM limits based on method 5 and method 202 testing. The mill suggests the following
PM limits for source No.1, No.5 andNo. 14because testing results were variable and
above the current limits when testing for condensable particulate in method 202
1. Source No. 1PowerBoilerNo.3 = 57 lb/hr
2. Source No.5 PowerBoilerNo.2 = 480 lbs/hr
3. Source No. 14Recovery BoilerNo.3 = 607 lb/hr
Response:
The Departmentdisagrees. Before these rates can be increased as requested, Domtarwill
have to demonstrate to the Departmentthat no violation ofthe NAAQS or any applicable
PSD standardswill occur. The permit shallremain as written.
Comment 7:
The requirement for weeklyobservation ofthis stack should notbe necessarynow that it
is equipped with the wet ESP. Operatingparameterswill be established during the initial
compliancetest scheduled in the near future. Establishingthe baseline operating
parameters will assure the boiler and wet ESP will be continuouslyoperatedwithin
parameters that will be establishedduring compliance certification.
Method 9observationshave served apurpose when there was no othermeans of
determining compliance with opacitylimits but now shouldbe replaced bymuch less
subjective continuous monitoring ofoperating parameters.
Response:
The Department disagrees. There is no requirement to install acontinuous opacity
monitor at this source and there is no established correlationbetween anypotential
operating parameters and opacity. Method 9remains the onlyestablished method of
demonstrating compliancewith the opacitylimits assigned to this source. The permit
shall remain as written.
ADEQ
OPERATING
AIR PERMIT
Pursuant to the Regulations ofthe Arkansas OperatingAirPermitProgram, Regulation 26:
Permit No. : 0287-AOP-R7
Renewal #1
IS ISSUED TO:
Domtar Industries Inc. - Ashdown Mill
285 Highway 71 South
Ashdown, AR 71822
Little River County
AFIN: 41-00002
THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL,
OPERATE, AND MAINTAINTHE EQUIPMENT AND EMISSION UNITS DESCRIBED IN
THE PERMIT APPLICATION AND ON THE FOLLOWINGPAGES. THIS PERMIT IS
VALID BETWEEN:
July 19, 2005 AND July 18, 2010
THE PERMITTEE IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED
HEREIN.
Signed:
_1;L]?~ JAN 28 Z008
Mike Bates Date Modified
Chief, Air Division
DomtarIndustries Inc. - Ashdown Mill
Pennit#: 0287-AOP-R7
AFIN: 41-00002
Table ofContents
SECTION I: FACILITY INFORMATION 6
SECTION II: INTRODUCTION 7
Summary ofPermitActivity 7
Process Description 7
Regulations 14
Emission Summary 15
SECTION III: PERMIT HISTORY 21
SECTION IV: SPECIFIC CONDITIONS 25
SN-Ol 25
No.3 PowerBoiler 25
SN-02 31
No.3 Lime Kiln 31
SN-03 39
No. I PowerBoiler 39
SN-05 44
No.2 PowerBoiler 44
SN-06 51
No.2 Recovery Boiler 51
SN-08 59
No.2 SmeltDissolving Tank 59
SN-09 65
No.2 Lime Kiln 65
SN-II 73
No.2 Natural Gas Fired Package Boiler 73
SN-14 74
No.3 Recovery Boiler 74
SN-15 82
No.3 Smelt Dissolving Tank 82
SN-16, 17 and 18 88
No. lA, IB and 2 Bleachplant Vents 88
SN-20 92
ERCO Cl02 Generator 92
SN-21 93
Effluent Treatment Lagoons 93
SN-22 96
No. IA and IB Brownstock Washers Vents 96
SN-23, 24, ~?~."26., an~~it 98
Storage Tat1k:s·.~..::..:·..:.; 98
SN-29 101
Recausticizer Vents 101
SN-30AthroughF 103
PCC Carbonators 103
SN-36 105
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Domtar Industries Inc. - Ashdown Mill
Permit#: 0287-AOP-R7
AFIN: 41-00002
Weak Black LiquorTanks 105
SN-37 106
Pulp Dryer 106
SN-38 107
No.2 and No.3 Wood yards 107
SN-40 108
No. lA and IB DigesterChip Fill Exhaust... 108
SN-41 110
Sludge LandfilL 110
SN-42 111
No.2 Decker 111
SN-43 112
Tub Grinder 112
SN-44athrough 44d 114
PaperMachines 114
SN-45 117
OxygenDelignification System 117
SN-46 118
Haul Roads - Fugitive Emissions 118
SECTION V: COMPLIANCE PLAN AND SCHEDULE 119
SECTION VI: PLANTWIDE CONDITIONS 120
Acid Rain (Title IV) 121
Title VI Provisions 121
Tire Derived Fuel 122
Testing Conditions 122
Standards for the Pulping System at Kraft Processes - Low Volume High Concentration
Sources 123
Clean Condensate Alternative Requirements 129
Recordkeeping Requirements 130
TestMethods and Procedures 131
Permit Shield 131
SECTION VII: INSIGNIFICANT ACTIVITIES 164
SECTION VIII: GENERAL PROVISIONS 166
Appendix A- 40 CFRPart 60, Subpart Db, Standards ofPerformance for Industrial
Commercial-Institutional SteamGenerating Units
Appendix B- ADEQ Continuous EmissionMonitoring System Conditions
Appendix C- 40 CFRPart 60, SubpartBB, Standards ofPerformance for Kraft Pulp Mills
Appendix D - 40 CFR Part 63, Subpart S, National Emission Standards for Hazardous Air
Pollutants from the Pulp and PaperIndustry
Appendix E- 40 CFRPart 63, SubpartMM, National Emission Standard for Hazardous Air
Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone
Semichemical Pulp Mills
Appendix F- 40 CFRPart 60, Subpart D, Standards ofPerformance for Fossil-Fuel-Fired Steam
Generators for Which Construction Is Commenced After August 17, 1971
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Domtar Industries Inc. -Ashdown Mill
Permit #: 0287-AOP-R7
AFIN: 41-00002
Appendix G- 40 CFRPart 60, Subpart Kb, Standards ofPerformance for Volatile Organic
Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction,
Reconstruction, orModification Commenced after July23, 1984
Appendix H - 40 CFRPart 63, SubpartRR, National Emission Standards for Individual Drain
Systems
Appendix I- Haul road tables from modeling report
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DomtarIndustries Inc. - Ashdown Mill
Permit #: 0287-AOP-R7
AFIN: 41-00002
List ofAcronyms and Abbreviations
AC.A. Arkansas Code Annotated
AFIN ADEQ Facility IdentificationNumber
CFR Code ofFederal Regulations
CO Carbon Monoxide
HAP Hazardous Air Pollutant
lb/hr Pound PerHour
MVAC Motor Vehicle Air Conditioner
No. Number
NO Nitrogen Oxide
x
PM Particulate Matter
PM Particulate Matter SmallerThan Ten Microns
lO
SNAP SignificantNew Alternatives Program (SNAP)
S02 SulfurDioxide
SSM Startup, Shutdown, and Malfunction Plan
Tpy Tons Per Year
UTM Universal Transverse Mercator
VOC Volatile Organic Compound
SN Source Number
TDF Tire DerivedFuel
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Domtar Industries Inc. - Ashdown Mill
Permit #: 0287-AOP-R7
AFIN: 41-00002
SECTION I: FACILITY INFORMATION
PERMITTEE: Domtar Industries Inc. -Ashdown Mill
AFIN: 41-00002
PERMIT NUMBER: 0287-AOP-R7
FACILITY ADDRESS: 285 Highway71 South
Ashdown, AR 71822
MAILING ADDRESS: 285 Highway 71 South
Ashdown, Arkansas 71822
COUNTY: Little River
CONTACT POSITION: Kelley R. Crouch, Sr. Process Engineer
TELEPHONE NUMBER: [phone] ext. 6168
REVIEWING ENGINEER: WesleyCrouch
UTM North South (Y): Zone 15: 3722.6
UTM East West (X): Zone 15: 399.7
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DomtarIndustries Inc. - Ashdown Mill
Pennit#: 0287-AOP-R7
AFIN: 41-00002
SECTION II: INTRODUCTION
Summary ofPermitActivity
DomtarIndustries Inc. - Ashdown Mill (AFIN: 41-00002) operates apapermill located at 285
Highway 71 South in Ashdown, Arkansas 71822. This modification will quantify emissions
from the haul roads (SN-46) for the first time, add acoal storage pile to the insignificant
activities list, add awet electrostaticprecipitator as acontrol device for particulate emissions for
SN-03 and correcttypographical errors. Pennitted emissionrates are 2149.5 tpy PM, 2149.5 tpy
PMIO, 8111.2 tpyS02, 3144.9 tpyVOC, 12880.3 tpy CO, and 1923.7tpyNOx•
Process Description
Nos. 2 and 3Wood yards produce approximately 10,000total tons ofwood chips perday. These
chips are fed to the lA digesters, the IE digesters, or the Kamyr continuous digester. The lA
digesters produce approximately 800-850 tons ofunbleached hardwood each day, as do the lB
digesters. Five digesters serve both the 1A and 1B lines.
TheNo.2 Pulp Mill uses acontinuous Kamyr digester to produce approximately900-950 tons
perday ofunbleached pulp. Brown stockwashers wash the pulp and send the pulp to the mill's
oxygen delignification system. The oxygendelignification system (02 Delig) uses elemental
oxygen and oxidized white liquorto break down the lignin in the softwood pulp before the pulp
gets to the bleach plant.
The lA, lB, and No.2 BleachPlants receive pulp from the lA, lB, andNo.2 pulp mills,
respectively. The bleach plants primarilyuse chlorine dioxide to bleachthe pulp until it is
suitable for making qualitypaperorpulp. The lA bleach plant processes approximately750-800
tons perdayofbleachedpulp due to losses inbleaching. lB processes approximatelythe same
tonnage, and the No.2 BleachPlantproduces about 850-900 tons perday. All this bleachedpulp
is sent to the pulp dryer orto one offour papermachines.
The pulp dryerproduces approximately450-500 tons perday ofeither softwood or hardwood
market pulp. This pulp is used internallyto make paper grades or sold to external customers.
The No. 61 PaperMachine produces approximately350 tons perday ofpaper; No. 62 produces
approximately600 tons perday; No .63 produces about 575-600 tons perday; and No 64
produces about 1000 tons per day. Papertonnage also includes fillers used to develop
brightness, opaque finish, and otherquality metrics in the finished product. The paper from the
machines is either sold in roll fonn or sentto the convertingoperations. In converting, the paper
rolls are processed into 8x 11" sheets (orother sizes), stacked into reams, and packed into
cartons for shipmentto outside customers.
Power and Chemical Recovery
Black liquor is abyproduct ofcooking the chips in all three pulping lines. The evaporators
evaporate water to concentrate the solids in the black liquor (called weakblack liquordue to its
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DomtarIndustries Inc. - Ashdown Mill
Permit#: 0287-AOP-R7
AFIN: 41-00002
relatively low dissolved solids content). The recoveryboilers bum concentratedblack liquor
solids. The two recoveryboilers bum approximately4,000 tons ofblack liquor solids (::=:; 55% in
No.3 Recovery, ::=:;45% in No.2 Recovery) each day.
The molten liquor from the bottom ofthe recoveryboilers is mixed in the dissolving tank with
weak wash from the recausticizing areato form green liquor. The green liquor is clarified and
mixed with hot lime (CaO) from the two lime kilns inone oftwo slakers. The liquor and lime
react to form calcium carbonate (CaC03) and sodium hydroxide (NaOH). The NaOH is the
primaryconstituent ofwhite liquor, the chemical used to cook chips in each hardwood and
softwood digester. The CaC0 is sent to the lime kilns where it is calcined, driving offthe CO
3 2
to form CaO to be used in the slakeragain. The No.2 Lime Kiln produces approximately275
350 tons perday oflime, and the No.3 Lime Kiln produces about 350-450 tons perday oflime.
Dregs from the green liquorclarifierare washed in order to recover any remaining inorganics
that can be used in the chemical recoveryprocess. Afterwashing, the dregs are sent to the lime
waste landfill. Approximately 150 tons perday ofdregs maybe produced each day. Grits from
the slaker(gravel, hard-burned lime, etc.) amount to about 8 tons perday and are disposed ofin
the lime waste landfill.
Fibernot used on the papermachines is sent to the wastewater treatment plant. This fiber is
recovered in three wastewaterclarifiers and is dewatered using one ofthree screw presses. The
dried fiber (sludge orwastewater treatment plantresidual) is sent to an on-site landfill for
disposal. Approximately 50 drytons ofsludge are generated daily.
Three powerboilers are used in conjunctionwith the recoveryboilers to produce steam used for
power generation. The No.1 PowerBoilerbums about 500-650 tons per day ofbark from the
wood yard. The No.2 PowerBoilerbums about 300 tons perday ofbark and 600 tons per day
ofbituminous coal. The No.3 PowerBoilerbums about 800-1000 tons perdayofbark. Steam
generation rates average about 120 klbs/hr, 600 klbs/hr, and 200 klbs/hr for Nos. 1,2 and 3
PowerBoilers, respectively.
The package boiler can be used to supplement steam demand during upset conditions or
shutdowns ofother boilers. It is typically used less than 25% ofany operating quarter.
WastewaterTreatment System
The mill's process sewers flow to an effluent lift pit, and then pumped to a splitterbox. The
effluent is then sent to one ofthree effluent clarifiers for removal ofprimary sludge. The sludge
slurryis sentto the screw presses and the supernatant goes backto the splitterbox. The effluent
goes through one ofthe two pre-settlingponds before it enters the first aerationpond. After
extensive aeration using surface and sub-surface aerators (68 aerators at 75 hp each), the effluent
flows to the second aeration pond which uses 33 aerators to further treat the effluent. After the
aeration zones, a quiescent stabilizationpond retains the effluent for about three weeks before it
is discharged to the Red River. Approximately55 million gallons ofprocess effluent are
discharged each day.
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