Date: August 12, 2011

(Finalized September 30, 2011)

Subject: Trip Report for Site Visit – GP Big Island, LLC

Risk and Technology review for pulp and paper production and combustion 

sources NESHAP

I. Purpose

The purpose of the site visit to GP Big Island, LLC in Big Island, Virginia was to obtain 

information about pulp and paper operations, equipment, and air pollution control 

devices. This information-gathering effort was part of regulatory development work for 

the Risk and Technology Review (RTR) for the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) for the pulp and paper industry.

II. Place and Date

GP Big Island, LLC

9363 Lee Jackson Highway, Big Island, VA 24526

(434) 299-7386

August 10, 2011

Mailing address:

PO Box 40, Big Island, VA 24526

III. Attendees

GP Big Island, LLC

• Tim Pierce

• Eldon Brammer

• Mark DeLaHunt

• Mayes Starke

• Julie Baty

• Russ Minerich

• Jeff Johnson

• Mike Curtis

• Tammy Wyles

• Mark Aguilar

• John Pinkerton, NCASI

• Ashok Jain, NCASI
U.S. Environmental Protection Agency (EPA)

• John Bradfield, Environmental Engineer, Office of Air Quality Planning and Standards 

 (OAQPS)/Sector Polices and Programs Division (SPPD)/Natural Resources Group 

 (NRG)

• Kelley Spence, Environmental Engineer, OAQPS/SPPD/NRG

• Karen Thundiyil, Office of Policy & Resources Management (ORPM)/Policy & 

 Regulatory Analysis Division (PRAD)

• Rafael Sanchez, Monitoring Assistance and Media Programs Division (MAMPD)/ Air 

 Branch (AB)

• Katie Hanks, EPA Contractor, Research Triangle Institute (RTI)

IV. Background Information

The site visit began with introductions and a meeting to discuss mill background, safety, 

and the agenda of the visit. Following the meeting, a tour of the facility was provided and 

the following areas were observed: wood yard, pulp mill, chemical recovery area, 

wastewater treatment, power house, and the paper machine area. The information 

obtained during the site visit and from the Information Collection Request (ICR) response 

is discussed below. The topics discussed are (A) general information, (B) pulp mill, (C) 

paper mill, (D) chemical recovery and energy generation, (E) wastewater treatment, and 

(F) new substance review process. 

A. General Information

The Big Island Mill (NEI42211, RTI187) began operation in 1891 and employs 

approximately 325 people. In 1959, the mill installed the first corrugating medium 

machine in the country, and a mill expansion in 1996 included installation of an old 

corrugated container (OCC) plant and a recycled linerboard machine. Today, the mill 

produces corrugating medium from semichemical hardwood pulp and recovered fiber on 

two paper machines with an approximate capacity of 356,000 tons per year, and 100% 

recycled linerboard or medium on a third paper machine with an approximate capacity of 

295,000 tons per year. 

B. Pulp Mill

The mill typically purchases 310,000 tons per year of hardwood chips for pulping and 

also utilizes pulp produced from recovered corrugated containers (OCC) and double-lined 

Kraft paper clippings (DLK) from box plants. Hardwood chips are purchased from 

facilities that participate in the Sustainable Forestry Initiative (SFI). Wood chips are 

stored in a pile, reclaimed, screened, and sent to four Pandia continuous digesters for 

cooking, with a combined capacity of 315,360 tons per year, utilizing the non-sulfur 

semichemical process. These Pandia continuous digesters are considerably different from

Kamyr digesters, as they process pulp horizontally in plug-flow conditions. Common 

cook time utilizing these digesters is 6 minutes. Approximately 125,000 tons of 

additional pulping capacity for recovered fiber is provided by a DLK pulper located in 
the Medium Mill. The total pulping capacity for the mill is approximately 775,000 tons 

per year.

Digester

Chips Pulp 

Washers Refiners To Paper 

Machine

Figure 1: Pulping process flow diagram

Pulper Stock Prep

Cleaners 

and 

Screens

OCC To Paper 

Machine

Figure 2: OCC recycling process flow diagram

C. Paper Mill

The mill has two paper machines (PM1 and PM3) located in the Medium Mill that are 

capable of producing approximately 336,000 tons per year of corrugating medium from 

semichemical hardwood pulp and OCC or DLK. PM1 is a fourdrinier (capacity 100,000 

tons per year) that was installed in 1928 and rebuilt in 1956. PM3 is a fourdrinier 

(capacity 236,000 tons per year) that was installed in 1959 and rebuilt in 1985. PM4 is a 

fourdrinier that was installed in 1996 at the recovered fiber facility to produce linerboard 

or medium from 100% recycled OCC. PM4 is capable of producing approximately 

295,000 tons per year. 

D. Chemical Recovery and Energy Generation

In the chemical recovery area, there is one evaporator line that was upgraded in 2001 to 

include digester blow steam pre-evaporation, and non-condensible gas collection for 

MACT, Subpart S compliance. A new, semichemical recovery boiler and smelt 

dissolving tank that combusts approximately 44 gallons per minute of black liquor solids

was installed in 2009. Initially, a steam reforming black liquor gasification unit was 

installed for compliance with MACT, Subpart MM, but due to reliability and operational 

issues, the unit was replaced with the standard semichemical recovery furnace. There is 

no causticization in the semichemical process. Sodium hydroxide and soda ash are added 

to the green liquor to create the cooking chemicals (e.g. white liquor), Figure 3. 

The mill has three power boilers with approximate design capacities of 190,000, 200,000, 

and 200,000 pounds per hour, that were installed in 1965, 1977, and 1995, respectively.
These boilers utilize coal, biofuel with recovered fiber residuals known as “OCC rejects”, 

and natural gas as fuel. A new boiler is currently being installed to replace a coal boiler. 

It is planned to begin operation later in 2011. One 7.5 MW steam turbine is used to 

generate 15% of the mill electricity (178 MWh/d). The facility also purchases 

approximately 936 MWh/d from the grid. 

Green 

Liquor 

System

Recovery 

Boiler

To Digesters

Liquor 

From 

Digesters

Evaps

Cooking 

Liquor 

Tank

Figure 3: Recovery process flow diagram

E. Wastewater Treatment

Approximately 7.5 million gallons of effluent are sent to wastewater treatment at the 

facility and then discharged into the James River. An activated sludge treatment (AST) 

process is used to treat the effluent, including a primary clarifier, two equalization ponds, 

an activated sludge aeration basin, a secondary clarifier, polishing pond, belt filter sludge 

press, and sludge diversion ponds. The dewatered primary and secondary sludge is 

landfilled or sent offsite for composting to create soil amendments. The main driver for 

the conversion to the activated sludge treatment system was the need for additional 

treatment due to the addition of PM4 in 1996, and the real estate limitations of expanding 

the ASB system at the facility. This conversion was possible due to the initial depth of 

the aeration basins, 12 feet. Systems with shallow basins (such as 5 feet deep basins)

would have poor conversion to the activated sludge treatment because of poor mixing and 

poor oxygen transfer. Utilization of AST treatment also results in higher energy use 

(more horsepower required by the aerators) per unit volume of the aeration basin since 

more solids must be maintained in suspension. In the case of energy use for mixing, 

approximately 25 hp is required per 1 million gallons of water treated with an ASB. In 

contrast, approximately 75-100 hp per million gallons is required for an AST system.

AST aeration tanks are typically much smaller than ASBs though, so the total energy 

difference will depend on the specific design parameters of each. Since an AST is 

typically a higher rate treatment process than an ASB, considerably more waste 

biological sludge will be produced, and must be dewatered and disposed. 
Figure 4: Wastewater treatment process flow diagram

F. New Substance Review Process

The Big Island facility requires that all chemicals undergo approval through a “new 

substance review” program. The requestor must obtain background information about 

the chemical, such as the MSDS and other information from suppliers. Once the 

information is obtained, a new substance review form must be completed. This form is 

filled out through an electronic, proprietary program, but it could be adopted in an 

electronic form or a paper form. 

After the form has been completed by the requestor, it is submitted for review and 

approval by leaders in health and safety, purchasing, environmental, and product 

stewardship. The final approval comes from the Operations Leader. Each of these 

individuals investigates related information, such as health hazard information, 

regulations affected, reactive chemical considerations (storage, product impact, etc.), and 

a personal protective equipment (PPE) hazard assessment. After review by the leaders of 

those departments, the requestor must summarize the impacts of the trial and the findings 

of the related information investigation. 

If a chemical is essentially benign, this process takes approximately 2 days. If the 

chemical is complicated and potentially hazardous, this process could take weeks, 

especially if the corporate office is involved with the decision. New procedures for 

handling and storage of the new chemical must also be developed. Approximately 10-20 

chemicals are reviewed each year at Big Island, but mill personnel estimated that 100 or 

more chemicals per year would need to be reviewed for more complicated processes, 

such as tissue making.