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 Isl and, LLC in Big Island, Virginia wa s to obtain information about pulp and paper operations, equipment, and air pollution control devices. This information

- gathering effort wa s 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 Bo x 40, Big Isl and, 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, NCASIU.S. Environmen tal 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, OAQP S/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 Contract or, 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 followi ng 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 belo w. The topics discussed are (A) general information, (B) pulp mill, (C) paper mill, (D) chemical recovery and energy generation, (E) wastewater treatment , an d (F) new substance review process

.

A

. General Information

The Big Island M ill (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 line rboard machine. Today, the mill produces corrugating medium from semichemical hardwood pulp and recovered fiber on two paper machines with a n approximate capacity of 356

, 000 tons per year

, and 100% recycled linerboard or medium on a third paper machine wit h 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 clippi ngs (DLK) from box plants

. Hardwood c hips are purchased from facilities that participate in the Sustainable Forestry Initiative (SFI)

. Wood c hips are stored in a pile, reclaimed

, screened

, and sent to four Pandia continuous digesters for cooking , with a co mbined capacity of 315,360 tons per year, utilizing the non

- sulfur semichemical process . These Pandia continuous dige sters are considerably different from Ka m y r digesters , as they process pulp horizontally in plug

- flow conditions . C ommon cook time utilizi ng these digesters is 6 minutes. Ap p roximately 125,000 tons of additional pulping capacity for recovered fiber is provided by a DLK pulper located inthe Medium Mill. The total pulp ing capacity for the mill is approximately 775 ,000 tons
per year

.

Digester Chips Pulp Washers Refiners To Paper Machine

F igure 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 produc ing approximately 336,000 tons per year of corrugati ng 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

. PM 4 is a fourdri ni er 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 t he chemical recovery area, there is one evaporato r 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 ta nk that combusts approximately 44 gallons per minute of black liquor solids was installed in 2009

. Initially, a steam reforming black liquor gasif i cation 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

.

T he 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 als o 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 wastewa ter treatment at the facility and then discharged into the James Riv er

. 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 con version 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 mus t 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 gallon s 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 req uestor 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, proprieta ry 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 O peration s L eader. Each of these individuals investigate s related information

, such as health hazard information, regulations affected, reactive chemical considerations (storage, product impact, etc.), and

a personal prot ective 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 proces s 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 m ill personnel estimated that 100 or more chemicals per year would need to be reviewed for more complicated processes, such as tissue making.