Date: July 22 , 2011 (Finalized September 30, 2011)

Subject: Trip Report for Site Visit

– Domtar Paper Company, LLC Risk and t echnology review for pulp and paper production and combustion sources NESHAP

I

. Purpose

The purpose of the site visit to Domt ar Paper Company in Bennettsville, South Carolina

, was to obtain information about pulp and paper operations, equipment, and air pollution control devices. Thi s information

- gathering effort wa s part of regulatory development work for the Risk and Technolog y Review (RTR) for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the pulp and paper industry.

II

. Place and Date

Domtar Paper Company, LLC ( Marlboro Mill ) 585 Willamette Road, Bennettsville, SC 29512 (843) 454

- 8955

July 20, 2011

Mailing address: PO Box 678, Bennettsville

, SC 29512

III

. Attendees Domtar Paper Company, LLC

• Bill Edwards, VP/Mill Manager

• Athena Strickland, Technical Services Manager

• Guy Martin, Senior Director

- Environment

• Chuck Thames, Final Products Manager

• Monte Ba t chelor, Health and Safety Manager

• Chris Gore, Pulp and Util i ties Manager

• Bill Seamans, Fiberline Manager

• Ray Crouse, Utilities Manager

• Amber Bowen, Process Engineer

• John Pinkerton, NCASI

U.S. Environmental Protection Agency (EPA)

• Bil l Schrock, Environmental Engineer

, Office of Air Quality Planning and Standards (OAQPS)/Sector Polices and Programs Division (SPPD)/Natural Resources Group (NRG)

• John Bradfield, Environmental Engineer, OAQPS/SPPD/NRG

• Kelley Spence, Enviro nmental Engineer, OAQPS/SPPD/NRG

• Katie Hanks , EPA contractor, Research Triangle Institute (RTI)IV

. Visit Summary

The site visit began with a meeting to discuss mill background, safety, and the agenda of the visit. A flow chart of the process, provided by D omtar, is attached (Attachment 1). Following the meeting, a tour of the facility was provided and the following areas were observed: wood yard, pulp mill, bleach plant, recovery area, caustic area, power house, wastewater treatment, and paper making 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) Bleach Plant, (D) Paper Mill, (E) Chemical Recovery and Energ y Generation, and (F) Wastewater Treatment.

A

. General Information

Marlboro Paper Mill (NEI47074, RTI107)

, the most recently opened pulp and paper mill in the United States

, was opened by Willamette in 1990, acquired by Weyerhaeuser in 2002, and became part of Domtar in 2007. The facility was the last Greenfield project installed in the US . Domtar has 10 paper mills. The Marlboro Paper mill produces approximately 380,000 tons of uncoated freesheet per year and 65,000 air

- dried metric tons of market pulp per year. Domtar also uses best practices and benchmarking across the company

, and with other companies

, to improve efficiency and decrease environmental impacts.

The Marlboro mill owns 2,300 acres of land near the Pee Dee River and employs approximate ly 325 people ; the facility is ISO 14001 certification ready. The main products from the facility are bleached softwood and bleached hardwood kraft market pulp and uncoated freesheet. The Marlboro mill is FSC (Forest Stewardship Council) third party certif ied and 100% of their wood meets the FSC controlled wood standar d

. Up to 2.2 million tons of wood per year are used to produce a maximum of 1410 bleached air dried tons of pulp per day, which can be used to produce up to 1140 off machine tons of paper per day and 518 air dry tons of market pulp per day . T he mill als o utilizes baled recycled paper for some grades

. The mill has an ann ual paper production capacity of 416,100 tons and an annual pulp production capacity of 189,070 tons, with 1 pulp line and 1 paper machine. The facility is a fully integrated facility with a wood yard, pulp mill, bleach plant, recovery and causticizing area, utilities, paper mill , and wastewater treatment. A flow diagram of the processes at the mill can be found in Attachment 1

.

B

. Pulp Mill

Wood arrives at the mill in the form of logs, which are debarked and chipped, and chips

. C hips are screened prior to pulping, Figure 1. Up to 2.2 million green tons of wood per
year is consumed for pulping

. The Marlboro mill utilizes t he kraft process with 8 RDH batch digesters for pulping hardwood and softwood. The RDH process (Rapid Displacement Heating) is a more efficient process for delignification than conventionalbatch digesters

. The digester is charged with chips similar to a r egular digester and is packed with steam allowing for increased chip capacity in the digester. S team and air are then displaced with cool black, hot black and hot white liquor s . This process provides for a more uniform and stronger pulp and lower steam co nsumption. The mill chose to use RDH batch digesters instead of a continuous digester because of the need to switch between the pulping of hardwood and softwood. Up to 14 5 0 air

- dried tons of unbleached pulp is produced per day. By

- products of the process are resin soaps (10,000 tons annually) and turpentine (100,000 gals annually). The mill also purchases secondary pulp.

Chipping and Debarking Digesters Chip Screens

Blow Tank Brown Stock Washing Screening

To Oxygen Delignification Chips

Logs

Figure 1: Wood yard and pulp mill process flow diagram

C

. Bleach Plant

The bleach plant utilizes a n elemental chlorine free (ECF) bleaching sequence, D (Eop) D with oxygen delignification as a pretreatment , Figure 2

. The R10 process is used to generate the chlorine dioxide used in the process. A Lurgi

- process was previously used at the mill to generate chlorine dioxide, but it was s hutdown due to environmental concerns

, large energy consumption , and high maintenance costs

. The mill produces up to 1410 air

dried tons of bleached pulp per day

. C urrently 20 % is sold as market pulp and 80 % is used at the facility to produce paper.Oxygen Delignification Unbleached Pulp Washers D1 Bleach Stage

D1 Washer EO Bleach Stage EO Washer

D2 Bleach

Stage D2 Washer Bleach Pulp Storage

Figure 2: Bleach plant process flow diagram

D

. Paper Mill

There is one twin

- wire paper machine with a capacity of 416,100 tons per year, and one pulp dryer with a capacity of 189,070 tons per year at the Marlboro facility , Figures 3 and 4

. The machi ne utilizes a sym

- former and has a machine width of 354 inches and a maximum speed of 4 ,500 feet per minute. A sym

- sizer is used to surface size (or surface coat) the sheet using a cooked starch

- based coating. The main grades produced are market pulp (blea ched softwood and bleached hardwood) and uncoated freesheet.

### Refiners Screen Blend Chest

Machine

Chest Cleaners Screen

Whitewater 

### HW pulp (from refiners)

S W pulp

Headbox & Former Wet Press Dryers

Size Press Dryers Reel

Figure 3 : Paper mill process flow diagramPressure

screens Headbox Machine

Chest

Double

wire Former &

Press Heavy Duty Press Pulp Dryer

To Bale Line and Warehouse Whitewater Pulp Whitewater

Figure 4 : Pulp dryer process flow diagram

E

. Chemical Recovery and Energy Generation

The mill utilizes one recovery boiler with a solids capacity of 4.4 million pounds per day and a steam generation capacity of 628,400 pounds per hour. The recovery boiler produces approximately 75 % of the steam required for mill processes by burning black liquor and utilizes 5 air zones to reduce NOx emissions , control CO emissions and reduce
carryover

. The chemical recovery process and causticizing are shown in Figure 5 and 6, respectively. The facility boasts the best SO 2 emission rate (0.07 kg/tonne) of pulp and paper facilities in North America, e ven though it burns petroleum coke in the lime kiln. One expressed concern for the facility is separate standards for individual HAPs in the boiler MACT; the boilers may meet one criterion (i.e. NOx) by a significant margin, but it may barely meet other cr iteria (i.e. CO) because the control of some pollutants cases increases in other pollutants. The mill also uses a 280,000 pound per hour biomass fueled power boiler and a 51.4 MW turbine generator, to generate power. There is also a small medium pressure g as fire package boiler on site that is used to supplement the steam system as needed. This boiler is rated up to 225,000 pounds per hour . T he mill focuses
on energy benchmarking; by reducing energy requirements, the facility will reduce its greenhouse ga s emissions. Only about 5% of the mills steam needs are supplied with natural gas. River water must be treated and de

- mineralized before utilization as boiler feedwater.Evaps (6 and a soap skimmer)

Recovery Boiler Concentrators

Smelt Dissolving Tank Green Liquor Clarifier To Causticizers Liquor From Digesters Evaps (4 and a soap skimmer)

Smelt

Figure 5: Recovery process flow diagr a m

Lime Mud

Washer White liquor Clarifier

Pre

- Coat

Filter Lime Kiln Green Liquor

Causticizers To Digesters White Liquor Slaker

Lime

Figure 6: Causticizing process flow diagramF

. Wastew ater Treatment

The mill is a low

- odor facility, as it is a totally collected kraft process

, and approximately 50.6 m 3 of water is used per tonne of paper. The waste sent to the landfill is approximately 5 kg per tonne of p aper. Approximately 16 million gallons of eff luent per day are sent to waste water treatment and t he Marlboro mill utilizes an aeration stabilization basin (ASB ). Note that methanol is removed via a steam stripper integrated with the black liquor evaporato rs and NCG incinerator. Effluent is processed using a primary clarifier, 2 ASBs, and 3 polishing ponds, Figure 7. Water can be retained for up to 65 days in wastewater treatment, before returning to the river. Sludge from the primary clarifier is pressed and burned for energy in the biomass boiler

.



## Primary Clarifier No. 1 ASB No. 2 ASB

No. 3 Polishing Pond No. 2 Polishing Pond No. 1 Polishing Pond

Pee Dee River Effluent

Figure 7 : Wastew ater t reatment p rocess f low d iagram

1 AttachmentAttachment 1