United States Environmental Protection Agency Office of the Administrator Washington, DC 20460 Mail Code 1802 EPA 100-R-00-006 December 1999 www.epa.gov/reinvent Project XL Progress Report Weyerhaeuser Flint River Operations On March 16,1995, the Clinton Administration announced a portfolio of reinvention initia- tives to be implemented by the U.S. Environmental Protection Agency (EPA) as a part of its efforts to achieve greater public health and environmental protection at a more reasonable cost. Through Project XL, which stands for excellence and Leadership, EPA enters into specific proj ect agreements with public or private sector sponsors to test regulatory, policy, and procedural alternatives that will produce data and experiences to help the Agency make improvements in the current system of environmental protection. The goal of Proj ect XL is to implement 50 proj ects that will test ways of producing superior environmental performance with improved economic efficiencies, while increasing public participation through active stakeholder processes. As of October 1999,15 EPA XL proj ects are in the implementation phase and 3 5 XL proj ects are under development. EPA Proj ect XL Progress Reports provide overviews of the status of XL proj ects that are implementing Final Proj ect Agree- ments (FPAs). The progress reports are available on the Internet via EPAs Proj ect XL web site at http://www.epa.gov/ProjectXL. Or, hard copies may be obtained by contacting the Office of Reinvention's Project XL general information number at 202-260-7434. Additional information on Proj ect XL is available on the web site or by contacting the general informa- tion number. Background Weyerhaeuser Company is one of the largest private owners of forest, with 5.4 million acres in the United States. Among its products are timber, paper, and pulp. Weyerhaeuser's Flint River pulp manufacturing facility in Oglethorpe, Georgia, manufactures 320,000 tons per year of absorbent fluff pulp, a material used in diapers. The facility was opened in 1981 and is located 100 miles south- west of Atlanta, Georgia. Weyerhaeuser is striving to minimize the environmental impact of its manufacturing processes on the Flint River and the surrounding environ- ment by pursuing a long-term vision of aMinimum Impact Mill (MEVI). Through a \ \r J-JL- J Weyerhaeuser XL Project v Oglethorpe, Georgia Major Milestones Septembers, 1995 Weyerhaeuser XL Proposal Submitted January 17, 1997 Final Project Agreement Signed January 28, 1998 First Annual Stakeholders Meeting Montezuma, Georgia February 4, 1999 Second Annual Stakeholders Meeting Flint River Facility 2006 Final FPA Commitments to be Met ------- Weyerhaeuser XL Project 12-31-99 combination of enforceable requirements and voluntary goals, the Weyerhaeuser XL proj ect will improve the environmental health of the nearby Flint River and surrounding watersheds by cutting bleach plant effluent by 5 0% over a 10-year period; reducing water use by one million gallons a day; cutting solid waste generation by 50% over a 10-year period; preparing and implementing a facility-wide plan to reduce energy use; reducing the generation of hazardous waste to a level where the Flint River facility can qualify as a condi- tionally exempt small-quantity generator; maintaining criteria air pollutant emissions at levels below facility-wide emission caps; preparing and implementing a site-specific alternative compliance plan for hazardous air pollutant (HAP) emissions; improving forest management practices in over 300,000 acres of land; and adopting the International Organization for Standardization (ISO) 14001, an international standard that defines the elements of a continually improving environmental management system. The Experiment The Weyerhaeuser proj ect tests a facility-wide permitting approach for water effluent discharges, air emis- sions, and solid waste generation that is designed to promote the MDVI concept. Minimum impact manufactur- ing contains the elements of a comprehensive pollution prevention program designed to minimize the use of raw materials and to stop waste generation rather than to rely on end-of-pipe remedies. The Flexibility The Weyerhaeuser XL proj ect establishes a long-term plan to continuously reduce the Flint River facility's impact on air, water, land, and the surrounding watersheds. As an incentive to achieve superior environmental performance at Weyerhaeuser's Flint River facility, EPA and the Georgia Environmental Protection Division (EPD) are providing more flexible and cost-effective processes for regulatory compliance. EPA and Georgia EPD are offering Weyerhaeuser regulatory flexibility in the areas of environmental performance reporting, effluent permitting, air quality permitting, hazardous air pollutant compliance, and solid waste permitting. The statutory programs, and EPA offices administering those programs, that affect the Weyerhaeuser XL proj ect are Clean Water Act (CWA) programs administered by EPAs Office of Wastewater Management and EPAs Office of Wetlands, Oceans, and Watersheds; Resource Conservation and Recovery Act (RCRA) programs administered by EPAs Office of Solid Waste; Clean Air Act (CAA) programs administered by EPAs Office of Air Quality Planning and Standards; and Pollution Prevention Act (PPA) programs administered by EPAs Office of Prevention, Pesticides, and Toxic Substances. All permitting programs required to implement the Final Proj ect Agreement (FPA) have been delegated by EPA to the State of Georgia. Permits are issued by Georgia EPD. Reporting. EPA Region 4 and the Georgia EPD are allowing Weyerhaeuser the flexibility to consolidate some of the facility's routine permitting reports into two reports per year. These reports are available on EPAs Project XL web site at http://www.epa.gov/ProjectXL. ------- Weyerhaeuser XL Project 12-31-99 Effluent Permitting. EPA Region 4 and Georgia EPD have revised Weyerhaeuser's National Pollution Dis- charge Elimination System (NPDES) permit to include more stringent effluent limits on biological oxygen demand (BOD), total suspended solids (TSS), and adsorbable organic halides (AOX); streamline the permit renewal process; eliminate fish tissue sampling requirements due to improvements in process technologies that have eliminated detectable dioxin levels in effluents; remove a requirement for additional assimilative capacity studies of the Flint River; and allow annual compliance certification in lieu of periodic discharge monitoring reporting (DMR) due to the company's 10-year history of meeting all required discharge levels. Air Quality Permitting. EPARegion 4 and Georgia EPD have modified the facility's existing air quality permit to include dual emission caps for air pollutants. The caps reduce allowable air emissions from the facility by 60% below limits that would be required under a standard permit. The dual emission caps are (1) a cap that allows the recovery furnace, smelt dissolving tank, calciner, and combination boiler (the facility's four maj or sources of emissions) to be operated to their design capacity without triggering permit review; and (2) a cap covering all facility sources except those four maj or sources. The dual emission caps apply to particulate matter (PM), sulfur dioxide (SO2), nitrous oxides (NOx), carbon monoxide (CO), volatile organic carbons (VOCs), and total reduced sulfur (odor-causing pollutant). This modified air quality permit streamlines the permit re- newal process, includes alternate excess emission reporting protocols, and includes a protocol for conducting manufacturing process experiments without triggering a permit review. Hazardous Air Pollutant Compliance. EPA Region 4 and Georgia EPD have agreed to provide Weyerhaeuser the flexibility to demonstrate HAP emission reductions using innovative pollution prevention approaches rather than end-of-pipe HAP controls. Weyerhaeuser committed to preparing an alternative compliance plan that will present the HAP emission reductions to be achieved by the facility following promul- gation of the Maximum Available Control Technology (MACT) Cluster Rule for the pulp and paper industry. Solid Waste Permitting. EPA Region 4 and Georgia EPD will modify Weyerhaeuser's solid waste permit to allow nonhazardous industrial wastes containing free liquids to be disposed of in a permitted, onsite landfill. Promoting Innovation and System Change Proj ect XL provides EPA opportunities to test and implement approaches that protect the environment and advance collaboration with stakeholders. EPA is continually identifying specific ways in which XL proj ects are helping to promote innovation and system change. The innovations and system changes emerging from the Weyerhaeuser XL project are described below. Pulp and Paper Cluster Rules. The Weyerhaeuser XL proj ect provides a pilot for testing alternative compli- ance approaches to a new MACT standard. Weyerhaeuser will prepare an alternative compliance plan that will present the HAP emission reductions to be achieved by the facility following the April 15,1998, promulgation of the MACT Cluster Rule for the pulp and paper industry. EPA will use a site-specific rulemaking or similar mechanism to authorize alternative MACT compliance. Consolidated Reporting. The Weyerhaeuser XL project allows the facility to consolidate reporting for some of the applicable Federal, state, and local permitting and regulatory programs into two comprehensive reports each year. The XL proj ect tests an approach to streamlining both permitting and the collection of higher quality information from regulated industries. The XL proj ect will influence development of the comprehensive infor- mation management plan to be prepared by the EPA's new consolidated Environmental Information Office. ------- Weyerhaeuser XL Project 12-31-99 Dual Emissions Caps. The Weyerhaeuser XL proj ect provides for dual emissions caps that limit facility-wide emissions to levels 60% below those that would be required under a standard permit. In return, Weyerhaeuser can change certain equipment operating conditions, as long as they do not result in emissions exceeding the caps, to respond to customer needs without triggering permit reviews. NPDESPermitting. Weyerhaeuser's NPDES permit has been revised to include more stringent effluent limits on BOD, TSS, and AOX. In return, Weyerhaeuser (1) is not required to conduct fish tissue sampling because improvements in process technologies have eliminated detectable dioxin levels in effluents; (2) is not required to conduct additional assimilative capacity studies of the Flint River; and (3) can provide an annual certification of compliance instead of periodic DMR because of the company's 10-year history of meeting all required dis- charge levels. Comprehensive Environmental Management System (EMS). Weyerhaeuser will voluntarily revise an EMS at the Flint River facility to conform with the ISO 14001 standard. The facility is developing a comprehensive manual of standard work procedures for plant employees. As announced in the Federal Register on March 12, 1998, EPA is evaluating options that will lead to development of an Agency policy on EMSs. The Weyerhaeuser XL proj ect will provide data on the compliance and environmental benefits of an EMS approach. Timber land Re source Strategies. Weyerhaeuser also will reduce solid and hazardous waste generation and improve forest management practices in more than 300,000 acres of timberland. EPA will participate in review and evaluation of feasibility studies with potential applicability of results across the pulp and paper industry. Project Commitment Summary This table and the environmental performance section that follows summarize progress in meeting commitments described in the FPA for Weyerhaeuser's Flint River facility. The facility has completed Phases I, II, and III of its environmental management plans (which are therefore not provided in the following table), is nearing comple- tion of all Phase IV environmental management plans, and is in the process of implementing Phase V feasibility studies. Commitment Status Minimum Impact Mill Phase IV Implementation Schedule Construct brownside optimization equipment. Construction and process optimization were completed in 1997. Upgrade odor control system. Construction and process optimization were completed in 1996. Reduce energy steam use. Construction and process optimization were completed in 1997. Revise existing EMS to conform to ISO 14001 EMS (nonenforceable), including operational procedures, record keeping, auditing, quality assurance, and permit requirements. The process of ISO 14001 documentation, originally scheduled for completion in mid-1997, has proceedec slower than expected. Weyerhaeuser has completed a corporate-wide guidance document for implementing an ISO 14001 EMS. The Flint River facility is identify ing environmental aspects of the facility's operations. Completion of ISO 14001 EMS documentation for the Flint River facility is expected in 2000. ------- Weyerhaeuser XL Project 12-31-99 Commitment Status Minimum Impact Mill Phase V Feasibility Studies Conduct feasibility studies for reducing solid waste generation through source elimination, by-product reuse, and energy recovery. A compost using facility by-products that is suitable for land application has been produced; an economic analysis of composting is underway, as are long-term land application feasibility trials. Conduct studies of mill water use to reduce the quantity of treated wastewater discharged into the river. A feasibility study has been completed on reusing excess white water in the bleach tower. Feasibility studies are under way on reusing bleaching plant filtrate in the wood yard log flume and on using waterless packing for rotary equipment. Conduct an energy conservation study to identify potential conservation practices and prepare a long- term energy conservation plan to reduce plant energy demand and power boiler steaming rates. Four small-scale energy conservation projects have been completed: returning product unit condensate to the boiler feedwater system, returning evaporator condensate to the recaust area, reducing secondary temperatures in the recovery boiler, and using weak filtrate to clean the cylinder mould. A facility-wide energy conservation study was completed in early 1999; the results of the study will be used to prepare a long-term energy conservation plan. Conduct feasibility studies, including water use, process elements, finished product quality, and multimedia impacts, to determine how to reduce the volume of bleach plant effluent flow. An initial feasibility study on creating a closed circula- tion bleach plant has been completed. The initial assessment determined that this is not a cost-effective option given market conditions. Additional feasibility studies are planned for reducing bleach plant effluent. Conduct FLAP emission reduction feasibility studies to identify pollution prevention approaches for achieving FLAP emission reductions. Emissions testing on facility sources has been com- pleted. Testing of condensate streams has begun. The data will form the basis for drafting aMACT alternative compliance plan and site-specific rule for the facility. Implement timberland resource strategies for over 300,000 acres of forest to designate forest buffers, minimize erosion caused by roads, improve stream- side management, develop water bars to stabilize soils, safeguard unique habitats, implement landscape planning, establish wildlife corridors, and protect threatened and endangered species. Documentation and implementation of timberland resource strategies was completed in the fall of 1997. Water Revise the NPDES permit to provide more stringent effluent limits for BOD, TS S, and AOX; to streamline the permit renewal process; to remove the fish tissue sampling requirement; to remove the requirement for additional assimilative capacity studies of the Flint River; and to allow annual compliance certification in lieu of DMR reporting. The NPDES permit was revised in July, 1997. ------- Weyerhaeuser XL Project 12-31-99 Commitment Status Water (Continued) Modify the surface water withdrawal permit to reduce the daily maximum withdrawal limits by one million gallons per day (MOD). The surface water withdrawal permit was sched- uled to be modified on January 1, 1998. It has been delayed and is now expected during 2000, follow- ing completion of water conservation studies. Solid Waste Modify the solid- waste permit to allow disposal of nonhazardous industrial wastes containing free liquids into a permitted onsite landfill. Weyerhaeuser will continue stormwater and leachate treatment and quarterly groundwater monitoring. Weyerhaeuser submitted a solid-waste permit modification request in late 1998. Hazardous Waste Reduce the generation of hazardous wastes to a level where the facility can qualify as a conditionally exempt small -quantity generator. Weyerhaeuser achieved designation as a condition- ally exempt small quantity generator in 1 997 by recycling and reusing a solvent (methyl ethyl ketone) used for cleaning painting equipment. Air Modify the facility's air quality permit to include dual emissions caps, to streamline the permit renewal process, to include alternate excess emission report- ing protocols, to include an alternate compliance testing protocol, and to include a protocol to allow experimental trials without triggering permitting. Revise Flint River's Title V permit to postpone permit modifications for activities undertaken pursuant to the XL proj ect until the permit comes up for renewal . Prepare a site-specific MACT alternative compliance plan that will detail how Weyerhaeuser will reduce HAP emissions to levels equal to or exceeding those required under the MACT Cluster Rule. The air quality permit was revised in December, 1997. The permit was revised in December, 1997. The MACT Cluster Rule for the pulp and paper industry was promulgated in April 1998. EPA, Georgia EPD, and Weyerhaeuser have met twice to begin development of a site-specific MACT applicability assessment. Results of emissions and condensate testing will be used to prepare a MACT alternative compliance plan. Once the plan is completed, EPA will prepare a site-specific rule. Reporting Prepare annual reports for distribution to EPA, the State of Georgia, and local stakeholders. Prepare midyear reports for distribution to EPA, the State of Georgia, and local stakeholders. Distribute data and reports to the public upon re- quest. Annual reports have been completed for 1997 and 1998. The 1999 annual report is due to be completed in January 2000. Midyear reports have been completed for 1 997, 1998, and 1999. As needed. ------- Weyerhaeuser XL Project 12-31-99 Stakeholder Meetings Conduct annual public meetings in January in the vicinity of the Flint River facility. The first annual stakeholders meeting was held in Montezuma, Georgia, on January 28,1998. The second annual stakeholders meeting was held at the Flint River facility on February 4, 1999. Environmental Performance This section summarizes progress in meeting the environmental performance commitments described in the FPA for Weyerhaeuser's Flint River Facility. Raw Water Usage: Reducing the facility' s use of water from the Flint River will reduce the quantity of treated wastewater discharged back into the river. Weyerhaeuser's goal is to reduce water withdrawal from the Flint River to a voluntary limit of 10.18 MGD monthly average by January 1,2000. Baseline water withdrawal at the facility is 11.18 MGD monthly average. The facility's surface water withdrawal permit was scheduled to be modified to reduce enforceable withdrawal limits by 1.0MGD,to 11.5 MGD monthly average, by January 1, 1998. Permit modification has been delayed and is now expected during the year 2000 following completion of water conservation studies. Progress: The water reductions obtained from mod- ernization projects in 1996 and 1997 were not suffi- cient to offset increased water use from other facility process areas, which resulted in an increase from the baseline to 11.74 MGD monthly average for 1997. In 1998, water use was reduced to 11.49 MGD monthly average through the daily water conservation efforts of production operators. By midyear 1999 water use increased to 12.19 MGD monthly average. The primary cause of the increased water use was customer demand for a higher brightness pulp, which requires more water to manufacture. Water use has been higher than normal, but is not greater than the current permit limit Raw Water 1999YTD 1998 Actual 1997 Actual 1996 Actual Voluntary Goal Baseline (1993-95 monthly averages) New Permit Goal Enforceable Permit 12.19 11.49 11.74 11.91 10.18 11.18 11.50 12.50 10.00 10.25 10.50 10.75 11.00 11.25 11.50 11.75 12.00 12.25 12.50 Millions of Gallons per Day Several facility staff are evaluating potential proj ects that would reduce water use. One of the most promising proj ects is to increase the capacity of a water pump that would prevent overflow of white water in the bleach plant. The white water that overflows currently enters the sewer and is replaced by new withdrawals. A detailed engineering review is being conducted to ensure that no part of the manufacturing process will be adversely affected by this change. Eliminating the overflow of white water in the bleach plant could potentially save 400,000 gallons of water per day. Other water conservation proj ects continue to be studied, such as sending bleaching filtrate to replenish water lost in the wood yard log flume and collecting bearing cooling water from boiler fans and sending it to the power boiler scrubber. Water conservation proj ects are a priority in future reporting periods. Bleach Plant Flow: Weyerhaeuser's long-term goal is to reduce bleach plant effluent flow by 50% to 10 cubic meters per air dried metric ton (ADMT) of finished product (fluff pulp used to make diapers) by the year ------- Weyerhaeuser XL Project 12-31-99 2006. The expected environmental benefits include (1) a two MGD monthly average water-use reduction (bleach plant flow is approximately 48 to 49% of the total plant water usage); (2) reductions in effluent BOD, TSS, and AOX; and (3) HAP emission reductions. To reach these goals, Weyerhaeuser plans to conduct feasibility studies on water use management. The results of these studies will be used by EPA, Georgia EPD, and Weyerhaeuser to negotiate a NPDES permit to be issued in 2002. The permit will contain enforceable measures for reducing effluent flow to an agreed-upon level by 2006. Bleach Plant Flow 1999YTD 1998 Actual 1997 Actual 1996 Actual FPA Goal by 2006 Baseline (1993-95 monthly averages) 10.0 20.0 20.0 20.0 20.0 20.0 Progress: Bleach plant flow remained unchanged at 20 cubic meters per ADMT in 1996,1997,1998, and the first half of 1999. An initial feasibility study to determine the equipment required to reduce bleach plant flow, the effect of the equipment on product quality and effluent, and estimated capital costs has been completed. Information gained from this study and other pertinent information will be reviewed by EPA and Georgia EPD in connection with the reissuance of the mill'sNPDES permit. The company's initial assessment is that the cost of creat- ing a closed bleach plant would not justify moving ahead with maj or bleach plant effluent quantity reductions. Pulp purchasers in Europe and North America have indicated little interest in paying a higher price for pulp from a mill with a closed bleach plant. Some additional testing for internal improvements in the bleach plant will be conducted to reduce bleach plant flow without requiring the maj or capital expenditures of creating a closed bleach plant. Biological Oxygen Demand (BOD) in Effluent: Weyerhaeuser has committed to reduce BOD levels in treated wastewater discharged to the Flint River. The facility's January 1998 NPDES permit allows the dis- charge of 3.8 pounds of BOD per ADMT of finished product. 9 10 11 12 13 14 15 16 17 18 19 20 21 Cubic Meters per Air-Dried Metric Ton of Finished Product Biological Oxygen Demand Progress: Weyerhaeuser has modernized several components of the pulping process, which has reduced the amount of organic materials, and consequently the BOD levels, in bleach plant wastewater. Weyerhaeuser reduced the amount of BOD in its effluent from a 1997 level of 3.01 pounds per ADMT to a 1998 level of 2.13 pounds per ADMT. During the first half of 1999, BOD levels in facility effluent increased to 2.74 pounds per ADMT. Unreliable operation in a facility process during 1999 has caused increased pro- duction of offgrade pulp, which is recycled through the pulp manufacturing process. This has increased the amount of water used, effluent produced, and BOD levels per ton of finished product. Total Suspended Solids (TSS) in Effluent: Weyerhaeuser has committed to reducing TSS levels in treated wastewater discharged to the Flint River. The facility's January 1998 NPDES permit allows the discharge of 4.09 pounds of TSS per ADMT of finished product. *Perrnit Level Effective 1-1-98 Baseline (1993-95 monthly averages) Allowable under Guideline Requirements 01234 Pounds per Air-Dried Metric Tons of Finished Product 'Units used in the NPDES permit are pounds per day. This data is collected as required by the permit and is available. The permit level has not been exceeded. ------- Weyerhaeuser XL Project 12-31-99 1998 Actual *Permit Level Effective 1-1-98 Base!lne(1993-95 monthly averages) Allowable under Guideline Requirements Progress: Weyerhaeuser has modernized several components of the pulping process, which has reduced the amount of TSS in bleach plant wastewater. Weyerhaeuser reduced the amount of TSS in its effluent from a 1997 level of 3.13 pounds per ADMT to a 1998 level of 2.8 pounds per ADMT. During the first half of 1999, TSS level sin facility effluent increased to 4.22 pounds per ADMT. TSS appears to be over the permit limit, but the pounds per ADMT unit used in the FPA is not the same measure as that used in the NPDES permit, which uses pounds per day. TSS is not over the NPDES limit. Unreliable operation in a facility process during 1999 caused increased production of offgrade pulp, which is recycled through the pulp manufacturing process. This increased the amount of water used, effluent produced, and TSS levels per ton of finished product. Adsorbable Organic Halides (AOX) in Effluent: Weyerhaeuser has committed to reducing AOX levels in treated wastewater discharged to the Flint River. The facility's January 1998 NPDES permit allows the discharge of 0.15 kilograms of AOX per ADMT of finished product. The AOX limit under Project XL is 4% beyond the best available technology standards proposed by EPA. Progress: Weyerhaeuser has modernized several components of the pulping process, which has generally maintained the levels of AOX in bleach plant wastewater. AOX levels were 0.10 kilo- grams per ADMT in 1996,1997, and 1998. During the first half of 1999, levels of AOX in facility effluent remained at 0.10 kilograms per ADMT. Solid Waste Generation: Weyerhaeuser has committed to reducing solid waste generation by 50% by the year of 2006 from the MIM Phase IV goal of 621 pounds per ADMT, which would be 310 pounds per ADMT. Source elimination, by-product recycling and reuse, and by-product energy recovery will be used to accomplish this goal. Progress: Weyerhaeuser has modernized several components of the pulping process, which has generally reduced the amount of solid waste generated by the plant. Solid waste generation at the facility in 1997 was 409 pounds per ADMT (59% of baseline). This increased in 1998 to 461 pounds per ADMT (67% of baseline). The increase was caused primarily by the generation of over 9,200 tons of addi- tional lime mud from two calciner operating and mechanical incidents. On the positive side, a total of 1,550 tons of solid waste reductions were achieved in waste clarifier sludge from enhancing performance of the finish fiber cleaners, from reducing power boiler fly ash, from reducing screening room knots from the digester, and from recovering wood yard debris. Total Suspended Solids 0 2 4 6 8 10 Pounds per Air-Dried Metric Ton of Finished Product *Units used in the NPDES permit are pounds per day. This data is collected as required by the permit and is available. The permit level has not been exceeded. Adsorbable Organic Halides 1999YTD 1998 Actual 1997 Actual 1996 Actual *Permit Level Effective 1-1-98 Baseline (1993-95 monthly averages) Allowable under Guideline Requirements 0.10 0.10 0.15 0.156 0.00 0.04 0.08 0.12 0.16 Kilograms per Air-Dried Metric Ton of Finished Product "Units used in the NPDES permit are pounds per day. This data is collected as required by the permit and is available. The permit limit has not been exceeded. Solid Waste Generation FPA Goal by 2006 Baseline (1995 level) 461 409 310 300 400 500 600 700 Pounds per Air-Dried Metric Ton of Finished Product ------- Weyerhaeuser XL Project 12-31-99 During the first half of 1999, solid waste generation increased to 475 pounds per ADMT (69% of baseline). The increase was predominately due to additional lime mud generation caused by calciner operational prob- lems. The increase in lime mud generation offset continued progress in reducing generation of power boiler fly ash by approximately 200 tons (6%), reducing generation of screening room knots by about 118 tons (27%), and recovering 982 tons of wood yard debris. The facility will emphasize the calcining and recausticizing operations to reduce lime mud generation during the remainder of the year. The University of Georgia has completed composting trials showing that composting is a viable alternative to landfilling of certain solid wastes. A draft of the composting feasibility report concludes that the composting process results in a stable product that can be used in horticultural, agricultural, and other soil blending applica- tions. The compost has been used on a test plot for surface mine reclamation and has shown promising results. The China Clay Producers Association has requested the compost for an expanded field study. If the ex- panded study is successful and the economics are favorable, composting of process residuals would be com- mercially viable. The Weyerhaeuser study plan for the field application of compost and some process wastes will continue. Field plots amended by compost and wastes have been planted with seedlings. A pine seedling survivability survey has been conducted but, due to drought conditions experienced this spring, growth measurements will not be performed until early next year. Air Emissions of Particulate Matter: The facility's December 1997 air quality permit includes dual emission caps for air pollutants. The cap on all emissions of par- ti culate matter is 589 tons per year, which is a 60% reduction from the 1,472 tons per year allowed under a standard permit. Progress: Particulate matter air emissions increased slightly from a 1997 level of 3 85 tons per year (65% of capped level) to a 1998 level of 390 tons per year (66% of capped level). Air emission levels for 1999 will be reported in the 1999 annual report, due in January 2000. Air Emissions of Total Reduced Sulfur: The facility's December 1997 air quality permit includes dual emission caps for air pollutants. The total cap on all emissions of total reduced sulfur is 62 tons per year, which is a 60% reduction from the 155 tons per year allowed under a standard permit. Progress: Total reduced sulfur air emissions decreased from a 1997 level of 35 tons peryear (56% of capped level) to a 1998 level of 33 tons peryear (53% of capped level). Air emission levels for 1999 will be reported in the 1999 annual report, due in January 2000. 1998 Actual 1997 Actual 1996 Actual 1995 Actual Total Dual Emissions Cap Effective 12/97 Allowable Under Standard Permit 1998 Actual 1997 Actual 1996 Actual 1995 Actual Total Dual Emissions Cap Effective 12/97 Allowable Under Standard Permit Particulate Matter 390 385 423 457 589 1472 300 600 900 Tons per Year 1200 1500 Total Reduced Sulfur 33 35 39 43 62 155 30 60 90 120 Tons perYear 150 180 10 ------- Weyerhaeuser XL Project 12-31-99 Air Emissions of Sulfur Dioxide (SOJ: The facility's Decem- ber 1997 air quality permit includes dual emission caps for air pollutants. The total cap on all emissions of SO2 is 879 tons per year, which is a 60% reduction from the 2,197 tons per year allowed under a standard permit. Progress: Emissions of SO2 have increased from the 1996 level of 271 tons per year (31% of capped level) because steam energy conservation initiatives have reduced the power boiler steaming rate and furnace temperatures to a point where SO2 is difficultto control. Sulfur dioxide air emissions have since de- creased from a 1997 level of 624 tons per year (71% of capped level) to a 1998 level of 582 tons per year (66% of capped level). Air emission levels for 1999 will be reported in the 1999 annual report, due in January 2000. Air Emissions of Nitrous Oxides (NOJ: The facility's De- cember 1997 air quality permit includes dual emission caps for air pollutants. The total cap on all emissions of nitrous oxides is 1,300 tons per year, which is a 60% reduction from the 3,250 tons per year allowed under a standard permit. Progress: Nitrous oxide air emissions increased slightly from a 1997 level of 769 tons per year (59% of capped level) to a 1998 level of 795 tons per year (61% of capped level). Emissions increased because the power boiler operated about 100 hours more in 1998 than in 1997. Air emission levels for 1999 will be reported in the 1999 annual report, due in January 2000. 1998 Actual 1997 Actual 1996 Actual 1995 Actual Total Dual Emissions Cap Effective 12/97 Allowable Under Standard Permit 1998 Actual 1997 Actual 1996 Actual 1995 Actual Total Dual Emissions Cap Effective 12/97 Allowable Under Standard Permit Sulfur Dioxide 271 582 624 587 2197 500 1000 1500 Tons per Year 2000 2500 Nitrous Oxides 795 769 832 1300 3250 500 1000 1500 2000 2500 Tons per Year 3000 3500 Air Emissions of Carbon Monoxide (CO): The facility's December 1997 air quality permit includes dual emission caps for air pollutants. The total cap on all emissions of carbon monoxide is 2,516 tons per year, which is a 60% reduction from the 6,290 tons per year allowed under a standard permit. Progress: Carbon monoxide air emissions increased from a 1997 level of 1,454 tons per year (58% of capped level) to a 1998 level of 1,573 tons per year (63% of capped level). Emissions increased because the power boiler operated about 100 hours more in 1998 than in 1997. Air emission levels for 1999 will be reported in the 1999 annual report, due in January 2000. 1998 Actual 1997 Actual 1996 Actual 1995 Actual Total Dual Emissions Cap Effective 12/97 Allowable Under Standard Permit Carbon Monoxide 1454 1676 1780 2516 6290 1000 2000 3000 4000 5000 Tons per Year 6000 7000 11 ------- Weyerhaeuser XL Project 12-31-99 Volatile Organic Compounds 1998 Actual 1995 Actual Total Dual Emissions Cap Effective 12/97 Allowable Under Standard Permit 652 636 759 1945 500 875 1250 Tons perYear 1625 2000 Air Emissions of Volatile Organic Compounds (VOCs): The facility's December 1997 air quality permit includes dual emission caps for air pollutants. The total cap on all emissions of VOCs is 778 tons per year, which is a 60% reduction from the 1,945 tons per year allowed under a standard permit. Progress: VOC emissions have increased slightly from the 1996 level of 636 tons per year (82% of capped level) because steam energy conservation initiatives reduced the power boiler steaming rate and furnace temperatures. VOC emissions have since decreased from a 1997 level of 669 tons per year (86% of capped level) to a 1998 level of 652 tons per year (84% of capped level). Air emission levels for 1999 will be reported in the 1999 annual report, due in January 2000. Hazardous Air Pollutant (HAP) Emissions: HAP emission levels that Weyerhaeuser will be required to attain under the new MACT rule will be determined based on a site-specific assessment, Weyerhaeuser's development of an alternative compliance plan, and Federal and state agency approval of that plan. Progress: Weyerhaeuser hosted two meetings in 1998 with EPA and the State of Georgia to begin the process of developing a site-specific alternative compliance plan for the facility. The facility has completed HAP emis- sions testing around the steam stripping system, the bleach plant, the screening room, and oxygen stage sources to quantify the amount of HAPs (in this case, methanol) that are produced in these process areas. HAP emis- sions testing conducted on sources subj ect to the MACT rules shows the mill to be in compliance with the MACT standards for HAPs collection. This is a result of the system modifications completed in 1996. Deter- mination of the HAP content of various condensate streams, as required by the MACT Cluster Rule, has been completed and Weyerhaeuser has met with EPA and Georgia EPD. As a result, Weyerhaeuser modified piping to the steam stripper system, which should send additional methanol to the wastewater biological treatment system. A sampling study was initiated in September to determine the effect of the piping modification. When the results are compiled, Weyerhaeuser will meet with EPA and Georgia EPD to begin development of a MACT alternative compliance plan. This will be followed by preparation of a Flint River Site-Specific MACT Rule. The process will be completed before the MACT compliance date in April 2001. Hazardous Waste Generation: Weyerhaeuser committed to reduce its hazardous waste generation to the point where the facility's RCRA designation would be changed from a small-quantity generator (SQG) to a conditionally exempt small-quantity generator. Progress: Weyerhaeuser achieved this goal in 1997 by recycling and reusing a solvent (methyl ethyl ketone) used for cleaning painting equipment. Environmental Management System (EMS): An EMS instills the principles of continuous environmental improvement through pollution prevention rather than end-of-pipe controls. The existing Flint River Operations EMS will be revised to conform to the ISO 14001 EMS. When completed, the ISO 14001 EMS will docu- ment the management systems required to comply with all applicable Weyerhaeuser policies and state, local, and Federal rules and regulations. Progress: Conversion of the existing EMS to the ISO 14001 standard has progressed slower than anticipated. Reorganization and staffing reductions needed to better compete in the highly competitive pulp and paper market has caused the environmental staff to focus mostly on immediate needs and requirements. Due to the 12 ------- Weyerhaeuser XL Project 12-31-99 limited resources and the requirements of other mandatory programs, such as the Cluster Rule and risk man- agement plans, only moderate progress was made during 1999. An ISO 14001 guidance document has been completed by Weyerhaeuser staff at the corporate level, at the Flint River facility, and at another Weyerhaeuser mill. The guidance document outlines the requirements, steps to take, and examples for implementing an ISO 14001 EMS. Other Weyerhaeuser mills will use this guidance document as a template to create their own EMS. The first of many environmental aspects of the facility's operations has been documented at the Flint River facility and will serve as a model for subsequent efforts. Additional progress is anticipated during 2000. Energy Conservation: Weyerhaeuser committed to conducting energy conservation studies to identify opportunities for long-term reductions in facility energy demand. Based on these studies, a long-term goal for energy conservation will be determined and incorporated into the FPA. The expected environmental benefit is a reduction in air pollutant emissions due to a reduction in the amount of fuel burned. Progress: Four energy conservation proj ects were completed during 1998, which together reduced steam use by 35,900 pounds per hour. These projects were returning product unit condensate to the boiler feedwater system; returning evaporator condensate to the recaust area; reducing secondary temperature on the recovery boiler; and using weak filtrate to clean the cylinder mould face wire. A facility-wide steam conservation study has been completed that identifies several proj ects with the potential to further reduce steam use. The proj ects are not being actively pursued at this time because of poor pulp and paper market conditions and the resulting tightening of capital availability. Data from the past several years show that steam use at the facility has decreased from an estimated 1994 level of 290,000 pounds per hour to an estimated 1998 level of 210,000 pounds per hour. Stakeholder Participation Weyerhaeuser worked to ensure that stakeholders were involved in the environmental design and impact assessment of its XL project and had an opportunity to participate fully in project development. The organiza- tions directly involved in negotiating the FPA included Weyerhaeuser, U. S. EPA, Georgia EPD, the Georgia Pollution Prevention Assistance Division (PPAD), and the Lake Blackshear Watershed Association. Efforts to include a broad array of stakeholders as direct participants and to keep the public well informed included a series of regional public meetings in Oglethorpe, Georgia; personal contacts through telephone calls and meetings; oral briefings and broad distribution of written descriptions of Proj ect XL to employees; oral briefings and the distribution of written proj ect summaries to interested national, nongovernmental organizations; and publication of notices in courthouses and local newspapers to convey an open invitation to scheduled public meetings. Complete listings of all stakeholders that participated in general public meetings held to discuss the Weyerhaeuser FPA are available in FPA Appendix A. 13 ------- Weyerhaeuser XL Project 12-31-99 Weyerhaeuser openly communicates with stakeholders about the status of operations under the FPA, answer- ing all questions and inquiries. Weyerhaeuser has committed to holding annual stakeholder meetings in the vicinity of the Flint River facility. Reasonable advanced meeting notice will be provided to Federal, state, and local agencies and other stakeholders. The annual meeting is the platform for Weyerhaeuser to present the status of FPA implementation and to answer stakeholder questions and concerns. On January 28,1998, the first Proj ect XL annual stakeholders meeting was held in Montezuma, Georgia. On February 4,1999, the second annual stakeholders meeting was held at the Flint River facility. Members of Weyerhaeuser's corporate leadership attended as well as representatives of EPA headquarters and Region 4, Georgia EPD, Weyerhaeuser employees, other stakeholders, and the general public. An audience of approxi- mately 200 people received reviews of the annual Project XL Progress Reports and participated in open question-and-answer periods. Audience feedback was very supportive of both the Proj ect XL program and Weyerhaeuser's environmental performance. No requests for changes in the direction or scope of the FPA were received from stakeholders or signatories during the meetings. A third annual stakeholders meeting is scheduled for January, 2000. Six-Month Outlook The key focus areas for continued successful implementation of the FPA over the next six months will be to determine the cause for and correct the growth in air emissions that occurred in 1997-1998; continue progress in converting the Flint River Operation's EMS into ISO 14001 EMS; identify and implement additional water conservation measures; modify the water withdrawal permit when water conservation measures support the MJJVI Phase IV goal; evaluate steam conservation study results, determine how much of a reduction in the power boiler steaming rate is possible before incurring operational problems, and begin development of an energy conversation plan; complete the development of the MACT site-specific alternative compliance plan for the facility, and imple- ment the applicable Cluster Rule requirements according to the timelines within the regulation; further develop composting and its economic feasibility as a means of reducing solid waste generation; and define possible water reuse and reduction opportunities that would reduce bleach plant effluent flow. Project Contacts Mark Johnson, Weyerhaeuser, (770) 396-8121. Lee Page, EPA Region 4, (404) 562-9131. Nancy Birnbaum, EPA Headquarters, (202) 260-2601. David Word, Georgia EPD, (404) 656-4713. AlanLeake, GeorgiaEPD, (404) 363-7138. BobDonoghue, Georgia PPAD, (404)651-5120. Information Sources The information sources used to develop this progress report include (1) discussions during teleconferences among representatives of the U.S. EPA, Weyerhaeuser Flint River Operations, GeorgiaEPD, Georgia PPAD, 14 ------- Weyerhaeuser XL Project 12-31-99 and local community stakeholders; (2) the FPA for the Weyerhaeuser XL proj ect; and (3) annual and semian- nual status reports prepared by Weyerhaeuser. The information sources are current through December 1999. Glossary Adsorbable Organic Halide (AOX): A measurement of the amount of chlorinated organic compounds in an effluent water sample. Assimilative Capacity: The capacity of a body of water to receive wastewaters or toxic material s without delete- rious effects and without damage to either aquatic life, or to humans or terrestrial animals that consume the water. Baseline: A measure by which future environmental performance can be compared. Best Management Practices: Methods that have been determined to be the most effective, practical means of preventing or reducing pollution from non-point sources. Biological Oxygen Demand (BOD): The measurement in an effluent water sample of the oxygen consumed by biological processes breaking down organic matter. Excessive amounts of BOD in water can result in algal blooms. Bleach Plant: Bleaching is any process that chemically alters pulp to increase its brightness. Brownside Optimization: The name given to Weyerhaeuser's proj ect to upgrade its pulp digester to isothermal cooking technology, reinj ection of wood knots, and change out of primary screens. Brownstock Washing: The pulping solution used in chemical pulping is separated from the pulp using brownstock washing. Efficient washing is critical to maximize the reuse of pulping solution and minimize the concentration of pulping solution in the pulp sent to the bleach plant. Calciner: In the calcining process, typically, a lime kiln is used to regenerate lime from lime mud. Carbon Monoxide (CO): A colorless, odorless, poisonous gas produced by incomplete fossil fuel combustion. Clean Air Act (CAA): The Clean Air Act is the comprehensive Federal law that regulates air emissions from area, stationary, and mobile sources. This law authorizes EPA to establish National Ambient Air Quality Standards (NAAQS) and other regulations to protect public health and the environment. Clean Water Act (CWA): The Clean Water Act sets the basic structure for regulating discharges of pollutants to waters of the United States. The law gives EPA the authority to set technology-based effluent standards on an industry basis and establish water quality standards for all contaminants in surface waters. The CWA makes it unlawful for any person to discharge any pollutant from a point source into navigable waters unless a Na- tional Pollutant Discharge Elimination System (NPDES) permitis obtained. Conditionally Exempt Small-Quantity Generator: Persons or enterprises that produce less than 220 pounds of hazardous waste per month. Exempt from most regulations, they are required only to determine whether their waste is hazardous, notify appropriate state or local agencies, and ship the waste by an authorized transporter to a permitted facility for proper disposal. Criteria Air Pollutants: The CAA requires EPA to set NAAQS for certain pollutants known to be hazardous to human health. EPA has identified and set standards to protect human health and welfare for six criteria air pollutantsozone, carbon monoxide (CO), total suspended particulates, sulfur dioxide (SO2), lead, and nitrogen oxide (NOx). EPA must describe the characteristics and potential health and welfare effects of these pollutants. It is on this basis thatNAAQSs are set or revised. 15 ------- Weyerhaeuser XL Project 12-31-99 Digester: A reaction vessel used to convert wood chips into pulp. Wood chips are mixed with a pulping solution (white liquor) in a reaction vessel (digester) that cooks the solution under increased pressure and temperature. Output products are separated wood fibers (pulp) and a liquid that contains woody solids in a solution of reacted and unreacted pulping chemicals (black liquor). Dioxin: Any one of a family of compounds known chemically as dibenzo-p-dioxins. Concern about dioxin arises from their potential toxicity as a contaminant in commercial products. Tests on laboratory animals indicate that dioxin is one of the most toxic of man-made compounds. Discharge Monitoring Report (DMR): Facilities that discharge wastewater directly from point sources to surface waters must submit DMRs under NPDES wastewater permitting. Effluent: Treated or untreated wastewater that flows out of a treatment plant, sewer, or industrial outfall. Generally refers to wastes discharged into surface waters. Emissions Cap: A provision designed to prevent proj ected growth in emissions from both existing and future stationary sources from exceeding mandated limits. Generally, such provisions require that any emissions increase from equipment at a facility be offset by emission reductions from other equipment under the same cap. End-of-Pipe Controls: Technologies, such as scrubbers on smokestacks and catalytic converters on automo- bile tailpipes, that reduce the emission or discharge of environmental pollutants after they have formed. Final Project Agreement: The FPA outlines the details of the XL project and each party's commitments. The project's sponsors, EPA, state agencies, Tribal governments, other regulators, and direct participant stakehold- ers negotiate the FPA. Forest Buffers: Strips of forests along each side of a stream that resist erosion and slow the runoff of sediment- laden rainwater into the stream. Hazardous Air Pollutants (HAPs): Air pollutants that are not covered by the NAAQS but that may present a threat of adverse human health effects or adverse environmental effects. Such pollutants include methanol, asbestos, beryllium, mercury, benzene, radionuclides, and vinyl chloride. International Organization for Standardization (ISO) 14000: ISO 14000 is primarily concerned with environ- mental management. The ISO 14000 series sets out the methods that can be implemented in an organization to minimize harmful effects on the environment caused by pollution or natural resource depletion. Landfill: Secure chemical landfills are disposal sites for hazardous wastes, selected and designed to minimize the chance of release of hazardous substances into the environment. Leachate: Water that collects contaminants as it trickles through wastes, pesticides, or fertilizers. Leaching may occur in farming areas, feedlots, and landfills, and may result in hazardous substances entering surface water, groundwater, or soil. Lime Mud: A by-product of the process of recovering used pulping solution. Impurities removed during the recaust process are mixed with lime, which precipitates lime mud. Maximum Available Control Technology (MACT): The emission standard for sources of air pollution requiring the maximum reduction of hazardous emissions, taking cost and feasibility into account. Under the CAA Amendments of 1990, the MACT must not be less than the average emission level achieved by controls on the best performing 12% of existing sources, by category, of industrial and utility sources. Media: Specific environmentsair, water, soilwhich are the subj ect of regulatory concern and activities. 16 ------- Weyerhaeuser XL Project 12-31-99 Methyl Ethyl Ketone (MEK): A solvent typically used in cleaning painting equipment. Minimum Impact Manufacturing (MIM): Minimum Impact Manufacturing contains the elements of a compre- hensive pollution prevention program designed to obtain the greatest use of raw materials and to stop waste generation rather than rely on end-of-pipe remedies. MEVI involves a holistic approach to pollution prevention employing a systems engineering approach, waste reduction, and a commitment to continuous environmental improvement. Multi-media: Several environmental media, such as air, water, and land. National Ambient Air Quality Standards (NAAQS): Standards established by EPA under the CAA applicable to the emission of criteria air pollutants throughout the country. National Pollutant Discharge Elimination System (NPDES): A provision of the CWA that prohibits the dis- charge of pollutants into waters of the United States unless a special permit is issued by EPA, a state, or where delegated, by a Tribal government on an Indian reservation. Nitrous Oxides (NOx): An air pollutant that is the result of photochemical reactions of nitric oxide in ambient air. Typically, it is a product of combustion from transportation and stationary sources. It is a maj or contributor to the formation of tropospheric ozone, photochemical smog, and acid deposition. Particulate Matter: Fine liquid or solid particles, such as dust, smoke, mist, fumes, or smog, found in air or emissions. Point Source: A stationary location or fixed facility from which pollutants are discharged; any single identifiable source of pollution, for example, a pipe, ditch, ship, ore pit, or factory smokestack. Pollution Prevention: Identifying, altering, or eliminating areas, processes, and activities that create excessive waste products or pollutants. Such activities, consistent with the Pollution Prevention Act of 1990, are con- ducted across all EPA programs. Pulp: Cellulose fibers separated from wood chips used in making paper, cardboard, and related products. Pulping Solution: A chemical solution that is mixed with wood chips and digested under temperature and pressure. The pulping solution degrades wood by dissolving the bonds holding cellulose fibers together. Recaust: The molten pulping solution reclaimed from the recovery boiler is recausticized to further remove impurities and convert sodium carbonate into active sodium hydroxide and sodium sulfide. Recovery Boiler: Used pulping solution is sent to the recovery boiler to burn off impurities (undigested woody solids). Woody solids are burned for energy and the pulping solution is removed from the mixture in molten form (smelt). Resource Conservation and Recovery Act (RCRA): RCRA gives EPA the authority to control hazardous waste from "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also establishes a framework for the management of nonhazardous wastes. RCRA enables EPA to address environmental problems that could result from underground tanks storing petroleum and other hazardous substances. RCRA focuses only on active and future facilities and does not address abandoned sites. Screening: A pulp processing step that helps remove impurities from digested pulp, such as bark fragments, oversized chips, and undigested chips. In open screening rooms, wastewater from the screening process goes to wastewater treatment prior to discharge. In closed screening rooms, wastewater from the screening process is reused in other pulping operations and ultimately enters the mill's recovery system. 17 ------- Weyerhaeuser XL Project 12-31-99 Small-Quantity Generator (SQG): Persons or enterprises that produce 220-2,200 pounds per month of hazardous waste. SQGs are required to keep more records than conditionally exempt generators. The largest category of hazardous waste generators, SQGs include automotive shops, dry cleaners, photographic develop- ers, and many other small businesses. Solid Waste: Nonliquid, nonsoluble materials ranging from municipal garbage to industrial wastes that contain complex and sometimes hazardous substances. Solid wastes also include sewage sludge, agricultural refuse, demolition wastes, and mining residues. Technically, solid waste also refers to liquids and gases in containers. Sulfur Dioxide (SO2): Sulfur-dioxide gases are formed when fuel containing sulfur (mainly coal and oil) is burned and can be formed during metal smelting and other industrial processes. Sulfur dioxide is associated with acidification of lakes and streams, accelerated corrosion of buildings and monuments, reduced visibility, and such adverse health effects as inhibition of breathing, respiratory illness, and aggravation of existing cardio- vascular disease. Title V of the Clean Air Act: Establishes a federal operating permit program that applies to any maj or stationary facility or source of air pollution. The purpose of the operating permits program is to ensure compliance with all applicable requirements of the CAA. Under the program, permits are issued by states or, when a state fails to carry out the CAA satisfactorily, by EPA. The permit includes information on which pollutants are being released, how much may be released, and what kinds of steps the source's owner or operator is taking to reduce pollution, including plans to monitor the pollution. Total Reduced Sulfur (TRS): Sulfur is a nonmetallic element used particularly in the chemical and paper indus- tries. TRS is a measure that includes all sulfur-based compounds with extra electrons, such as hydrogen sulfide, dimethyl sulfide, and dimethyl disulfide. TRS has an odor suggestive of rotten eggs. Total Suspended Solids (TSS): The measurement of the amount of suspended solids in an effluent water sample. Volatile Organic Compound (VOC): Any organic compound that easily evaporates and participates in atmo- spheric photochemical reactions, except those designated by EPA as having negligible photochemical reactivity. Wastewater: The spent or used water from a home, community, farm, or industry that contains dissolved or suspended matter. Water Bars: An obstruction that slows the downhill flow of rainwater and, therefore, reduces erosion. White Water: Screening and cleaning operations during the pulp processing stage are sources of large volumes of wastewater. This effluent stream is called white water because of its characteristic color. 18 ------- |