Oklahoma department of environmental quality

The only listings for paper machines that can be considered similar to the Muskogee Mill Paper Machines are the No. 8 Paper Machine at G-P’s Crossett, Arkansas Mill, P & G’s four paper machines at its mill in Cape Girardeau, Missouri, and the Nos. 9 and 10 Paper Machines at G-P’s Green Bay Mill. BACT for the No. 8 Paper Machine at G-P’s Crossett, Arkansas Mill was determined to be no control while BACT for P & G’s Mill in Cape Girardeau, Missouri was determined to be a VOC limit of 2% of the chemical additives used and the use of low-VOC content additives consistent with product quality and equipment operation. BACT for the paper machines at G-P’s Green Bay Mill was 2.9 lbs/ADT for Paper Machine No. 10 and 2.7 lbs/ADT for Paper machine No. 9.

The available control technologies for control are not cost effective. The Mill proposes no additional controls.

The Converting Department takes parent rolls from each paper machine, cuts or slices the roll into smaller widths, then prints, perforates, and attaches each product stream to a core, finally cutting the paper to the proper length for the product being manufactured. Each product is packaged and sent to warehouses for later shipment to both commercial and retail customers, or for direct shipment to other G-P customers. The project will not modify any converting area paper printer, and thus paper printing is not subject to BACT. The Converting Department also makes paper cores for use in the final packages by gluing a paper substrate together. Each of the rewinding/slitting machines has a trim collection system that picks up waste from the cutting operation and directs the waste to a cyclone for product recovery. The recovered waste paper is sent back to the Pulp Processing Department where it is made into recycled pulp. The dust from the cyclone is discharged to a baghouse to control emissions before clean air is discharged to the atmosphere.

To identify the current technologies in use today for reducing PM/PM₁₀ and VOC emissions from Converting Department operations, information was collected from vendor literature from the Internet or directly from vendors. Additionally, the analysis reviewed the technologies in use at G-P’s other Converting Department operations. The only recent BACT analyses for Converting Department operations that have been prepared due to a PSD permit application include one for the No. 9 Paper Machine and associated converting equipment for G-P’s Paper Mill in Crossett, Arkansas in April 2001 and another for the No. 6 Paper Machine and associated converting equipment at G-P’s Port Hudson, Louisiana Paper Mill in August 2001. The Crossett Mill No. 9 Paper Machine was never constructed. The Port Hudson No. 6 Paper Machine and associated converting equipment were constructed and began operation in 2002. The converting equipment for the No. 6 Paper Machine project included the use of wet scrubbers for dust control from the trim line operations.

Cyclone separators are devices that utilize centrifugal forces and low pressure caused by spinning motion to separate materials of different density, size and shape. Gas cyclones are used to separate particulate matter (including lead) from dust-laden air streams. Cyclones are popular because they are simple to operate, inexpensive to manufacture, require little maintenance, have no moving parts, and operate at high temperatures and pressures. There are two types of separators available, tangential and axial. Both types operate on the same principle; however, in axial flow cyclones the gas stream enters from the top of the unit and is forced to move tangentially by a grate in the top of the cyclone. In tangential cyclones the gas stream enters from an inlet on the side that is positioned tangentially to the body of the unit. Multi-stage cyclones can increase the amount of particulate matter that is removed by connecting a number of single stage cyclones in series. The first stage of a multi-stage cyclone removes the larger particles while the remaining stages remove smaller particles. The collection efficiency of cyclones vary anywhere from 25-95%, depending upon whether the system is comprised of a single-stage cyclone or a multi-stage cyclone system.

ESPs use electrical energy to charge and collect particles with a very high removal efficiency. The classification of ESPs may be as wet or dry systems and/or single-stage or two-stage systems. Dry systems are the predominant type used in industrial applications. Wet systems are gaining in use today since they eliminate the possibility of fires, which can sometimes occur in dry systems.

The principal components of a DESP include the housing, discharge and collection electrodes, power source, cleaning mechanism, and solids handling systems. The housing is gas-tight, weatherproof, and grounded for safety. Dust particles entering the housing are charged by ions from the discharge electrodes. Dust is collected on the collection electrodes, also referred to as plates. The system voltage and the distance between the discharge and collection electrodes govern the electric field strength and the amount of charge on the particles. DESPs are most effective at collecting coarse, larger particles above the 1.0 micron (m) size. Particles smaller than this are difficult to remove because they can inhibit the generation of the charging corona in the inlet field and thereby reduce collection efficiency. Rappers serve as the cleaning mechanisms for DESPs. Dust hoppers collect the precipitated particles from a DESP. Dust is removed continuously or periodically from the hopper and stored in a container until final disposition. Collection efficiencies for DESPs are usually at or above 98-99%.

An ESP is a collection device that uses electromotive forces to drive particles out of a gas stream onto collector plates. Electrodes in the center of the gas stream are maintained at a high voltage, which charge the particles. Wet ESPs operate a wet wall on the back of an ESP with either continuous or intermittent water flow. The water flow is collected into a sump. The advantage to a wet ESP is that it has no back coronas and reduced risk of fire. The collection efficiency for a wet ESP is similar to that of a dry ESP.

Searches of the RBLC were conducted to identify control technologies for the control of PM/PM₁₀ and VOC emissions from converting department equipment operations. Searches were conducted only for RBLC determinations added during or after January 1995. The specific EPA RBLC categories searched are listed below:

Process name contains “converting” or “printing”

30.002 Kraft Pulp Mills

30.004 Pulp & Paper Production Other than Kraft
The only entry in the RBLC is G-P Port Hudson, LA Mill (permit PSD-LA-581 (M-2)). The specified control is a wet scrubber for each converting area. While the determination in the RBLC does not specify a control efficiency, the permitted emission rate of 1.75 lbs PM/hr for each stack is listed.
Step 2 - Technical Feasibility Analysis

The technically feasible controls are wet scrubbers and a baghouse.

The next step in the BACT analysis is to rank the various control options not eliminated in the previous step. The two control technologies are ranked as follows:

1. 
   The top level of control is a baghouse rated at up to 99% removal
   
2. 
   The next level of control is a wet scrubber rated at up to 98% removal
   

Step 4 – Control Effectiveness Evaluation

The Mill currently operates a baghouse for this source that will not need modification to control potential dust emissions from the converting area following the completion of the construction project. The Mill selects the top level of control. Thus, no additional effectiveness evaluation is needed.
Step 5 – Select BACT

The Mill proposes the top level of control, the existing baghouse, as BACT

The Mill is proposing to add three flexographic printers to its polyethylene plant. The three printers will operate in the same work area as the existing printer. The plant produces rolls of polyethylene film and prepares them for printing logos. The proposed presses will unwind the unprinted rolls produced at the Muskogee Mill or offsite and transfer color images using the flexographic process and solvent-based inks.

VOC emissions from polyethylene printing presses could be routed to a catalytic or thermal oxidizer for destruction, or to a carbon adsorption system. Thermal oxidation offers up to 99% control, catalytic oxidation offers up to 95% control, and carbon adsorption offers up to 90% control. G-P currently operates three printing presses at its facility in Warwick, NY, using a thermal oxidizer to destroy VOC.

Searches of the RBLC were conducted to identify control technologies for VOC emissions from printing press equipment operations. Searches were conducted only for RBLC determinations added during or after January 1995. The specific EPA RBLC categories searched are any whose process name contains the term “printing.” A large table in the application lists 16 companies using carbon adsorption, thermal oxidizers, catalytic oxidizers, low-VOC or UV-cured inks, and various combinations of the first four. A brief explanation of these control technologies is listed below.