Weyerhaeuser Company

Meeting Summary June 16-17, 1998

Date: Junel6/17,1998

Project XL - Site Specific Rule Development for MACT 1 Compliance

Attendance: US EPA, GAEPD and Weyerhaeuser

Meeting Objectives:

-Identify Flint River Operation's process equipment regulated by MACT I & NSPS Subpart BB.
-Develop emissions inventory to quantity HAPs for MACT I compliance, MIM Phase IV reductions and HVLC over controlled sources (credits).

Meeting Agenda:

1. Review Project XL - MACT Accounting Principles: reviewed principles for HAPs accounting per Appendix 7 of the XL FPA. The group had no changes to the principles.
2. Reviewed Flint River Process Flow Diagrams covering MACT I process equipment systems. See highlighted flow shoots.
3. Performed MACT Applicability Review by using process area definitions in rule. Determined whether current equipment was required to be collected by MACT 1 or was potential "credit" source for HAPs reduction. Identified equipment collection system (HVLC/LVHC/scrubber) or ir source was vented to atmosphere.
4. Field toured the following process areas: bleach plant, screening standpipes, refiner rejects lank, chip bin, Radi trim standpipe, knots conveyor belt, brownstock diffusion washer, docker, VOC tank, CtO2 mixers, turpentine storage tank, hardpiping to lagoon.

Digester System - See Flow Diagram pages Al A2

MACT I Equipment Current Status MACT I

Chip Bin HVLC No
Steaming Vessel LVHC Yes
Impregnation Vessel LVHC Yes
Continuous Digester LVHC Yes
Digester No IA Flash Tank LVHC Yes
Digester No I B Flash Tank LVHC Yes
Digester No 2 Flash Tank LVHC Yes

Note: All above listed LVHC source's emissions are captured through the No 2 Turpentine condenser Into the LVHC System.
Note: Chip Bin uses fresh 50 lb steam for preheating, Low pressure feeder results In minimal blow back from steaming vessel.
Note; Digester System Is regulated under NSPS Subpart BB.

Pulp Washing System - See Flow Diagram

MACT I Equipment Current status MACT I

Pressure Diffusion (PD) Washer No Vent Yes
PD Washer Filtrate Tank HVLC Yes
No I Digester Surge Tank HVLC Yes
No 2 Digester Surge Tank HVLC Yes
Brownstock Diffusion Washer Atmosphere Yes
1 Stage BSW Filtrate Tank Atmosphere Yes
2 Stage OSW Filtrate Tank HVLC Yes

Notter & Screen Systems - See Flow Diagram

MACT I Equipment Current Status MACT I

Primary Knotter No Vent Yes
Secondary Knotter No Vent Yes
Knotter Accept Tank Atmosphere Yes
Primary Screen Standpipe Atmosphere Yes
Secondary Screen Standpipe Atmosphere Yes
Tertiary Screen Standpipe Atmosphere Yes
Refine Rejects Tank Atmosphere Yes
Radi Trim Standpipe Atmosphere Yes
Knots Conveyor Belt HVLC through Chip Bin No

Note: Required to meet < 0.3 lb HAPs/ODT on total system for MACT I compliance.

Decker System - See Flow Diagram

MACT I Equipment Current Status MACT I

Cylinder Mould Decker Atmosphere No
Cylinder Mould Vacuum Pump Atmosphere No
Cylinder Mould Filtrate Tank Atmosphere No

Note: Alternative sources that could be controlled. Decker does not use any process washwater; therefore exempt from MACT 1.

Oxygen Delignification System

MACT I Equipment Current Status MACT I

Oxygen Blow Tank Atmosphere Yes
Post Oxygen Washer (POW) Atmosphere Yes
POW Filtrate Tank Atmosphere Yes

Bleaching System

MACT I Equipment Current Status MACT I

DI MC Mixer No Vent Yes
DI Tower Washer BP Scrubber Yes
DI Filtrate Tank Atmosphere Yes
D2 MC Mixer No Vent Yes
D2 Tower/Washer BP Scrubber Yes
D2 Filtrate Tank BP Scrubber Yes

Note: EPA to confirm if D1 filter Tank and BP Scrubber outlet combined <10 ppm; D1 Filtrate Tank collection not required.
Note: Bleach Plant meets chloroform standard since no hypochlorite or chlorine used.

Evaporate System - See Flow Diagram page.

MACT I Equipment Current Status MACT I

5th Effect No Vent Yes
4th Effect No Vent Yes
3rd Effect No Vent No
6th Effect No Vent No
2nd Effect No Vent No
IA Concentrator No Vent No
1B Concentrator No Vent No
IC Concentrator No Vent No
#1 Surface Condenser LVHC Yes.
#2 Surface Condenser LVHC Yes
Hotwell LVHC Yes

Evaporator System - See Flow Diagram

NON MACT l Equipment Current Status MACT I

Weak Liquor Storage Tank HVLC No
Soap Skim Tank HVLC No
Soap Separation Tank HVLC No
Bollout Tank HVLC No
Utility Tank HVLC ?
50% Black Liquor Tank HVLC ?
South 67% Tank HVLC No
North 6711/o Tank HVLC No
#1 ESP Make Down Tank HVLC No
#2 ESP Make Down Tank HVLC No
#3 ESP Make Down Tank HVLC No
Sall Cake Mix Tank HVLC No

Note: Evaporator System is regulated under NSPS Subpart Eii3
Note: EPA to confirm status of 50% Black Liquor Tank (exempt or part of the evaps process); also Utility Tank when in 50% service.

Steam Stripper System - See Block Diagram SK-4

MACT I Equipment Current Status MACT I

Stripper Feed Tank LVHC Yes
Spiral treat Exchanger No Vent Yes
Stripper Column No Vent Yes
Stripper Overhead Condenser LVHC Yes
Decanter LVHC Yes
Foul Oil Storage Tank LVHC Yes
Process Condensate Tank HVLC Yes
VOC Tank HVLC Yes

Turpentine Recovery System - See Block Diagram SK-3

MACT I Equipment Current Status MACT I

No 1 Condenser No Vent Yes
No 2 Condenser LVHC Yes
Turpentine Decanter LVHC Yes

Note: Turpentine Storage Tank is used solely for turpentine product storage and is not considered part of the turpentine recovery process,.The Turpentine Storage Tank pressure/vacuum vent valve is @ 1/2 ounce setting.

LVHC System - See NCG Strong Gas System Diagram

.MACT I Equipment Systems Current Status MACT I

Digester System LVHC Yes
Turpentine System LVHC Yes
Evaporator System LVHC Yes
Steam Stripper System LVHC Yes

HVLC System - See NCG Weak Gas System Diagram

MACT I Equipment Systems Current Status MACT I

Pu(p Washing Sy-stem HVLC - incomplete Yes
Knotter & Screening Systems Atmosphere Yes
Decker System Atmosphere Exempt
Oxygen Dolignifica(lon System Atmosphere Yes
Weak Liquor Storage Tank& HVLG No

"Closed" Collection System

MACT I Equipment Systems Current Status MACT I

LVHC System Closed Yes
HVLC System Closed Yes
Bleach Plant Scrubber Sys. Closed / diffusion washer puffs Yes

Note: EPA to check on whether diffusion washer "puffs" from positive pressure meats closed vent collection system requirements.
Note: Perform leak testing using Method 21 (hand hold VOC motor).
Note: Weyerhaeuser to submit to EPA an alternative to Inlet air flow monitor on Bleach Plant Scrubber.

Control Device Treatment

MACT I Equipment System Current Status MACT I

LVHC System Galciner & Power Boiler Yes
HVLC System Power Boiler & Recovery Boiler Yes
Bleach Plant Scrubber Sys. Scrubber Yes

Note: Using flame zone infection of combustion devices for HVLC & LVHC incineration.

MACT I Equipment Systems Current Status MACT I

Digester System No sewering Yes
Turpentine Recovery System ND 3 Heat Exchanger - VOC Tank - Biological Treatment Yes
Docanter Underflow - Stripper Feed Tank Yes
Evaporator System Hotwell Foul Side - Stripper Feed Tank Yes
HVLC System Hotwell Foul Side - Stripper Feed Tank Yes
LVHC System Hotwell Foul Side - Stripper Feed Tank Yes

Note: During startup/shutdown/malfunction two loop seals on the HVLC system may go to sewer; loop seal @ power boiler and loop seal at weak gas vacuum pump "Duke".

Draft - NEXT STEPS:

1. EPA (Penny & Steve) complete EPA's followups.
2. Weyerhaeuser collect process data on condensate methanol collection and removal from sl(ipper system,
3. Weyerhaeuser submit proposal for inlet air bleach plant scrubber monitoring.
4. Weyerhaeuser develop HAPs emissions inventory and sampling plan for quantifying MIM IV & HVLC credits and MACT I collection requirements.

EPA Followups & Discussion Items:

1. Note: Chip Bin low pressure feeder results in minimal blow back from steaming vessel.
2. Confirm if I)l Filtrate Tank and BP scrubber outlet combined < 10 ppm; DI Filtrate Tank collection not required.
3. Confirm status of 50% Black Liquor Tank (exempt or per(of the evaps process); also Utility Tank when in 50% liquor service.
4. Turpentine Storage Tank is used solely for turpentine product storage and Is not considered part of (he turpentine recovery system definition.
5. Evaluate whether positive pressurization "puffing" from diffusion washers can be addressed under closed vent collection system requirernants.
6. Review utilizing stripper methanol product measurement in lbl(on pulp as demonstrating compliance with condensate segregation requirements.
7. Review combinating the stripper and biological treatment options for demonstrating compliance with condensate treatrnent requirements.

Draft - TIMELINE.

July - September: EPA answer followups identified in "Notes".
July - September. Weyerhaeuser collect Initial stripper data and develop HAPs emissions inventory and sampling plan.
October: Reconnect meeting with EPA/GaEPD/Weyerhaeuser

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