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Weyerhaeuser Company

Final Project Agreement Mid-Year Progress Report

WEYERHAEUSER COMPANY
FLINT RIVER OPERATIONS456\

PROJECT XL
FINAL PROJECT AGREEMENT (FPA)

1997 MIDYEAR PROGRESS REPORT
(JANUARY 97 - JUNE 97)


FLINT RIVER OPERATIONS
PROJECT XL 1997 MIDYEAR PROGRESS REPORT (JANUARY 97 - JUNE 97)
OUTLINE

I. Overview

- General Status
- Facility Compliance Status

II. Environmental Performance Update

- FPA Table Two
- FPA Table Three

III. Minimum Impact Manufacturing

- MIM Phase IV Implementation
- MIM Phase V Implementation

IV. Stakeholder Involvement

- Meetings
- Presentations
- Information Requests
- FPA Project Contacts Listing

V. Final Project Agreement Implementation

- Regulatory Actions
- Weyerhaeuser Actions

VI. Schedule

- Next Six Months
- Long Term Schedule
- Weyerhaeuser Contact Listing
- Glossary of Terms


FLINT RIVER OPERATIONS
PROJECT XL 1997 MIDYEAR PROGRESS REPORT (JANUARY 97 - JUNE 97)

OVERVIEW:

 

Note: The Midyear 1997 FPA Tables Two and Three summarized the facility's actual environmental

performance results versus the FPA superior environmental goals. The 1997 Midyear Progress Report narrative

provides detailed technical information describing the specific actions taken by the facility to achieve the

superior environmental performance levels.

 

General Status

 

Having successfully signed the Final Progress Agreement (FPA) on January 17, 1997, Weyerhaeuser's Flint River Operations has been diligently working on the implementation of the Minimum Impact Manufacturing (MIM) Phase IV projects; beginning investigations into certain feasibility studies of the MIM Phase V projects; and jointly working with Stakeholders and FPA Signatories to incorporate the FPA agreement terms into the facility's environmental permits. Presently, Flint River Operation's actual environmental performance through June '97 has been equal to or better than the MIM Phase IV FPA performance goals.

 

Additionally, Weyerhaeuser has openly responded to numerous information requests from various stakeholder groups (regulatory agencies, industry groups, environmental organizations, news media representatives) for additional details of the FPA background and Weyerhaeuser's key lessons learned of how to successfully participate in U.S. EPA's Project XL program. Responding to these stakeholder inquiries has provided Weyerhaeuser with both the opportunity to transfer successful pollution prevention approaches and encourage other organizations to participate in the Project XL reinvention program.

 

Facility Compliance Status

 

Flint River Operations has continued building upon its superior environmental compliance record with no compliance issues in any of its regulatory environmental management programs or permits in the reporting interval.

 

ENVIRONMENTAL PERFORMANCE UPDATE:

 

One of the primary purposes of the FPA was to delineate the level of superior environmental performance that Flint River Operations would achieve under its MIM evolution strategy. These superior environmental performance targets were specified in Tables Two and Three of the FPA. The tables are updated in this report to reflect the facility's actual environmental performance through June '97. With the successful construction and startup of the MIM Phase IV projects (Isothermal Cooking - Brownside Optimization, Odor Control System Upgrade, Energy Steam Reductions) and maintaining the existing environmental management system elements, the current environmental performance is equal to or better than the MIM Phase IV FPA performance goals. See Midyear 1997 FPA Tables Two and Three.

 

 

 

 

MINIMUM IMPACT MANUFACTURING:

 

MIM Phase IV Implementation

 

MIM Phase IV covers the construction and operation of several process technology improvements (Isothermal Cooking - Brownside Optimization, Odor Control Upgrade, Energy Steam Reductions) and the conversion of the existing Flint River environmental management system (EMS) to conform to the ISO 14001 EMS. MIM Phase IV projects did improve the facility's environmental performance in the following media: effluent parameters of BOD5/TSS/COD/Color, process solid waste generation, raw water usage, hazardous air pollutants, total reduced sulfur emissions and criteria pollutant emissions. The combined environmental performance improvements from MIM Phase IV projects is reflected in the 1997 Actual Year-To-Date columns in Tables Two and Three.

 

* Isothermal Cooking - Brownside Optimization: Project successfully completed.

 

* Odor Control Upgrade: Project successfully completed.

 

* Energy Steam Reductions: The bleach plant condensate recovery and warm water tank steam reduction have been successfully implemented. The bleach plant filtrate heat exchange project has been partially completed. Additional energy steam reductions were realized by the Odor Control Upgrade project through process condensate collection. These steam reductions have resulted in reducing the power boiler steaming rate and corresponding reductions in criteria air pollution from reduced woodfuel burning.

 

* ISO 14001 EMS: The initiative to convert the existing Flint River EMS into the ISO 14001 EMS has not yet begun. It is currently scheduled to start in the fall of this year and is projected to be completed by June '98.

 

MIM Phase V Implementation

 

The MIM Phase V Feasibility Studies have been initiated in the following areas: Solid Waste Reductions, Timberlands Resource Strategies and Hazardous Air Pollutants (HAPs) Emission Reductions. The MIM Phase V Feasibility Studies for Bleach Plant Effluent Reductions, Water Use Reductions and Energy Conservation were not initiated during this initial six month period; but are expected to follow their respective timelines per the original FPA schedule.

 

* Solid Waste Reductions: The current 1997 YTD performance of 422 lbs/ADMT versus a MIM Phase IV goal

of 621 lbs/ADMT is the result of the following process solid waste improvements: 22,000 tons of lime mud

reduction due to increased calciner reliability and process capacity improvement; 7,500 tons of wood knots

reduction due to Isothermal Cooking project (new digester eliminated the generation of a wood waste); 1,000

tons of boiler ash reduction due to reduced steaming rate and woodfuel usage (ie. energy steam reduction

projects); and 100 tons of woodyard logyard debris recovery as woodfuel versus landfilled. However,

wastewater clarifier sludge generation is up 1,800 tons due to the new finished product cleaners project

rejecting more fiber to the sewer. New fiber recovery equipment to reclaim this material was installed in July

'97 and should reduce wastewater clarifier sludge generation to below 1995 actual levels. Progress on this

reduction will be included in the 1997 Annual Progress Report.

 

* Composting Feasibility Trial - In conduction with the Georgia Institute of Technology and University of

Georgia a composting recipe based on a blend of process solid wastes has been developed. Currently,

composting is being conducted in large scale reactors at the University of Georgia. Plans are being

investigated to conduct pilot plant scale composting trials at Flint River Operations starting Fall '97 with

application testing on Weyerhaeuser timberlands starting in early '98.

 

* Land Application Feasibility Trials - Silvicultural application of process solid wastes on regeneration and

existing timber stands is being conducted by the University of Georgia (5 year study). A new Weyerhaeuser

R&D forester is currently in training to conduct extended testing on improved tree growing and long term soil

productivity utilizing process solid waste and composted materials. Application of process solid wastes on

selected row crops in test plots is being conducted by the University of Georgia.

 

* Timberlands Resource Strategies: Documentation of the Weyerhaeuser Resource Strategies (including water

quality, wildlife habitat, soil productivity, aesthetics and forest products) into operating management practices

has begun. Current schedule targets completing the documentation, employee training and field deployment

by the end of '97.

 

* Hazardous Air Pollutant (HAPs) Emission Reductions: A preliminary investigation was conducted on the

effects of the new isothermal cooking digester and resultant impact on HAP emissions from brownstock

washing, oxygen delignification and bleaching processes. This investigation showed a reduction of HAP

emissions from the above mentioned processes when the digester kappa number was lowered. This resulted in

"cleaner" brownstock and more recovery of the lignins into the closed liquor recovery loop. In conjunction

with this investigation, clean process condensate wash water (contains residual methanol) used in the post

oxygen washer was substituted with fresh mill water (no residual methanol) to determine the impacts on

fugitive HAP emissions from the oxygen delignification system. Due to unstable process operating conditions

during the trial, no final control strategy can be made at this time. Upon the finalization of the Cluster Rules,

ie, MACT Standards, a detailed HAPs testing and reduction plan will be developed.

 

STAKEHOLDER INVOLVEMENT:

 

Since approval of the FPA, Weyerhaeuser Company has received numerous information requests from various stakeholder groups including the following: state regulatory agencies, industry groups, environmental organizations and news publications (magazines, newsletters, etc.). As part of the continuing Stakeholder Involvement Plan and in the spirit of the XL criteria of "Transferability", Weyerhaeuser has openly responded to the information requests and has participated in several conferences sharing our XL success story.

 

U.S. EPA has maintained an updated Project XL internet page, which contains a copy of the approved FPA document and other associated information. This 1997 Midyear Progress Report will be available on U.S. EPA's Project XL internet page at https://www.epa.gov/ProjectXL.

 

The following is a listing of meetings and conferences that Weyerhaeuser personnel have attended and participated in to share information regarding the FPA and Project XL:

 

Georgia Pollution Prevention Assistance Division: Southwire Corporation Annual Environmental Conference:

Presented program on Weyerhaeuser's Project XL Experience & Minimum Impact Manufacturing.

 

American Forest & Paper Industry's National Council of the Paper Industry for Air and Stream Improvement:

NCASI 1997 Southern Regional Meeting and Workshops: Presented program on Weyerhaeuser's

Project XL Experience & Minimum Impact Manufacturing during the opening session of the conference.

 

U.S. EPA's Project XL Roundtable Meetings: have actively participated as a stakeholder during these meetings

throughout the United States.

 

Technical Association of the Pulp and Paper Industry - 1997 Annual Meeting: Presented program on Weyerhaeuser's Project XL Experience & Minimum Impact Manufacturing.

 

1997 Annual Environmental Auditors Roundtable Meeting: Presented program on Weyerhaeuser's Project XL

Experience & Minimum Impact Manufacturing.

 

Oregon Responsible Environmental Management Conference: Plenary session presentation on Project XL experience and regulatory reinvention.

 

Environmental Corporate Counsel Summit Meeting: Presented Weyerhaeuser's Project XL Experience.

 

FINAL PROJECT AGREEMENT IMPLEMENTATION:

 

Regulatory Actions

 

The implementation of the FPA agreement covering the superior environmental performance goals and the agreed to regulatory flexibility are in progress. The proposed permit modification language of the permits (NPDES, surface water, solid waste, air) to implement the FPA can be found in appendices three through six of the FPA. The facility's NPDES wastewater treatment permit has been revised incorporating the MIM Phase IV superior environmental performance limits for effluent BOD5, TSS and AOX. Additionally, the permit reflects the regulatory flexibility for monitoring, reporting, streamlined permit renewals, removal of fish tissue sampling and assimilative capacity studies. The permit reissuance followed the standard public notice and 30 day public comment period to solicit stakeholder input (no non supportive comments were received). The new permit is expected to be in effect by the end of July '97. The permit language modifications followed the proposed permit language found in appendix three of the FPA.

 

Modifications to the existing facility air quality permit are in progress. A draft air quality permit incorporating the FPA agreement for a dual emissions cap, streamlined permitting, reporting, alternative compliance testing and experimental trials flexibility is expected by mid August. The draft permit language modifications follow the proposed permit language found in appendix six of the FPA. Upon agreement by the signatories, the draft permit will be posted for a 30 day public comment period by mid September. The modified permit is expected to be issued by early October '97.

 

Weyerhaeuser Actions

 

No other permits have been modified at this time to incorporate the terms of the FPA. The modifications to the surface and groundwater withdrawal permits and solid waste handling permit is scheduled for the third and fourth quarters of 1997. Upon the finalization of the Cluster Rules, ie, MACT Standards, a detailed HAPs reduction plan will be developed. This plan will detail the required HAPs emission reduction required by the MACT rule and the site specific actions to be taken to demonstrate compliance with the required HAPs reduction.

 

SCHEDULE:

 

Next Six Months

 

The key focus areas for continued successful implementation of the FPA over the next six months will be the following:

 

* Convert Flint River Operation's EMS into ISO 14001 EMS and deployment of Timberlands EMS.

* Identify and implement water conservation measures to achieve MIM Phase IV goal of 10.18 MGD.

* Finalize air quality permit modifications, including stakeholder input.

* Form facility task team to begin development of an Energy Conversation plan.

* Plan and execute the first Annual Stakeholders public meeting - mid/late January '98.

* Maintain current environmental management system to meet compliance and customer requirements.

 

Long Term Schedule

 

At this time, the long term schedule for MIM Phase V feasibility studies and the implementation of the agreed- upon regulatory flexibility are on track with the original schedule outlined in the FPA. The finalization of the Cluster Rules and the associated development of the site specific MACT Compliance Plan should occur during 1998 (based on final rule publication). In addition to the Project XL FPA initiatives, other regulatory requirements to be implemented include the following: Clean Air Act Risk Management Plan; Cluster Rule Liquor Best Management Practices; and state approval of the facility's Title V Air Permit. Additionally, we will continue our on-going dialogue with Stakeholders seeking their input on our facility's long term MIM Vision, including the Lake Blackshear Watershed Association, Macon County Local Emergency Planning Committee, local neighbors and facility employees.

 

Weyerhaeuser Project Contact Listing:

 

Please contact the below listed Weyerhaeuser individuals for more information regarding this FPA:

 

Mr. Russell Stevenson

Environmental Manager

Weyerhaeuser Company - Flint River Operations

Old Stage Coach Road

P.O. Box 238

Oglethorpe, Georgia 31068

 

Phone: (912) 472 5518

Fax: (912) 472 5508

----------------------------

 

Ms. Janet McElmurray

Public Affairs Resource

Weyerhaeuser Company - Flint River Operations

Old Stage Coach Road

P.O. Box 238

Oglethorpe, Georgia 31068

 

Phone: (912) 472 5230

Fax: (912) 472 5588

----------------------------

 

Mr. Mark Johnson

Environmental Manager

Weyerhaeuser Company Office of Environment

115 Perimeter Center Place, Suite 495

Atlanta, Georgia 30346

 

Phone: (770) 396 8131

Fax: (770) 396 9331

----------------------------

 

Mr. Gary Risner

Federal Environmental Manager

Weyerhaeuser Company

1100 Connecticut Ave NW Suite 530

Washington, DC 20036

 

Phone: (202) 293 7222

Fax: (202) 293 2955


GLOSSARY OF TERMS

ADMT Air Dry Metric Ton - measure of the facility's finished product = 2,205 lbs

 

AOX Adsorbable Organic Halide - measurement of the amount of chlorinated organic compounds.

 

BOD5 Biological Oxygen Demand - the amount of oxygen consumed in five days by biological processes breaking down organic matter.

 

COD Chemical Oxygen Demand - the measure of oxygen required to oxidize all compounds in water, both organic and inorganic.

 

EMS Environmental Management System

 

FPA Final Project Agreement

 

HAP Hazardous Air Pollutant

 

MIM Minimum Impact Manufacturing - a holistic pollution prevention strategy to

minimize the impact on the natural environment (air, soil, water).

 

TSS Total Suspended Solids - a measurement of the amount of suspended solids in an effluent water sample.

 

XL eXcellence and Leadership

 


MIDYEAR 1997 FPA - TABLE TWO

FLINT RIVER BASELINE PERFORMANCE AND MIM IV GOALS TO BE INCLUDED IN ENFORCEABLE PERMITS







ENVIRONMENTAL PARAMETER Applicable regulatory requirements are unaffected for all regulated environmental parameters that are not listed in Table Two.
BASELINE Baseline conditions are derived from average monthly values for calendar 1993, 1994 and 1995.
1995 ACTUAL
1996 ACTUAL
1997 ACTUAL YTD
PRE - FPA

ALLOWABLE

FPA AGREEMENT MIM

PHASE IV GOAL

Raw Water Usage (million gallons/day)
11.18
11.43
11.91
11.43
14.34
11.50 The Surface Water Withdrawal Permit (094-1191-01) monthly withdrawal limit will be reduced by 1.0 MGD - new limit - 11.5 MGD
Effluent Discharged to Flint River
BOD (lbs./ADMT)
4.32
4.15
3.52
3.39
5.30/4.83 The BOD limit proposed in EPA's draft Cluster Rule, 4.83 lbs./ADMT, is provided for purposes of comparison.
3.80
TSS (lbs./ADMT)
4.65
5.14
3.58
3.32
5.80/8.58 The TSS limit proposed in the draft Cluster Rule, 8.58 lbs./ADMT, is provided for purposes of comparison.
4.09
AOX (kg./ADMT)
0.11
0.10
0.10
0.10
N/A Not Applicable.
0.15 The AOX limit proposed as an entry requirement for EPA's Tier I Incentives Program, for comparison, is 0.30 kg/kkg. 61 Fed. Reg. 36,850 (July 15, 1996).
MIDYEAR 1997 FPA - TABLE THREE





FLINT RIVER BASELINE PERFORMANCE AND MIM GOALS THAT WILL NOT BE INCLUDED IN ENFORCEABLE PERMITS
Environmental Parameter
Basline
1995 Actual
1996 ACTUAL
1997 ACTUAL YTD
FPA Agreement MIM

PHASE IV GOAL

FPA Agreement

MIM

PHASE V GOAL

Solid Waste Generation (lbs/ADMT)
690
653
505
422
621
310
Hazardous Waste Generation
Small Qnty. Gen.
Small Qnty.Gen.
Small Qnty.Gen.
Conditionally Exempt SQG
Conditionally Exempt SQG
Conditionally Exempt SQG
Bleach Plant Flow (m3/ADMT)
20
20
20
20
N/A
10
Environmental Management System
Flint River EMS
Flint River EMS
Flint River EMS
Flint River EMS
ISO 14001
ISO 14001
Energy Conservation
To Be Determined after Feasibility Study

 


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