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Weyerhaeuser Company
Final Project Agreement Mid-Year Progress Report
WEYERHAEUSER COMPANYFLINT RIVER OPERATIONS
PROJECT XL
FINAL PROJECT AGREEMENT (FPA)
1998 MIDYEAR PROGRESS REPORT
(JANUARY 98 - JUNE 98)
FLINT RIVER OPERATIONS
PROJECT XL
1998 MIDYEAR PROGRESS REPORT
(JANUARY 98 - JUNE 98)
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
- FPA Section IX: Implementation Schedule
VI. Schedule
- Next Six Months
- Long Term Schedule
- Weyerhaeuser Contact Listing
- Glossary of Terms FLINT RIVER OPERATIONS
PROJECT XL
1998 MIDYEAR PROGRESS REPORT
(JANUARY 98 - JUNE 98)
I. OVERVIEW:
Note: The Midyear 1998 FPA Tables Two and Three summarize the facility's actual environmental
performance results versus the FPA superior environmental goals. The 1998 Midyear Progress Report narrative
provides detailed technical information describing the specific actions taken by the facility to achieve the
superior environmental performance goals.
General Status
During the first half of the second year in Project XL; Weyerhaeuser's Flint River Operations has been working toward the completion of Minimum Impact Manufacturing (MIM) Phase IV initiatives. Isothermal Cooking, Odor Control System Upgrade and Energy Steam Reductions have been successfully completed. The conversion of the Flint River EMS to ISO 14001 is the only remaining MIM IV initiative. Feasibility studies of several of the MIM Phase V focus areas have begun. Flint River Operations actual environmental performance through June '98 continues to be equal to or better than the MIM Phase IV FPA performance goals.
The Cluster Rule was finally promulgated on April 15, 1998! Weyerhaeuser has facilitated two meetings with U.S. EPA and Georgia EPD to begin forming the site-specific agreement for achieving alternative compliance with the MACT I portion of the rule under terms of the FPA.
In June, of 1998 Weyerhaeuser Company was selected by the American Business Press as the "1998 W.D. Littleford Award for Corporate Community Service Grand Winner" for its environmental preservation efforts per Project XL. The company was nominated for the award by Chemical Engineering magazine and selected as co-Grand Winner for its Environmental Champions Award. Additionally, Weyerhaeuser Company received the 1998 American Forest and Paper Association's "Pollution Prevention Award" for the environmental performance commitments per Project XL.
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 continued building upon its strong environmental compliance record during 1998. The facility completed another period of perfect 100% compliance with its wastewater NPDES, drinking water, landfill, surface water and groundwater withdrawal permits. During the six month period there were two separate process upset conditions when the facility received community odor inquiries. Both of these inquiries came from off-duty employees that live in the local area. There have been 32 air permit reporting incidents in the first six months of 1998. Approximately 80% of these incidents are attributed to Power Boiler operation difficulties. Two root causes have been identified that have caused the Power Boiler incidents. First, poor Calciner reliability during this period has shifted the Power Boiler towards becoming the primary incineration device for strong TRS gases. Secondly, steam energy conservation initiatives have driven the steaming rate of the Power Boiler down to a low point where maintaining the required furnace temperature and SO2 control is difficult. Work is in progress to correct these two root causes and prevent reoccurrence of these incidents. The reporting incidents are summarized below:
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| Power Boiler SO2 Excess Emissions |
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Strong & Weak TRS Gas Venting |
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| Low Power Boiler Furnace Incineration Temperature |
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Calciner TRS Excess Emissions |
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| Power Boiler Scrubber Pressure Drop |
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Bleach Plant Scrubber Flow |
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| Bleach Plant ORP |
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II. 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 '98. The current environmental performance continues to be equal to or better than the MIM Phase IV FPA performance goals with the exception of converting the existing Environmental Management System to a system that would certify to ISO 14001. Raw water usage, effluent discharge BOD and TSS continue to trend down. However, during this reporting period effluent discharge AOX and process solid waste generation have increased slightly above 1997 actuals; but remain below FPA goals. The AOX increase can be attributed to an increase in customer demand for high brightness pulp which results in higher chlorine dioxide usage in the bleach plant area. Solid waste generation increase is due to poor Calciner reliability causing higher lime mud solid waste generation. (See Midyear 1998 FPA Tables Two and Three.)
III. 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 Flint River Operation's environmental management system (EMS) to conform to ISO 14001. Focus areas of MIM Phase IV:
* ISO 14001 EMS; the conversion of the existing EMS to conform to the ISO 14001 EMS has been progressing slower than planned. A tool has been developed to identify and determine significant environmental activities and products per the ISO standard. Completion is forecast to be mid 1999.
* Raw Water Usage Reduction: The water reduction anticipated from the MIM Phase IV projects was not sufficient to offset increased mill water usage from other process areas. However, the total usage has returned to 11.40 MMDG monthly average versus a FPA goal of 11.50 MMGD through daily water conservation focus of the production operators. Water use reductions will continue to be a focus area within the MIM Phase V feasibility studies.
MIM Phase V Implementation
During the first half of 1998, MIM Phase V Feasibility Studies were initiated or continued in the following areas: Solid Waste Reductions, Energy Conservation and Hazardous Air Pollutants (HAPs) Emission Reductions. The MIM Phase V Feasibility Studies for Bleach Plant Effluent Reductions will be initiated according to the FPA schedule. The Timberlands Resource Strategies was fully implemented in 1997.
* Solid Waste Reductions: The solid waste performance for the first half of 1998 is 446 lbs/ADMT of production. This is an increase of approximately 9% over 1997 actual performance. This negative impact was caused by Calciner operating and mechanical problems resulting in additional downtime. On the positive side, reductions are being noted in Waste Clarifier Sludge due to the enhanced performance of the finish fiber cleaners and continued reduction in Screening Room "Knots" from the Digester modifications.
Composting Feasibility Trial: As previously reported in 1997, a compost suitable for soil enhancement was successfully produced at the plant under the supervision of the University of Georgia and the Georgia Institute of Technology. A second batch of process solid wastes will be composted starting in August to determine reproducibility of the composting process under summer conditions and fine tuning of the recipe.
Land Application Feasibility Trials: A study plan for application of the composted process solid wastes on small test plots as forest and crop amendments has been prepared and submitted to the Georgia EPD. Permission to conduct the study was received from Georgia EPD in a letter dated July 17, 1998. Field plots are being prepared and the study is expected to start in late September. The long term study being conducted by the University of Georgia using process solid wastes for silvacultural and agricultural soil productivity continues on schedule.
* Energy Conservation: Several small scale energy conservation projects are in progress during this reporting period that together will cause a significant reduction of steam demand. These projects are:
· Product Unit condensate return to the boiler feedwater system
· Recovery Boiler Soot Blower steam reduction (15,000 lbs/hr savings)
· Evaporator Condensate returned to the Recaust area (saving steam to heat Mud Filter wash water and mill water savings)
· Reduction of secondary temperature on the Recovery Boiler (will save steam demand on Power Boiler)
Funding has been approved and a consultant selected to perform a "Steam Conservation" study that will identify steam saving projects throughout the plant. This study is scheduled to begin in August and be completed by the end of 1998. This study's findings will be the basis of the plant's energy conservation plan.
* Hazardous Air Pollutant (HAPs) Emission Reductions: Since the finalization of the Cluster Rule, two meetings have taken place with EPA and Georgia EPD. These meetings were designed to begin the process of defining the site specific MACT I alternative compliance rule for Flint River Operations. The process flowsheets for the various portions of the mill that are regulated by MACT I were reviewed. Specific pieces of equipment were determined to be within or outside the scope of the rule. An accounting was made of which equipment emissions are collected by the existing odor control systems. Some equipment potentially must have collection added, while other equipment is already collected but is not required by the rule. This "extra" collection will be used to potentially offset required collection that would have to be added. This will be determined at a future meeting. Before that meeting takes place the mill will perform testing around the Steam Stripping system, the Bleach Plant, Screening, and the Oxygen Stage to quantify the amount of HAPS or methanol that is produced in these process areas.
IV. 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.
On January 28, 1998 the first Project XL annual stakeholders meeting was held in Montezuma, Georgia. Members of Weyerhaeuser's corporate leadership were in attendance as well as members from headquarters and Region 4 EPA, Georgia EPD, Weyerhaeuser employees, stakeholders, and the general public. An audience of approximately 200 people received a review of the first Annual Project XL Progress Report; followed by an open question and answers period. Feedback from the audience was very supportive of both the Project XL Program and Weyerhaeuser Company's environmental performance. No requests for changes in the direction or scope of the FPA was received from the stakeholders or signatories during the meeting.
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 1998 Midyear Progress Report will be available on U.S. EPA's Project XL Internet page at http://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 during calendar year 1998:
Lockheed Martin Aeronautical System - Pollution Prevention & Environmental Department:
Presented program on Weyerhaeuser's Project XL Experience & Minimum Impact Manufacturing.
CH2M Hill Consultant - Atlanta Regional Office
Presented program on Weyerhaeuser's Project XL Experience & Minimum Impact Manufacturing.
State of Georgia Office of Budget and Planning - Georgia Environmental Partnerships:
Presented program on Weyerhaeuser's Project XL Experience & Minimum Impact Manufacturing for
achieving Industrial Sustainability.
V. FINAL PROJECT AGREEMENT IMPLEMENTATION:
Regulatory Actions
During this midyear period, the only regulatory initiative has been the development of the site specific rule for implementing the alternative compliance approach for the MACT I standard. The modifications to the solid waste handling and the water withdrawal permits are expected during the second half of 1998
FPA Section IX: Implementation Schedule
Progress against the implementation timelines outlined in FPA Section IX. - Implementing Project XL for Flint River Operations, is as follows:
Mechanisms That Are Enforceable:
WATER: Items 1, 2, 3, 4, 5 - Completed in NPDES permit.
WATER USAGE: Item 1 - No action has taken place with project at this time. The study to identify water reduction possibilities remains on the plant's technology plan for 1998.
SOLID WASTE: Item 1 - Will submit for minor solid waste permit modification in 98.3.
AIR: Items 1, 2, 3, 4, 5, 6 - Completed in PSD air quality permit. Item 7 - In progress
Mechanisms That Are Not Enforceable:
ISO 14001 EMS: Item 1 - Work in progress, to be completed by 6/99.
WATER: Item 1 - Following timelines per the original FPA.
SOLID WASTE: Item 1 - Completed. Item 2 - Feasibility studies in progress for composting and land application initiatives; following timelines per the original FPA for 50% reduction.
HAZARDOUS WASTE: Item 1 - Completed.
BLEACH PLANT: Item 1 - Following timelines per the original FPA for 50% reduction.
ENERGY: Item 1, 2: Following timelines per the original FPA.
VI. SCHEDULE:
Next Six Months
The key focus areas for continued successful implementation of the FPA over the next six months will be the following:
· Continue the effort to convert Flint River Operation's EMS into ISO 14001 EMS
· Identify and implement water conservation measures to achieve MIM Phase IV goal of 10.18 MGD.
· Execute the "Steam Conservation " study to begin development of an Energy Conversation plan.
· Plan and execute the second Annual Stakeholders public meeting - mid/late January '99.
· Maintain current environmental management system to meet compliance and customer requirements.
· Continue the development of the MACT I Alternative Compliance Plan for the facility.
· Implement the Cluster Rule requirements according to timelines within the regulation.
· Complete the modification of the Solid Waste Handling permit to incorporate FPA flexibility.
· Complete the modification of the water withdrawal permit to incorporate MIM Phase IV commitment.
· Define possible water reuse and reduction opportunities that would reduce Bleach Plant effluent flow.
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 nearly on track with the original schedule outlined in the FPA. 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, Compliance Assurance Monitoring requirements and state issuance 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. Gary Strandburg
Environmental Manager
Weyerhaeuser Company - Flint River Operations
Old Stage Coach Road
P.O. Box 238
Oglethorpe, Georgia 31068
Phone: (912) 472 5227
Fax: (912) 472 5508
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Mr. Russell Stevenson
Pulp Business - Environmental Manager
Old Stage Coach Road
P.O. Box 238
Oglethorpe, Georgia 31068
Phone: (912) 472 5518
Fax: (912) 472 5508
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Ms. Janet McRanie
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
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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
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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 Absorbable 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
EPA United States Environmental Protection Agency
EPD Georgia Environmental Protection Division
FPA Final Project Agreement
HAP Hazardous Air Pollutant
ISO International Standards Organization
NPDES National Pollutant Discharge Elimination System
MIM Minimum Impact Manufacturing - a holistic pollution prevention strategy to minimize the impact on the natural environment (air, soil, water).
MACT Maximum Achievable Control Technology
ORP Oxidation Reduction Potential
SO2 Sulfur Dioxide
TRS Total Reduced Sulfur
TSS Total Suspended Solids - a measurement of the amount of suspended solids in an effluent water sample.
XL eXcellence and Leadership
1998 MIDYEAR ACTUALS FPA - TABLE TWO
FLINT RIVER BASELINE PERFORMANCE AND MIM IV GOALS TO BE INCLUDED IN ENFORCEABLE PERMITS
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PHASE IV GOAL |
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1998 MIDYEAR ACTUALS FPA - TABLE THREE
FLINT RIVER BASELINE PERFORMANCE AND MIM GOALS THAT WILL NOT BE
INCLUDED IN ENFORCEABLE PERMITS
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MIM PHASE V GOAL |
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