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International Paper, Emissions Monitoring
Addendum to Proposal
INTERNATIONAL PAPER
WFI XL PROJECT ADDENDUM
November, 1998
Project Description/Environmental Results
International Paper proposes to develop an innovative alternative emission monitoring system at its Jay, Maine facility using a predictive emissions monitor (PEM) system developed utilizing a computer model with a neural network to predict particulate matter, sulfur dioxide, nitrogen oxide, carbon monoxide, and carbon dioxide emissions from the mill's waste fuel incinerator (WFI). IP will develop a protocol using the PEM to provide feedback on operational controls to maintain optimal emission rates, and prevent potential license exceedances in conjunction with the Town of Jay and interested stakeholders. If the PEM is successful, this system will replace existing applicable continuous emission monitors and stack testing requirements.
Successful PEMs
A successful PEM will provide continuous information on emissions (where none existed before), as well as improve operational efficiency while reducing emissions. It will identify actions which will maintain reduced emission rates and will help to prevent license exceedances. A PEM would provide near-continuous real time feedback and reinforce parameters chosen from the Compliance Assurance Action Plan developed by IP and the Town of Jay. A successful PEM would also identify additional key parameters necessary to operate the incinerator below maximum permitted emission levels by developing a mathematical relationship between operational parameters and emission rates. The PEM can also be used to optimize operations by reducing emissions while increasing power production. Traditional "end-of-pipe" periodic stack testing and continuous monitoring will no longer be necessary to ensure compliance.
Superior Environmental Performance with PEMs at Androscoggin Mill
IP, under this Project XL project, will develop an alternative emission monitoring system using PEM technology at its Jay, Maine facility. Project proposals are dependent on PEM satisfying performance specification requirements such as Relative Accuracy Tests (RATA). Using approved PEM technology, IP proposes to ensure and achieve the following environmental baselines and benefits:
Tier 1 Equivalent Performance
IP will use PEM technology to continuously predict its emissions throughout the duration of the project and will conduct stack testing to verify the PEM under a reduced monitoring schedule during the duration of the project. IP will make a voluntary commitment to maintain environmental performance at least equivalent to current performance levels.
Tier 1 Benchmark Exceedance
The PEM will allow IP to take actions such as process adjustments when predicted emissions approach permitted limits. While the legally enforceable limits remain at maximum permitted emission levels, IP will make a voluntary commitment to maintain operations at a level equal to or less than 90% of its currently permitted maximum. Failure to observe this voluntary commitment could be an appropriate basis to terminate or modify the project. The method to accomplish this commitment will be through process optimization which will be determined during the model development and testing phase. IP will seek to optimize production and emissions so that emissions decrease while production remains the same or possibly increases.
Temporary Permit Exceedances During Developmental Testing
Some concerns had been raised regarding the proposed permit exceedances discussed in the project application. These exceedances would be necessary to allow for model development, such that it would be able to accurately predict those conditions that would produce emissions above the permitted levels. While it is recognized that these exceedances would be necessary, still, they represent a violation of existing permit conditions and a possible exceedence of NAAQS. This is part of the regulatory flexibility sought under the XL project.
The liklihood of a NAAQS exceedence is very remote since the WFI represents an insignificant portion of the mills overall impact on ambient air. However, to ensure this exceedence will not occur, the mill will monitor ambient conditions during testing and will stop or modify the testing protocol to prevent this occurance.
Pollution Prevention Upstream from End-of-Pipe Releases
Current regulations require traditional end-of-pipe periodic stack testing and continuous emissions monitoring (CEM) systems which are designed to record compliance with permit limits and exceedances when a violation actually occurs. With this system, there is no opportunity to prevent or lower emissions at the time of measurement. Conversely, the proposed implementation of the PEM will allow IP to directly correlate the relationship between varying operational parameters, predict emissions at its plant in advance, and allow IP to take action to adjust emissions before the exceedances actually occur. The ability will prevent the emission of pollutants at levels which approach or exceed permit limits. IP will make a voluntary commitment to take action such as process adjustments when predicted emissions get to within 90 percent of permitted limits.
Improvement in Stakeholder Priority Environmental Conditions
Presently, the mill has developed a Compliance Assurance Action Plan (Plan) which was developed as part of the Jay Air Permit No. 5 (Appendix A). This plan was developed using information obtained during five years of stack testing and general operator knowledge. The Town of Jay feels that the Plan is an integral part of the overall project and feels that it will help assist in assuring no violations. It identifies key parameters which may effect emissions and sets specific actions when these parameters move outside acceptable ranges. The Plan contains environmental conditions such as O2, scrubber flow and scrubber dP. IP will make a voluntary commitment to reinforce the parameters identified in the Plan and add any additional parameters identified in the project necessary to operate the incinerator in compliance.
Stakeholder Process
Efforts will be made to enlist particulate CEM suppliers as part of the stakeholders process. They will be asked to install one of their CEMs during the experimental phase of the project.