Toxic Substance Reduction Plan Summary
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- Winifred Bradford
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1 Toxic Substance Reduction Plan Summary Resolute Forest Products Fort Frances Mill Phase 2 Substances BASIC FACILITY INFORMATION LEGAL & TRADE NAME AND SITE ADDRESS Company Name Resolute FP Canada Inc. Facility Name Fort Frances Division Facility Address 427 Mowat Avenue Fort Frances, ON Number of Employees 443 NPRI ID Ontario MOE ID 5101 Legal & Trade Name Resolute FP Canada Inc, 111 Duke Street, Suite 5000, Montreal, Qc, H3C 2M1 Address Percent Ownership 100 % Business Number PRIMARY NAICS CODES 2 Digit NAICS Code 32 Manufacturing 4 Digit NAICS Code 3221 Pulp, Paper and Paperboard Mills 6 Digit NAICS Code Newsprint Mills COMPANY CONTACT INFORMATION Facility Public Contact Cyndy Strand, Environmental Manager, (807) ext 1909 Facility Technical Contact Cyndy Strand, Environmental Manager, (807) ext 1909 (807) x1909 Person Who Prepared Plan Cyndy Strand, Environmental Manager, (807) ext 1909 Parent Company Contact Pascale Lagacé, Environmental Director, (514) Planner Responsible for Making Pascale Lagacé, Environmental TSRP0073 Recommendations Director, Planner Responsible for Certification Pascale Lagacé, Environmental Director, (514) TSRP0073
2 SUBSTANCE NAME AND CAS NUMBER Substance Name & CAS # Ammonia (Total) NA 16 Substance Name & CAS # Phosphorous (Total) * Substance Name & CAS # Chlorine Dioxide Substance Name & CAS # Total Reduced Sulphur Substance Name & CAS # NO Substance Name & CAS # CO Substance Name & CAS # SO Substance Name & CAS # Total Particulate Matter * Substance Name & CAS # PM 10 * Substance Name & CAS # PM 2.5 * Substance Name & CAS # Pentane * Substance Name & CAS # Hexane * Substance Name & CAS # Butane * Substance Name & CAS # Alpha Pinene * Substance Name & CAS # Beta Pinene * Substance Name & CAS # Propane * Substance Name & CAS # Methyl Isobutyl Ketone * Substance Name & CAS # D Limonene *
3 TOXIC REDUCTION PLAN OVERVIEW Statement of Intent Resolute FP Canada Inc, Fort Frances Mill, is committed to playing a leadership role in protecting the environment. Whenever technically and economically feasible, Resolute Fort Frances is committed to reduce the use and/or creation of toxic substances identified in this Toxic Substance Reduction Plan (TSRP) Summary in compliance with all Federal and Provincial Regulations. This plan summary accurately reflects the content of the TSRP for Ammonia, Phosphorous, Chlorine Dioxide, Total Reduced Sulphur, NO2, CO, SO2, TPM, PM10, PM2.5, and Speciated VOCs: Pentane, Hexane, Butane, Alpha Pinene, Beta Pinene, Propane, Methyl Isobutyl Ketone and D Limonene. Objectives of Plan Resolute Forest Products Fort Frances Mill is committed to reviewing the use, creation and options for reduction of all toxic substances identified in this TRSP; consequently, this plan will determine the technical and economic feasibility of each option to determine which, if any, are viable for implementation at this time. Plan Overview Information specific to each toxic substance is found in the following appendices: Appendix A Ammonia Appendix B Phosphorous Appendix C Chlorine Dioxide Appendix D Total Reduced Sulphur Appendix E Criteria Air Contaminants (SO2, NO2, CO) Appendix F Particulate Matter (TPM, PM10, PM2.5) Appendix G Speciated VOCs Information for each toxic substance includes: Descriptions of processes that use or create the toxic substance Annual costs associated with the toxic substance Reduction Options and associated reduction estimates Technical and Economic Feasibility of each option List of options to be implemented Toxic Substance Accounting Information Toxic Substance Accounting information, including records of methods used to track and quantify, quantifications and input and output analysis of all toxic substances identified in this TSRP can be found in the facility s toxic substance accounting files upon request.
4 APPENDIX A Ammonia (Total) Description of Processes That Use or Create Ammonia (Total) Ammonia created and released as a by product in the pulping process. It is also added as a nutrient in the waste water treatment system. Ammonia creation and destruction is very difficult to quantify in the WWTS as is in constantly changing state in the ammonification process. Detailed calculations and process information including flow charts are included in our TRA spreadsheets electronically or hard copies in the Environmental Manager's Office. Options to be Implemented Option 1 Idling of Kraft Mill The idling of the Kraft Mill would result in the elimination of the following air emission sources: Recovery Furnace, Smelt Tank, Lime kiln, Tall oil stacks, BL Vents, Brownstock washers, KM Effleunt building, Bleach plant, NCG Incinerator, (Release to Air) Conservatively estimate 10% reduction in release to water. Elimination of the aforementioned sources values were used. As the wastewater treatment system is a living system, using ammonia as a source of food, we are unsure as to the impact the idling of the Kraft mill will have on Use and Water Disposal. Investigation into impacts on lagoon operation will be monitored. Reduction Category Equipment or Process Modifications Estimate of Reductions Contained On Site Releases Disposal Transfer in Option 1 Used Create d Air Water L and On sit e O ff site off site Product Ammonia (To tal) (Tonnes) BASELINE N/A N/A N/A 0 Option 1: N/A N/A N/A 3.17 kg N/A 0 % Reduction 33% N/A 97% 00% N/A N/A 9.70% N/A 0% Implementation Plan The last cook in the Kraft mill was Dec 4, 2012, with the rest of the process down between Dec 5 6, At this time reduction in Creation and Release began. The majority of the clean up is to be completed by the end of 2012, with smaller jobs possibly continuing into February of 2013.
5 APPENDIX B Phosphorus Description of Processes That Use or Create Phosphorus Phophorus is coincidentally manufactured as a byproduct and released on site to the environment. It enters the process mainly from the wood and is released during the cook and oxygen delignification processes. In the combustion process it is disposed of from the ash as a waste product. Phosporus is added as a nutrient in the waste water treatment system Detailed calculations and process information including flow charts are included in our TRA spreadsheets electronically or hard copies in the Environmental Manager's Office. Options to be Implemented Option 1 Idling of Kraft Mill The idling of the Kraft Mill would result in the elimination of the Recovery furnace, the smelt dissolving tank and the lime kiln air emission sources. The discharge to the landfill of lime mud and green dregs would also be eliminated as well as the effluent wastewater discharge to WWTS. The use amount will also be reduced as the BOD load to the WWTS will be reduced, decreasing the amount of phosphorous we are sending to the lagoon. We expect the supplemental phosphorus added to the WWTS to be reduced as well. Reduction Category Equipment or Process Modifications Option 2 Biomass Boiler Operation Reduction Due to the idling of the Kraft mill, as well as increased operational costs to produce Cogen power, the operational load on the biomass boiler has been reduced. Anticipated boiler operation of below 75% MCR beginning in Biomass boiler will depend less on the combustion of wood sources and more on the combustion of natural gas (conservatively estimated 50% reduction) Reduction of the input of wood chips and therefore the reduction in the discharge of ash which is a large source of phosphorus to the landfill. Reduction Category Equipment or Process Modifications
6 Estimate of Reductions On Site Releases Disposal Transfer Contained in Used Created Air Water L and On sit e O ff site off site Product Phosphorus (Total) (Tonnes/year) BASELINE N/A N/A N/A Option 1: N/A N/A N/A 3.95 N/A 0 % Reduction 18% N/A 55% 50% N/A N/A 11% N/A 0 % Option 2: 9.56 N/A N/A N/A 3.59 N/A 0 % Reduction 25% N/A 23% 50% N/A N/A 10% N/A 0% Implementation Plan The last cook in the Kraft mill was Dec 4, 2012, with the rest of the process down between Dec 5 6, At this time planned reduction in Creation and Release began. Biomass boiler has been at minimum load since December 2013 and projected to continue to run at or below levels predicted when calculating reduction values.
7 APPENDIX C Chlorine Dioxide Description of Processes That Use or Create Chlorine Dioxide In the bleaching process, the chlorine dioxide (ClO2) is generated in the R8 generator as per the following equation: 3 NaClO3 + 2 H2SO CH3OH > 3 ClO2 + Na3H(SO4) H2O CH3OH HCOOH CO2 Chlorine dioxide is a successful bleaching agent as it is able to destroy lignin without significantly degrading cellulose; thus preserving pulp strength while giving it high, stable brightness. Detailed calculations and process information including flow charts are included in our TRA spreadsheets electronically or hard copies in the Environmental Manager's Office. Toxic Substance Use and Creation Reduction Options Options to be Implemented Option 1 Idling of Kraft Mill The idling of the Kraft Mill would result in the elimination of the R8 bleaching process which would completely eliminate this toxin in the process. Reduction Category Equipment or Process Modifications Estimate of Reductions On Site Releases Disposal Transfer Contained in Used Created Air Water L and On sit e Off site of f site Product Chlorine Diox ide (Tonnes) BASELINE N/A N/A N/A N/A N/A 0 Option 1: N/A N/A N/A N/A N/A N/A 0 % Reduction N/A 100% 100% N/A N/A N/A N/A N/A 0% Implementation Plan The last cook in the Kraft mill was Dec 4, 2012, with the rest of the process down between Dec 5 6, The majority of the clean up is to be completed by the end of 2012, with smaller jobs continuing into February of 2013.
8 APPENDIX D Total Reduced Sulphur Description of Processes That Use or Create Total Reduced Sulphur TRS is coincidentally manufactured as a by product in the pulping process and released. Detailed calculations and process information including flow charts are included in our TRA spreadsheets electronically or hard copies in the Environmental Manager's Office. Toxic Substance Use and Creation Reduction Options Options to be Implemented Option 1 Idling of Kraft Mill Trace quantities of TRS are inadvertently generated in pulp and paper mills as a by product from the use of sodium sulphide (Na2S) in kraft cooking. The idling of the Kraft Mill would result in the elimination of the following sources: Recovery Furnace, Smelt Tank, Lime kiln, NCG Incinerator, Brownstock washer, BL vents, KM Effluent building, and Impounding Tank (Release to Air) Reduction Category Equipment or Process Modifications Option 2 Primary and Secondary WWTS Odour Control Odor control chemistry is being used at the lagoon to minimize fugitive emissions from WWTS. Also, Primary WWTS odor control has been implemented with a continuous application of odor control chemicals (Hydrogen peroxide). Success has been measured due to a reduction in TRS exceedances Due to the fact that calculations are based on emission factors, no calculated reductions could be measured from either project.. Reduction Category Equipment or Process Modifications Estimate of Reductions On Site Releases Disposal Transfer Contained in Used Create d Air Water L and On sit e Off site of f site Product TRS (Tonnes/ year) BASELINE N/A N/A N/A N/A N/A 0 Option 1: N/A N/A N/A N/A N/A N/A 0 % Reduction N/A 84% 69% N/A N/A N/A N/A N/A 0 % Option 2: N/A N/A N/A N/A N/A N/A N/A N/A 0 % Reduction N/A N/A N/A N/A N/A N/A N/A N/A 0%
9 Implementation Plan The last cook in the Kraft mill was Dec 4, 2012, with the rest of the process down between Dec 5 6, The majority of the clean up is to be completed by the end of 2012, with smaller jobs possibly continuing into February of 2013.
10 APPENDIX E Criteria Air Contaminants (SO2, NO2, CO) Description of Processes That Use or Create CAC s CAC s are generally formed during combustion processes. They are a product of incomplete combustion. They are also formed as by products during the pulping process. Detailed calculations and process information including flow charts are included in our TRA spreadsheets electronically or hard copies in the Environmental Manager's Office. Toxic Substance Use and Creation Reduction Options Options to be Implemented Option 1 Idling of Kraft Mill The idling of the Kraft Mill would result in the elimination of the following sources: Recovery Furnace, Smelt Tank, Lime kiln, NCG Incinerator, Brownstock washer, BL vents, KM Effluent building, and Impounding Tank (Release to Air) Steam plant (NG combustion in Flash dryer, pkg boiler and misc heaters, biomass boiler) (Release to Air) Reduction Category Equipment or Process Modifications Estimate of Reductions On Site Releases Disposal Transfer Contained in Used Created Air Water Land On sit e Off site off site Product SO2 (Tonnes/ year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 67% 67% N/A N/A N/A N/A N/A N/A NO2 (Tonnes/ year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 32% 32% N/A N/A N/A N/A N/A N/A CO (Tonnes/y ear) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 38% 38% N/A N/A N/A N/A N/A N/A
11 Implementation Plan The last cook in the Kraft mill was Dec 4, 2012, with the rest of the process down between Dec 5 6, The majority of the clean up is to be completed by the end of 2012, with smaller jobs possibly continuing into February of 2013.
12 APPENDIX F Particulate Matter (TPM/PM10/PM2.5) Description of Processes That Use or Create Particulate Matter Particulate matter is coincidentally manufactured as a byproduct in pulp and paper manufacturing operations Detailed calculations and process information including flow charts are included in our TRA spreadsheets electronically or hard copies in the Environmental Manager's Office. Toxic Substance Use and Creation Reduction Options Options to be Implemented Option 1 Idling of Kraft Mill The idling of the Kraft Mill would result in the elimination of the following sources: Recovery Furnace, Smelt Tank, Lime kiln, NCG Incinerator, Brownstock washer, BL vents, KM Effluent building, and Impounding Tank (Release to Air) Reduction Category Equipment or Process Modifications Option 2 Idling of one Paper machine The idling of one Paper Machine would result in the reduction of the following sources: Paper Machine Vents (Release to Air) Reduction Category Product Design or Reformulation
13 Estimate of Reductions On Site Releases Disposal Transfer Contained in Used Created Air Water Land On sit e Off site of f site Product TPM (Tonnes/ year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 85% 85% N/A N/A N/A N/A N/A N/A Option 2: N/A N/A N/A N/A N/A N/A % Reduction % 0.35% N/A N/A N/A N/A N/A N/A PM10 (Tonnes/year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 87% 87% N/A N/A N/A N/A N/A N/A Option 2: N/A N/A N/A N/A N/A N/A % Reduction % 0.45% N/A N/A N/A N/A N/A N/A PM2. 5 (Tonnes/year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 85% 85% N/A N/A N/A N/A N/A N/A Option 2: N/A N/A N/A N/A N/A N/A % Reduction % 0.35% N/A N/A N/A N/A N/A N/A Implementation Plan The last cook in the Kraft mill was Dec 4, 2012, with the rest of the process down between Dec 5 6, As the emissions being reduced are based on NCASI emission factors which use production quantities to calculate emissions, these toxins were eliminated from above mentioned sources at that point in time. In 2012 the operational capacity of the paper machines has been reduced by operating one machine some of the time. It is forecasted to only be running one paper machine continually in 2013.
14 APPENDIX G Speciated VOC s (Pentane, Hexane, Butane, Alpha Pinene, Beta Pinene, Propane, Methyl Isobutyl Ketone and D Limonene) Description of Processes That Use or Create VOC s VOC s are generally generated as a by product in the paper making and pulping processes due to the processing of wood. From the NCASI NPRI handbook, they are "coincidentally manufactured as a byproduct" and thereby released. They are also created as a by product of combustion in the Biomass Boiler. Detailed calculations and process information including flow charts are included in our TRA spreadsheets electronically or hard copies in the Environmental Manager's Office. Toxic Substance Use and Creation Reduction Options Options to be Implemented Option 1 Idling of Kraft Mill The idling of the Kraft Mill would result in the elimination of the following sources: Loading Cyclone, Recovery Furnace, Smelt Tank, Lime kiln, BL vents, Bleach Plant, R8 Generator, Brownstock washers, KM Effluent building, and Impounding Tank (Release to Air) Reduction Category Equipment or Process Modifications Estimate of Reductions On Site Releases Disposal Transfer Contained in Used Create d Air Water Land On sit e Off site off site Product D Limone ne (Tonnes/ year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 29% 29% N/A N/A N/A N/A N/A N/A Methyl Isobutyl K etone (Tonnes/ year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 25% 25% N/A N/A N/A N/A N/A N/A
15 Alpha Pi nene (Tonnes/ year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 23% 23% N/A N/A N/A N/A N/A N/A Beta Pine ne (Tonnes/ year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 18% 18% N/A N/A N/A N/A N/A N/A Propane (Tonnes/year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 22% 22% N/A N/A N/A N/A N/A N/A Butane (T onnes/year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 22% 22% N/A N/A N/A N/A N/A N/A Hexane (Tonnes/year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 22% 22% N/A N/A N/A N/A N/A N/A Pentane (Tonnes/year) BASELINE N/A N/A N/A N/A N/A N/A Option 1: N/A N/A N/A N/A N/A N/A % Reduction 0 22% 22% N/A N/A N/A N/A N/A N/A Implementation Plan The last cook in the Kraft mill was Dec 4, 2012, with the rest of the process down between Dec 5 6, The majority of the clean up is to be completed by the end of 2012, with smaller jobs possibly continuing into February of 2013.
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