The Pulp and Paper NESHAP at 40 C. F. R. §63.444(c) requires that the total HPA emissions from both the equipment systems listed in Paragraph 10 of the CAFO, and the vents, wastewater, and condensate streams from the control device used to reduce HAP emissions shall be controlled. Under 40 C.F.R. §63.444(c)(2), each magnesium based or ammonium based sulfite pulping process shall:
(i) emit no more than 2.2 lbs of total HAPS or methanolm per ton of Oven Dried Pulp (ODP); or
(ii) Remove 87 percent or more by weight of the total HAP or methanol.
On December 8, 2005, EPA issued to the Port Edwards Mill a Finding of Violation (FOV) of 40 C>F>R> §444(c)(2) based on the methanol emissions results submitted as identified in the CAFO.
Based on the analysis of the factors specified in Section 113(e) of the ACT, 42 U.S.C. §7413(c), the facts of this case, and Respondent's cooperation, it was determined that a Civil Penalty would be appropriate to settle this action.