Report. Toxic Reduction Plan. Conestoga-Rovers & Associates 651 Colby Drive Waterloo, Ontario N2V 1C2.

Transcription

1 Report Carbon Monoxide Oxides of Nitrogen Particulate Matter <10 Particulate Matter <2.5 Prepared for: Interlake Acquisition Corporation Limited Conestoga-Rovers & Associates 651 Colby Drive Waterloo, Ontario N2V 1C2 December 2013

2 Table of Contents Page Section 1.0 Introduction Basic Facility Information Statement of Intent Objectives Facility Description... 3 Section 2.0 Identification and Description Stages and Processes Process Flow Diagram... 4 Section 3.0 Tracking and Quantification Process Combustion Equipment Process Process Combustion Equipment Process (Created) Process Combustion Equipment (Released to Air) Input/Output Balance Comfort Heating Process Comforting Heating Process (Created) Comfort Heating Process (Released to Air) Input/Output Balance Emergency Generator Process Emergency Generator Process (Created) Emergency Generator Process (Released to Air) Input/Output Balance Dust Collectors Process Dust Collectors Process (Created) Dust Collector Process (Released to Air) Input/Output Balance Section 4.0 Facility-Wide Accounting Information Use Creation Transformation Destruction Contained In Product Releases to Air Releases to Land Releases to Water Disposals (On-Site) Disposals (Off-Site) Off-Site Transfers (Treatment or Recycling) Section 5.0 Direct and Indirect Cost Analysis Section 6.0 Toxic Substance Use and Creation Reduction Options Material or Feedstock Substitution Options December 2013

3 Table of Contents Page Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Product Redesign or Reformulation Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Equipment or Process Modifications Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Spill and Leak Prevention Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility On-Site Reuse and Recycling Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Improved Inventory Management/Purchasing Techniques Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Training or Improved Operating Practices Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Section 7.0 Options to Be Implemented Section 8.0 Plan Certifications December 2013

4 List of Figures Page Figure 1 Facility General Process Flow Diagram... 5 Figure 2 Flow Diagram for the Paper/Tissue Machines... 5 Figure 3 Process Combustion Equipment Process... 6 Figure 4 Comfort Heating Process... 9 Figure 5 Emergency Generator Process Figure 6 Dust Collector List of Tables Page Table 1 Toxic Substances from Process Combustion Equipment... 6 Table 2 Toxic Substances emissions Created from Process Combustion Equipment... 7 Table 3 Toxic Substances Created from Comfort Heating Equipment... 9 Table 4 Toxic Substances Created from Comfort Heating Table 5 Toxic Substances Created from Emergency Generator Table 6 Toxic Substances emissions Created from Emergency Generator Table 7 PM10 and PM2.5 from Dust Collectors Table 8 Calculation of PM10 and PM2.5 Created from Dust Collector List of Appendices Appendix A Appendix B Appendix C Appendix D Appendix E Planner Recommendations Plan Summary for Oxides of Nitrogen Plan Summary for Carbon Monoxide Plan Summary for PM10 Plan Summary for PM-2 December 2013

5 Section 1.0 Introduction 1.1 Basic Facility Information Example table of basic facility information: Name & CAS # of Substance Carbon Monoxide Oxides of Nitrogen Particulate Matter <10 Particulate Matter < NA NA Facility Identification and Site Address Company Name Facility Name Interlake Acquisition Corporation Limited Interlake Paper 45 Merritt Street, Facility Address St. Catherines, Ontario L2T 1J4 Spatial Coordination of Facility m E (UTM Coordinates) m N Number of Employees 107 NPRI ID Ontario MOE ID Number 5428 Parent Company (PC) Information PC Name PC Address Percent Ownership for PC Clearwater Paper Corporation Located at 601 West Riverside, Suite 1100 Spokane, Washington, United States (100% owned) Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 32 - Manufacturing 4 Digit NAICS Code 3221 Pulp, Paper and Paperboard Mills 6 Digit NAICS Code Paper (except newsprint) Mills December

6 Company Contact Information Gord Allen, Central Utilities Chief Engineer Facility Public Contact Phone: (905) Fax: (905) Gord Allen, Central Utilities Chief Engineer Facility Technical Contact: Phone: (905) Fax: (905) Company Coordinator Contact Gord Allen, Central Utilities Chief Engineer Phone: (905) Person who Prepared the Plan: (if different from the Coordinator) Highest Ranking Employee Planner Responsible for Making Recommendations Planner Responsible for Certification Fax: (905) Erik Martinez, P.Eng Conestoga-Rovers & Associates Limited 651 Colby Drive, Waterloo ON N2V 1C2 Phone: (519) Fax: (555) Steve Michalko, Mill Manager Phone: (905) Fax: (905) Planner Information: Erik Martinez, P.Eng Planner License No: TSRP0005 Conestoga-Rovers & Associates Limited 651 Colby Drive, Waterloo ON N2V 1C2 Phone: (519) Fax: (555) Erik Martinez, P.Eng Phone: (519) Fax: (555) December

7 1.2 Statement of Intent Interlake Acquisition Corporation Limited (Interlake) is committed to playing a leadership role in protecting the environment. Whenever feasible, we will eliminate, or reduce the creation and releases of carbon monoxide, oxides of nitrogen, PM10 and PM2.5 in compliance with all Federal and Provincial Regulations. 1.3 Objectives Interlake produces high quality paper/tissue products in an environmentally responsible manner. Interlake will strive to reduce the creation of carbon monoxide, oxides of nitrogen, PM10, PM2.5 at the facility. Further, this plan will determine the technical and economic feasibility of each option to determine which, if any, are viable for implementation at this time. 1.4 Facility Description The Interlake facility is a paper/tissue manufacturing facility. The facility receives virgin fibre and recycled materials and loads them into large pulpers. Through agitation and chemical additives, the pulp is broken down into loose individual fibres. After each batch is complete, the fibres are then transferred via pumps to its respective holding chest. Depending on the type or grade of paper being produced on the machine, fibres from each of the holding chests are metered into the Machine Chest at variable rates. The mixed fibres or stock is then diluted down and injected onto the machines wire section. As the stock is carried along the machine, moisture is removed from the stock by vacuums, heat, and pressing rolls. The dried paper is cut at customer preferred widths, wrapped in a plastic film and placed on a truck for shipment either directly to the customer or to a warehouse for temporary storage. Polyvinyl alcohol (PVA) is mixed with water to form an adhesive and applied to the Yankee dryer before the paper is passed through the dryer. The North American Industry Classification System (NAICS) Code that applies to this Facility is Paper (except newsprint) Mills. Section 2.0 Identification and Description 2.1 Stages and Processes Carbon Monoxide, Oxides of Nitrogen, PM10 and PM2.5 is created from the combustion of natural gas in process related equipment and comfort heating equipment, as well as from combustion of No. 2 Fuel Oil. Also, PM10 and PM2.5 are created from the Facility's dust collector. The stages and processes that involve these toxic substances are as follows: A variety of products are received at the Facility in several different forms (Receiving and Storage Stage). When the material is ready to be used, it is transferred into a hopper. This stage does not involve the toxic substances and therefore is not included in the quantification section. December

8 The products are added through a hopper in the appropriate batch sizes quantities, approximately once every 9 hours into a tank where it is agitated with water and cooked at a temperature of 147 F for duration of 3 hours. The mixture is then allowed to cool for 6 hours. Once cooled, the solution is transferred to a holding tank where it is maintained at a temperature of 112 F. When ready for use, the mixture is pumped to a blending tank at a rate of 2800 ml/min and mixed with other chemicals. The mixture is then ready to be applied to the Yankee Dryer. The glue mixture is applied to the Yankee dryer at 120 psi before the paper from Dryer #1 is introduced to this stage. The rate of application is not metered. The Yankee dryer operates at 240 F. The dried paper is then cut to the appropriate widths, wrapped in a plastic film and shipped off-site. This stage does not involve the toxic substances and therefore is not included in the quantification section. The facility operates process equipment which is fueled by natural gas, including a burner, a boiler and a dryer. The natural gas that is burned in the process equipment produces carbon monoxide, oxides of nitrogen, PM10 and PM2.5, which is directly released to the atmosphere. It is estimated that 90% of the natural gas consumed at the Facility is used for process combustion equipment. This stage is further described in Section 3.1. In the comfort heating process natural gas is combusted and exhausted through the comfort heating stack. The natural gas that is burned in the comfort heating equipment produces carbon monoxide, oxides of nitrogen, PM10 and PM2.5, which is directly released to the atmosphere. It is estimated that 10 percent of the natural gas consumed at the Facility is used for comfort heating purposes. This stage is further described in Section 3.2. The facility operates an emergency generator which was run occasionally throughout the year for testing purposes. The generator runs on diesel fuel which produces carbon monoxide, oxides of nitrogen, PM10 and PM2.5, which is directly released to the atmosphere. This stage is further described in Section 3.3. The Facility operates one dust collector at the Facility to treat fugitive particulate matter emissions from the Tissue Machine area. Fugitive emissions are created from several of the processes involved in the Tissue Machine stage. This stage is further described in Section 3.4. In 2012, the facility operated 24 hours a day, 7 days a week, and 50 weeks of the year. 2.2 Process Flow Diagram The following process flow diagram showing the Facility stages and processes is provided as a visual aid in interpreting the movement of the toxic substance throughout the facility. December

9 Figure 1- Facility General Process Flow Diagram A more detailed process flow diagram of the paper/tissue Machines is provided as a visual aid in understanding the movement of the toxic substance throughout the facility. Figure 2 - Flow Diagram for the Paper/Tissue Machines December

10 Section 3.0 Tracking and Quantification 3.1 Process Combustion Equipment Process The facility operates process equipment which is fueled by natural gas, including a burner, a boiler and dryer. The natural gas that is burned in the process equipment produces carbon monoxide, oxides of nitrogen, PM10 and PM2.5, which is directly released to the atmosphere. It is estimated that 90 percent of the natural gas consumed at the Facility is used for process combustion equipment. Figure 3 Process Combustion Equipment Process Table 1 Toxic Substances from Process Combustion Equipment Toxic Substance Creation (C 1 ) (tonnes) Emitted to Air (A 1 ) (tonnes) Carbon Monoxide Oxides of Nitrogen PM PM Process Combustion Equipment Process (Created) A) Tracking and Quantification Method Quantification Method: Emission Factor The amount of carbon monoxide, oxides of nitrogen, PM10 and PM2.5 created in the process related equipment is based on USEPA-AP42 emission factors for boilers less than 100 million BTUs and annual natural gas consumption. Interlake has identified that 90 percent of the total natural gas consumption from the facility is consumed in the process equipment. December

11 B) Best Available Method Rationale Emission Factors The use of USEPA AP-42 emission factors for the determination of the amount of each toxic substance being created from process equipment combusting natural gas is considered to have average data quality. Raw Material Quantities The quantity of natural gas consumed at the Facility is tracked by utility invoices. The quantity used specifically for process related purposes is an estimated value. Therefore, the raw material quantities quality of data is considered to be average. C) Quantification of Toxic Substance Table 2 Toxic Substances emissions Created from Process Combustion Equipment Source Process Equipment (C 1 ) Toxic Substance USEPA AP-42 Emission Factor (kg/10 6 m 3 ) Natural Gas Consumed in 2012 (m 3 ) Percent of Natural Gas used in Process Equipment (%) Total Emission Rate (tonnes/yr) Carbon 1,344 15,066,321 90% Monoxide Oxides of 1,600 15,066,321 90% Nitrogen PM ,066,321 90% PM ,066,321 90% Sample Calculation Carbon Monoxide: 15,066,321 m3 1,344 kg C 1 = yr m 3 90% C 1 = tonnes yr December

12 3.1.2 Process Combustion Equipment (Released to Air) A) Tracking and Quantification Method Quantification Method: Mass Balance The amount of each toxic substance released to air in the Process Combustion Equipment Process is equal to the amount that was created in the Process Combustion Equipment Process. B) Best Available Method Rationale Emission Factors Refer to Section 3.1.1B Raw Material Quantities Refer to Section 3.1.1B C) Quantification of Toxic Substance Refer to Section 3.3.1C Input/Output Balance Use + Creation = Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Off-Site Transfers (for treatment, recycling) + Disposals Note: This Process only includes carbon monoxide, oxides of nitrogen, PM10 and PM2.5 created and released to air. Carbon Monoxide: C 1 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes Oxides of Nitrogen: C 1 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes December

13 PM10: C 1 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes PM2.5: C 1 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes After evaluating the input/output balance, no material sources were found to be missing and no calculation errors were identified. Therefore given the data quality of the values used in the input/output balance, the results are considered reasonable and acceptable 3.2 Comfort Heating Process In the comfort heating process natural gas is combusted and exhausted through the comfort heating stack. The natural gas that is burned in the comfort heating equipment produces carbon monoxide, oxides of nitrogen, PM10 and PM2.5, which is directly released to the atmosphere. It is estimated that 10 percent of the natural gas consumed at the Facility is used for comfort heating purposes. Figure 4 Comfort Heating Process Table 3 Toxic Substances Created from Comfort Heating Equipment Toxic Substance Creation (C 2 ) (tonnes) Emitted to Air (A 2 ) (tonnes) Carbon Monoxide Oxides of Nitrogen PM PM December

14 3.2.1 Comforting Heating Process (Created) A) Tracking and Quantification Method Quantification Method: Emission Factor The amount of carbon monoxide, oxides of nitrogen, PM10 and PM2.5 created in the comfort heating equipment is based on USEPA-AP42 emission factors for boilers less than 100 million BTUs and annual natural gas consumption. Interlake has identified that 10 percent of the total natural gas consumption from the facility is consumed in the comfort heating equipment. B) Best Available Method Rationale Emission Factors The use of USEPA AP-42 emission factors for the determination of the amount of each toxic substance being created from the combustion of natural gas in comfort heating equipment is considered to have average data quality. Raw Material Quantities The quantity of natural gas consumed at the Facility is tracked by utility invoices. The quantity used specifically for comfort heating is an estimated value. Therefore, the raw material quantities quality of data is considered to be average. C) Quantification of Toxic Substance Table 4 Toxic Substances Created from Comfort Heating Source Toxic Substance USEPA AP-42 Emission Factor (kg/10 6 m 3 ) Natural Gas Consumed in 2012 (m 3 ) Percent of Natural Gas used in Comfort Heating (%) Total Emission Rate (tonnes/yr) Comfort Heating (C 2 ) Carbon 1,344 15,066,321 10% Monoxide Oxides of 1,600 15,066,321 10% Nitrogen PM ,066,321 10% PM ,066,321 10% December

15 Sample Calculation Carbon Monoxide: 15,066,321 m3 1,344 kg C 2 = yr m 3 10% C 2 = tonnes yr Comfort Heating Process (Released to Air) A) Tracking and Quantification Method Quantification Method: Mass Balance The amount of each toxic substance released to air in the Comfort Heating Process is equal to the amount that was created in the Comfort Heating Process. B) Best Available Method Rationale Emission Factors Refer to Section 3.2.1B Raw Material Quantities Refer to Section 3.2.1B C) Quantification of Toxic Substance Refer to Section 3.2.1C Input/Output Balance Use + Creation = Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Off-Site Transfers (for treatment, recycling) + Disposals Note: This Process only includes carbon monoxide, oxides of nitrogen, PM10 and PM2.5 created, and released to air. December

16 Carbon Monoxide: C 2 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes Oxides of Nitrogen: C 2 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes PM10: C 2 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes PM2.5: C 2 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes After evaluating the input/output balance, no material sources were found to be missing and no calculation errors were identified. Therefore given the data quality of the values used in the input/output balance, the results are considered reasonable and acceptable. 3.3 Emergency Generator Process The facility operates an emergency generator which is used occasionally throughout the year for testing purposes. The generator runs on diesel fuel which produces carbon monoxide, oxides of nitrogen, PM10 and PM2.5, which is directly released to the atmosphere. Figure 5 Emergency Generator Process December

17 Table 5 Toxic Substances Created from Emergency Generator Toxic Substance Creation (C 3 ) (tonnes) Emitted to Air (A 3 ) (tonnes) Carbon Monoxide Oxides of Nitrogen PM PM Emergency Generator Process (Created) A) Tracking and Quantification Method Quantification Method: Emission Factor The amount of carbon monoxide, oxides of nitrogen, PM10 and PM2.5 created in the comfort heating equipment is based on USEPA-AP42 emission factors for diesel fuel combustion in uncontrolled diesel industrial engines. The emergency generator was utilized in August and October of the 2012 calendar year. B) Best Available Method Rationale Emission Factors The use of USEPA AP-42 emission factors for the determination of the amount of each toxic substance being created from the combustion of diesel fuel in the emergency generator is considered to have average data quality. Raw Material Quantities The quantity of diesel fuel consumed at the Facility is tracked by utility invoices. Therefore, the raw material quantities quality of data is considered to be above average. C) Quantification of Toxic Substance Table 6 Toxic Substances emissions Created from Emergency Generator Source Toxic Substance USEPA AP-42 Emission Factor (kg/10 6 m 3 ) Emergency Generator (C 3 ) Diesel Fuel Consumed in 2012 (L) Total Emission Rate (tonnes/yr) Carbon Monoxide 0.6 3, Oxides of Nitrogen 2.4 3, PM , PM , December

18 Sample Calculation Carbon Monoxide: C 3 = 3,230 L yr 0.6 kg L C 3 = tonnes yr Emergency Generator Process (Released to Air) A) Tracking and Quantification Method Quantification Method: Mass Balance The amount of each toxic substance released to air in the Emergency Generator Process is equal to the amount that was created in the Emergency Generator Process. B) Best Available Method Rationale Emission Factors Refer to Section 3.3.1B Raw Material Quantities Refer to Section 3.3.1B C) Quantification of Toxic Substance Refer to Section 3.3.1C Input/Output Balance Use + Creation = Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Off-Site Transfers (for treatment, recycling) + Disposals Note: This Process only includes carbon monoxide, oxides of nitrogen, PM10 and PM2.5 created, and released to air. December

19 Carbon Monoxide: C 3 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes Oxides of Nitrogen: C 3 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes PM10: C 3 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes PM2.5: C 3 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes After evaluating the input/output balance, no material sources were found to be missing and no calculation errors were identified. Therefore given the data quality of the values used in the input/output balance, the results are considered reasonable and acceptable. 3.4 Dust Collectors Process The Facility operates one dust collector at the Facility to treat fugitive particulate matter emissions from the Tissue Machine area. Fugitive emissions are created from several of the processes involved in the Tissue Machine stage. The PM10 and PM2.5 is released to the atmosphere from the dust collector (A 4 ). Figure 6 - Dust Collector December

20 Table 7 PM10 and PM2.5 from Dust Collectors Toxic Substance Creation (C 4 ) (tonnes) Emitted to Air (A 4 ) (tonnes) PM PM Dust Collectors Process (Created) A) Tracking and Quantification Method Quantification Method: Emission Factor The PM2.5 that is released from the dust collector is based on the flowrate of the dust collector, manufacturers guaranteed outlet loading factor of grains/ft 3 and the dust collector hours of operation in B) Best Available Method Rationale PM10 and PM2.5 Emission Factor The emissions of PM10 and PM2.5 from the dust collector are based on a guaranteed outlet loading. When considering other methods of calculating the creation of PM, the guaranteed outlet loading factor provides the highest data quality. This calculation is considered to have average data quality as it is based on an emission factor. One option to improve the data quality of the dust collector's emissions would be to perform stack testing. Hours of Operation The hours of operation during the year 2012 is tracked internally by the Facility. The exhaust flowrate of the dust collector is also known and used in the calculations. C) Quantification of Toxic Substance Table 8 - Calculation of PM10 and PM2.5 Created from Dust Collector Name Dust Collector Identification Flowrate of Dust Collector (ft 3 /min) Manufacturers' Outlet Loading (grains/ft 3 ) Dust Collector Schedule (hrs/yr) Emission Rate (tonnes/yr) Dust Collectors (C 4 ) Source 30 15, , December

21 Sample Calculation - Dust Collector C 4 = C 4 = 15,000 ft3 min tonnes yr grains ft Dust Collector Process (Released to Air) A) Tracking and Quantification Method Quantification Method: Emission Factor kg 60 min 7,864 hr grains hr yr It was assumed that all PM10 and PM2.5 was released to air from the Dust Collector. B) Best Available Method Rationale Emission Factor Refer to Section 3.4.1B Hours of Operation The hours of operation during the year 2012 is tracked internally by the Facility. The exhaust flowrate of the dust collector is also known and used in the calculations. C) Quantification of Toxic Substance Refer to Section 3.1.1C Input/Output Balance To ensure that all PM10 has been accounted for in this process, an input/output calculation was completed using the following equation: Use + Creation = Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Off-Site Transfers (for treatment, recycling) + Disposals Note: This process only includes PM10 and PM2.5 created and released to air. December

22 C 4 = A tonnes/yr = tonnes/yr Unaccounted Material = 0 tonnes After evaluating the input/output balance, no material sources were found to be missing and no calculation errors were identified. Therefore, given the data quality of the values used in the input/output balance, the results are judged as reasonable and acceptable. Section 4.0 Facility-Wide Accounting Information 4.1 Use There was zero use of any of the toxic substances on-site in Creation The total facility wide creation of Carbon Monoxide, Oxides of Nitrogen, PM10 and PM2.5 during 2012 were as follows: Carbon Monoxide: Facility Wide Creation = C 1 + C 2 +C 3 = tonnes Oxides of Nitrogen: Facility Wide Creation = C 1 + C 2 +C 3 = tonnes PM10: Facility Wide Use = C 1 + C 2 +C 3 +C 4 = tonnes PM2.5: Facility Wide Use = C 1 + C 2 +C 3 +C 4 = tonnes 4.3 Transformation There were zero transformations of any of the toxic substances on-site in Destruction There were zero destruction of any of the toxic substances on-site in December

23 4.5 Contained In Product There were zero quantities of any of the toxic substances contained in product in Releases to Air The total facility wide amount of each toxic substance released to air in 2012 is equal to the amount created from the combustion of natural gas, combustion of No. 2 Fuel Oil and operation of the dust collector. Carbon Monoxide: Facility Wide Release to Air = A 1 + A 2 +A 3 = tonnes Oxides of Nitrogen: Facility Wide Release to Air = A 1 + A 2 +A 3 = tonnes PM10: Facility Wide Release to Air = A 1 + A 2 +A 3 + A 4 = tonnes PM2.5: Facility Wide Release to Air = A 1 + A 2 +A 3 + A 4 = tonnes 4.7 Releases to Land There were zero releases to land of any of the toxic substances on-site in Releases to Water There were zero releases to water of any of the toxic substances on-site in Disposals (On-Site) There were zero on-site disposals of any of the toxic substances in Disposals (Off-Site) There were zero off-site disposals of any of the toxic substances in Off-Site Transfers (Treatment or Recycling) There were zero off-site transfers of any of the toxic substances in December

24 Section 5.0 Direct and Indirect Cost Analysis The direct costs associated with the creation of carbon monoxide, oxides of nitrogen, PM10 and PM2.5 are the following: Dust Collector Maintenance $ 7,000 Comfort Heating Equipment Maintenance $ 4,000 Boiler Maintenance $ 25,000 The indirect costs associated with the creation of carbon monoxide, oxides of nitrogen, PM10 and PM2.5 are the following: NPRI/TRA Consulting Fees $ 10,000 Interlake Time Requirements for TRA/NPRI Reporting $ 800 [20 hrs x $40/hr] Therefore, the total direct/indirect cost for methanol at the Interlake Facility is $46,800. Section 6.0 Toxic Substance Use and Creation Reduction Options 6.1 Material or Feedstock Substitution Options Identification of Options The equipment operating at Interlake that creates carbon monoxide, oxides of nitrogen, PM10 and PM2.5 include comfort heating equipment and process equipment. The dust collector at the Facility emits PM10 and PM2.5. Therefore, no possible reduction options under the material or feedstock substitution category were identified that would reduce these toxic substances Estimated Reductions Not applicable Technical Feasibility Not applicable Economic Feasibility Not applicable. December

25 6.2 Product Redesign or Reformulation Identification of Options The sources at Interlake that are responsible for the creation of each toxic substance are not directly related to the formulation of the final product. Therefore, no possible reduction options for product redesign or reformulation were identified Estimated Reductions Not Applicable Technical Feasibility Not Applicable Economic Feasibility Not Applicable. 6.3 Equipment or Process Modifications Identification of Options The Facility has already modified the air/fuel ratio through the damper control on the dryer burner to allow for better combustion efficiency in the burner. The Facility has conducted a width reduction project on the dryer burner which has resulted in a reduction in gas consumption. There are currently no modifications available to be made to the equipment that creates the toxic substances that would result in a reduction of their creation. There are no process modifications that could occur which would alter the equipment usage required for the processes at Interlake resulting in a reduction in the creation of these substances. Therefore, no possible reduction options for equipment or process modifications were identified Estimated Reductions Not Applicable Technical Feasibility Not Applicable Economic Feasibility Not Applicable. December

26 6.4 Spill and Leak Prevention Identification of Options The Facility follows its maintenance schedules for all equipment associated with the creation of each toxic substance. It has been determined that no further measures can be taken to prevent any spills or leaks at the Facility. Therefore, no possible reduction options for spill and leak prevention were identified Estimated Reductions Not Applicable Technical Feasibility Not Applicable Economic Feasibility Not Applicable. 6.5 On-Site Reuse and Recycling Identification of Options There are no opportunities to re-use any collected dust at the Facility. The combustion equipment at Interlake that creates the toxic substances does not create leftover material that could potentially be recycled. Therefore, no possible reduction options for On-Site Reuse and Recycling have been identified Estimated Reductions Not Applicable Technical Feasibility Not Applicable Economic Feasibility Not Applicable. December

27 6.6 Improved Inventory Management/Purchasing Techniques Identification of Options Improving inventory management or purchasing techniques will not result in a reduction in the creation of the toxic substances. Therefore, no possible reduction options for improved inventory management/purchasing techniques were identified Estimated Reductions Not Applicable Technical Feasibility Not Applicable Economic Feasibility Not Applicable. 6.7 Training or Improved Operating Practices Identification of Options The equipment is used as required and there is no opportunity to improve operating practices that would result in a reduction of the toxic substances being created. Therefore, no possible reduction options for training or improved operating practices were identified Estimated Reductions Not Applicable Technical Feasibility Not Applicable Economic Feasibility Not Applicable. December

28 Section 7.0 Options to Be Implemented It was determined that there are no potential options available to reduce the creation of carbon monoxide, oxides of nitrogen, PM10 or PM2.5. Section 8.0 Plan Certifications Certification by Highest Ranking Employee As of October 25, 2013, I, Steve Michalko, certify that I have read the toxic substance reduction plan for the toxic substance referred to below and am familiar with its contents, and to my knowledge the plan is factually accurate and complies with the Toxics Reduction Act, 2009 and Ontario Regulation 455/09 (General) made under that Act. Carbon Monoxide Oxides of Nitrogen PM10 PM2.5 Steve Michalko Plant Manager Date December

29 Certification by Licensed Planner As of December 20, 2013, I, Erik Martinez, certify that I am familiar with the processes at that use or create the toxic substance referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the plan dated October 10, 2012 and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act. Carbon Monoxide Oxides of Nitrogen PM10 PM2.5 Erik Martinez, P. Eng. Planner License TSRP#0005 Conestoga Rovers & Associates Date December

30 Appendix A Planner Recommendations December 2013

31 651 Colby Drive, Waterloo, Ontario, N2V 1C2 Telephone: (519) Fax: (519) December 12, 2013 Reference No Mr. Gord Allen 45 Merritt Street St. Catherines, ON L2T 1J4 Dear Mr. Allen: Re: Toxics Reduction Plan Carbon Monoxide, Oxides of Nitrogen, PM10 & PM2.5 Planner Recommendations INTRODUCTION The Toxics Reduction Act and Ontario Regulation (O. Reg.) 455/09 require that each toxic substance reduction plan be reviewed and certified by a Licensed Toxic Substance Reduction Planner (Planner). Section 18 of O. Reg. 455/09 requires the Planner to provide recommendations, with supporting rationale, for the purposes of improving all aspects of the plan including the potential for reducing the use and creation of the toxic substance at the facility and the business rationale for implementing the plan. The Planner is required to provide recommendations for any of the following relevant issues, or a written explanation of why a recommendation is not necessary: 1. Whether improvements could be made in the expertise relied on in preparing the plan 2. Whether improvements could be made in: i. The data and methods used for accounting purposes ii. The process flow diagrams iii. Reasons why the input and output balances are not approximately equal iv. A description of how, when, where and why the substance is used or created 3. Whether there are technically and economically feasible options for reducing the use and creation of the substance at the facility that have not been identified in the plan that would result in reductions that are equal to or greater than those already identified in the plan 4. Whether improvements could be made in: i. The estimates of anticipated reduction of use or creation, releases to environment and contained in product of the substance ii. In determination of the technical feasibility of options Worldwide Engineering, Environmental, Construction, and IT Services

32 December 19, 2012 Reference No iii. In determination of the economic feasibility of options 5. Whether improvements could be made to the estimates of the direct and indirect costs 6. Whether the steps and timetable set out in the implementation plan are likely to be achieved. 1.0 EXPERTISE RELIED ON IN PREPARING THE PLAN This Toxic Substance Reduction Plan (Plan) was developed by a planning team that included Gord Allen, central utilities chief engineer at Interlake Acquisition Corporation Limited (Interlake), Gavin Moore, an environmental consultant, and Erik Martinez, a Licensed Certified Toxics Reduction Planner. Gord Allen is knowledgeable in all aspects of the production processes at Interlake and was able to provide the information required to develop the Plan. All relevant data was collected from the appropriate departments. Gavin Moore was responsible for preparing the plan through consultation with Gord Allen and with advice from the Licensed Planner. Erik Martinez has provided engineering consulting services for Interlake in the past and is familiar with the facility processes. The level of expertise relied on during the preparation of the Plan was sufficient that the involvement of any additional parties with relevant technical experience would not have improved the plan or increased the potential to reduce the creation of carbon monoxide, oxides of nitrogen, PM10 and PM ACCOUNTING Data and Methods Used The total amount of toxic substances created from the combustion of natural gas is based on USEPA-AP42 emission factors for boilers less than 100 million BTUs and annual natural gas consumption. The total amount of toxic substances created from the combustion of fuel oil is based on USEPA-AP42 emission factors for uncontrolled small boilers less than 100 million BTUs and annual natural gas consumption. The total amount of PM10 and PM2.5 created from the dust collector is based on manufacturers guaranteed outlet loading value of grains/ft 3 and the annual operational hours of the dust collector. Worldwide Engineering, Environmental, Construction, and IT Services

33 December 19, 2012 Reference No The on-site release to air of each toxic substance from the natural gas and Diesel Fuel combusting equipment and the dust collector is equal to the total amount created from this equipment. All quantities calculated for accounting purposes are based on emission factors. Based on the data available and the type of processes involved at Interlake, these are the most accurate and appropriate methods for accounting purposes. Process Flow Diagrams Interlake maintains process flow charts for all stages of production. The process flow diagrams provided for the purposes of this Plan are considered to be comprehensive and accurate. The accounting quantities of each toxic substance have been shown on each of the detailed process flow diagrams developed for each process at Interlake. This level of detail provides a comprehensive understanding of the flow of material through the process. The Plan satisfies this condition of the Regulation and a recommendation is not necessary. Input/Output Balance The input and output balances were calculated using a combination of Interlake s internal tracking records and mass balances. Therefore, the inputs are equal to the outputs, and a recommendation is not necessary. Description of how, when, where, and why the substance is used or created The Plan satisfies this condition of the Regulation and I have no recommendations to improve the Plan regarding this requirement. 3.0 TOXIC SUBSTANCE REDUCTION OPTIONS Interlake engaged in a detailed review of each reduction category. There are no possible reduction options for carbon monoxide, oxides of nitrogen, PM10 or PM2.5 at this time. Having completed a detailed review of Interlake s operation, including a site visit and meetings with Facility personnel, I agree with the justifications put forward in Section 6.0 of the Plan, which provide sufficient rationale for why Interlake could not identify reduction options to reduce the creation of carbon monoxide, oxides of nitrogen, PM10 or PM2.5 at this time. Worldwide Engineering, Environmental, Construction, and IT Services

34 December 19, 2012 Reference No DIRECT AND INDIRECT COSTS All manufacturing costs are independent of the creation of carbon monoxide, oxides of nitrogen, PM10 or PM2.5 and would exist regardless if these compounds were eliminated from the Facility. The Plan satisfies this condition of the Regulation and I have no recommendations to improve the Plan regarding this requirement. 5.0 IMPLEMENTATION PLAN There was no possible reduction options identified as justified by Interlake. Therefore, an implementation plan is not provided. Should you have any questions on the above, please do not hesitate to contact us. Yours truly, CONESTOGA-ROVERS & ASSOCIATES Erik Martinez, P. Eng. Certified Toxics Reduction Planner License #TSRP0005 GM// Worldwide Engineering, Environmental, Construction, and IT Services

35 Appendix B Plan Summary for Oxides of Nitrogen December 2013

36 TRA Plan Summary Oxides of Nitrogen Basic Facility Information Name & CAS # of Substance Oxides of Nitrogen Company Name Facility Name Facility Identification and Site Address Interlake Acquisition Corporation Limited Interlake Paper 45 Merritt Street, Facility Address St. Catherines, Ontario L2T 1J4 Spatial Coordination of Facility m E (UTM Coordinates) m N Number of Employees 107 NPRI ID Ontario MOE ID Number 5428 PC Name PC Address Percent Ownership for PC Parent Company (PC) Information Clearwater Paper Corporation Located at 601 West Riverside, Suite 1100 Spokane, Washington, United States (100% owned) Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 32 - Manufacturing 4 Digit NAICS Code 3221 Pulp, Paper and Paperboard Mills 6 Digit NAICS Code Paper (except newsprint) Mills Facility Public Contact Facility Technical Contact: Company Contact Information Steve Michalko, Mill Manager Steve.Michalko@clearwaterpaper.com Phone: (905) Fax: (905) Gord Allen, Central Utilities Chief Engineer gord.allen@clearwaterpaper.com Phone: (905) Fax: (905) December 2013 B-1

37 Company Coordinator Contact Person who Prepared the Plan: (if different from the Coordinator) Highest Ranking Employee Planner Responsible for Making Recommendations Planner Responsible for Certification Gord Allen, Central Utilities Chief Engineer Phone: (905) Fax: (905) Erik Martinez, P.Eng Conestoga-Rovers & Associates Limited 651 Colby Drive, Waterloo ON N2V 1C2 Phone: (519) Fax: (555) Steve Michalko, Mill Manager Phone: (905) Fax: (905) Planner Information: Erik Martinez, P.Eng Planner License No: TSRP0005 Conestoga-Rovers & Associates Limited 651 Colby Drive, Waterloo ON N2V 1C2 Phone: (519) Fax: (555) Erik Martinez, P.Eng Phone: (519) Fax: (555) Toxic Reduction Policy Statement of Intent Interlake Acquisition Corporation Limited (Interlake) is committed to playing a leadership role in protecting the environment. Whenever feasible, we will eliminate, or reduce the creation and releases of oxides of nitrogen in compliance with all Federal and Provincial Regulations. Reduction Objectives Interlake produces high quality paper/tissue products in an environmentally responsible manner. Interlake will strive to reduce the creation of Oxides of Nitrogen at the facility. Further, this plan will December 2013 B-2

38 determine the technical and economic feasibility of each option to determine which, if any, are viable for implementation at this time. Description of Facility The Interlake facility is a paper/tissue manufacturing facility. The facility receives virgin fibre and recycled materials and loads them into large pulpers. Through agitation and chemical additives, the pulp is broken down into loose individual fibres. After each batch is complete, the fibres are then transferred via pumps to its respective holding chest. Depending on the type or grade of paper being produced on the machine, fibres from each of the holding chests are metered into the Machine Chest at variable rates. The mixed fibres or stock is then diluted down and injected onto the machines wire section. As the stock is carried along the machine, moisture is removed from the stock by vacuums, heat, and pressing rolls. The dried paper is cut at customer preferred widths, wrapped in a plastic film and placed on a truck for shipment either directly to the customer or to a warehouse for temporary storage. Polyvinyl alcohol (PVA) is mixed with water to form an adhesive and applied to the Yankee dryer before the paper is passed through the dryer. The North American Industry Classification System (NAICS) Code that applies to this Facility is Paper (except newsprint) Mills. Toxic Substance Reduction Options to Be Implemented There were no options identified that can be implemented by Interlake to reduce the creation or releases of oxides of nitrogen. Plan Summary Statement This plan summary accurately reflects the content of the toxic substance reduction plan for oxides of nitrogen. Certification by Highest Ranking Employee Attached. Certification by Licensed Planner Attached. December 2013 B-3

39 Appendix C Plan Summary for Carbon Monoxide December 2013

40 TRA Plan Summary Carbon Monoxide Basic Facility Information Name & CAS # of Substance Carbon Monoxide Company Name Facility Name Facility Identification and Site Address Interlake Acquisition Corporation Limited Interlake Paper 45 Merritt Street, Facility Address St. Catherines, Ontario L2T 1J4 Spatial Coordination of m E Facility (UTM Coordinates) m N Number of Employees 107 NPRI ID Ontario MOE ID Number 5428 PC Name PC Address Percent Ownership for PC Parent Company (PC) Information Clearwater Paper Corporation Located at 601 West Riverside, Suite 1100 Spokane, Washington, United States (100% owned) Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 32 - Manufacturing 4 Digit NAICS Code 3221 Pulp, Paper and Paperboard Mills 6 Digit NAICS Code Paper (except newsprint) Mills Facility Public Contact Facility Technical Contact: Company Contact Information Steve Michalko, Mill Manager Steve.Michalko@clearwaterpaper.com Phone: (905) Fax: (905) Gord Allen, Central Utilities Chief Engineer gord.allen@clearwaterpaper.com Phone: (905) Fax: (905) December 2013 C-1

41 Company Coordinator Contact Person who Prepared the Plan: (if different from the Coordinator) Highest Ranking Employee Planner Responsible for Making Recommendations Planner Responsible for Certification Gord Allen, Central Utilities Chief Engineer Phone: (905) Fax: (905) Erik Martinez, P.Eng Conestoga-Rovers & Associates Limited 651 Colby Drive, Waterloo ON N2V 1C2 Phone: (519) Fax: (555) Steve Michalko, Mill Manager Phone: (905) Fax: (905) Planner Information: Erik Martinez, P.Eng Planner License No: TSRP0005 Conestoga-Rovers & Associates Limited 651 Colby Drive, Waterloo ON N2V 1C2 Phone: (519) Fax: (555) Erik Martinez, P.Eng Phone: (519) Fax: (555) Toxic Reduction Policy Statement of Intent Interlake Acquisition Corporation Limited (Interlake) is committed to playing a leadership role in protecting the environment. Whenever feasible, we will eliminate, or reduce the creation and releases of carbon monoxide in compliance with all Federal and Provincial Regulations. Reduction Objectives Interlake produces high quality paper/tissue products in an environmentally responsible manner. Interlake will strive to reduce the creation of carbon monoxide at the facility. Further, this plan will December 2013 C-2

42 determine the technical and economic feasibility of each option to determine which, if any, are viable for implementation at this time. Description of Facility The Interlake facility is a paper/tissue manufacturing facility. The facility receives virgin fibre and recycled materials and loads them into large pulpers. Through agitation and chemical additives, the pulp is broken down into loose individual fibres. After each batch is complete, the fibres are then transferred via pumps to its respective holding chest. Depending on the type or grade of paper being produced on the machine, fibres from each of the holding chests are metered into the Machine Chest at variable rates. The mixed fibres or stock is then diluted down and injected onto the machines wire section. As the stock is carried along the machine, moisture is removed from the stock by vacuums, heat, and pressing rolls. The dried paper is cut at customer preferred widths, wrapped in a plastic film and placed on a truck for shipment either directly to the customer or to a warehouse for temporary storage. Polyvinyl alcohol (PVA) is mixed with water to form an adhesive and applied to the Yankee dryer before the paper is passed through the dryer. The North American Industry Classification System (NAICS) Code that applies to this Facility is Paper (except newsprint) Mills. Toxic Substance Reduction Options to Be Implemented There were no options identified that can be implemented by Interlake to reduce the creation or releases of carbon monoxide. Plan Summary Statement This plan summary accurately reflects the content of the toxic substance reduction plan for carbon monoxide. Certification by Highest Ranking Employee Attached. Certification by Licensed Planner Attached. December 2013 C-3