Part 11- Regulation of Business, Chapter 52: Environmental Regulation, Note 2

Summary and Analysis of Regulatory Requirements for B-P Paper Company B-P Paper Company’s proposed papermaking facility must comply with a range of environmental regulations to address its air emissions, wastewater discharge, and solid waste disposal. Additionally, ethical considerations arise for unregulated pollutants. 1. Air Emissions The facility will emit sulfur oxides (SOx), nitrogen oxides (NOx), and particulate matter (PM). Major requirements include:   Compliance with the Clean Air Act (CAA): o Ambient Air Quality Standards: The facility must ensure emissions align with the National Ambient Air Quality Standards (NAAQS) for SOx, NOx, and PM. o New Source Performance Standards (NSPS): As a new stationary source, the facility must use the best available control technology (BACT) to minimize emissions. o Preconstruction Permitting: A New Source Review (NSR) permit must be obtained, including assessment of potential emissions and air quality impacts. o State Implementation Plan (SIP): Compliance with Georgia's SIP is required to ensure local air quality standards are maintained. Control Technology: Likely installation of scrubbers, baghouses, or other systems to reduce SOx, NOx, and particulate emissions. 2. Wastewater Discharge The facility will draw water from and discharge treated water back into the Chattahoochee River. Major requirements include:  Clean Water Act (CWA): o National Pollutant Discharge Elimination System (NPDES) Permit: Required for all wastewater discharges into navigable waters. The permit will specify effluent limits for pollutants based on technology and water quality standards. o Water Quality Standards: Discharges must meet state and federal standards to ensure the Chattahoochee River maintains its designated uses (e.g., drinking water, recreation, wildlife habitat). o Pretreatment Requirements: The facility must treat its wastewater on-site to remove contaminants before discharge.  Monitoring and Reporting: Continuous monitoring and regular reporting to the Environmental Protection Division (EPD) in Georgia will be necessary to ensure compliance. 3. Waste Sludge and Container Disposal The facility’s waste sludge and chlorine containers will require proper handling under federal and state laws:   Resource Conservation and Recovery Act (RCRA): o Hazardous Waste Classification: If the sludge or containers are classified as hazardous waste (e.g., due to toxicity or corrosivity), the facility must adhere to strict generation, transportation, storage, and disposal rules. o Manifest System: A tracking system will document waste movement to prevent illegal dumping. o Landfill Standards: If the sludge is non-hazardous, disposal in a Subtitle D landfill must meet state and federal requirements. Container Management: Containers that held hazardous substances like chlorine must be decontaminated or disposed of according to RCRA standards. 4. Ethical Obligations for Unregulated Pollutants If the company identifies hazards not currently regulated, ethical considerations include:    Corporate Responsibility: Protecting human health and the environment beyond compliance demonstrates good corporate citizenship and builds public trust. Precautionary Principle: B-P Paper could implement additional safeguards (e.g., advanced filtration or waste minimization strategies) to mitigate risks from unregulated substances. Stakeholder Engagement: Transparency with the community and stakeholders about potential risks and mitigation efforts can preempt regulatory or public backlash. National Environmental Policy Act (NEPA) Requirements If federal funding or permitting is involved, the company must prepare an Environmental Impact Statement (EIS). The EIS would analyze: 1. 2. 3. 4. 5. Environmental impacts of the project. Unavoidable adverse impacts. Alternatives to the proposed action. Short- and long-term environmental consequences. Irreversible resource commitments.