ADEQ

ARK A N S A S

Department of Environmental Quality

September 27, 2011

Guy Donaldson, Chief

Air Planning Section - MC 6PD

USEPA - Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Re: Response to Regional Haze SIP Review Questions

Mr. Donaldson:

In your letter of September 14,2011, you requested clarification on eight aspects of the Regional

Haze State Implementation Plan (RH SIP) that was submitted by the Arkansas Department of

Environmental Quality in September 2008. The following responses are based on our review of

the documents that were included in the original submittal and, in some instances, the

recollection of the Air Division staff that participated in the development of the RH SIP. For ease

of review, your questions have been reproduced herein with responses following each.

Supporting documentation has been provided in various formats depending on the type of media

best suited to the purpose.

1. The Georgia-Pacific Crossett Mill 6A Boiler was included in the table of BART eligible

sources under the Arkansas Pollution Control and Ecology Commission Regulation 19,

Chapter 15, but it was not identified in the RH SIP narrative as being BART eligible (see

page 45 of the RH SIP narrative). We would like clarification regarding the startup date

of the boiler, and request that documentation corroborating the startup date of the boiler

be submitted to us. As you are aware, the startup date criteria for BART eligibility

provides that a unit is BART eligible ifit was in existence on August 7.1977, but was not

in operation before August 7, 1962.

Response: The facility provided ADEQ with a copy of a document "Boiler - Report of

Inspection - Standard Form for States and Cities Operating Under the ASME Code" ( copy

enclosed) that was prepared by an inspector for The Travelers Indemnity Company. The first

inspection of this boiler was conducted on 08/06/62 and the report was stamped "paid" on

08/15/62. While we have previously asserted that the boiler could not be considered as "in

operation" prior to the issuance of the report, ADEQ cannot say this with certainty. The boiler

could be considered capable of operation as of 08/06/62. Despite this uncertainty regarding the

date of start of operations, the boiler was modeled by ADEQ and found to be not subject to

BART. A copy of the modeling files is enclosed. This information has been previously provided

to Region 6 modeling staff.

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS 72118-5317/ TELEPHONE 501-682-0744 / FAX 501-682-0880

www.adeq.state.ar.us
Guy Donaldson - USEPA Region 6 September 27,2011

2. The Georgia-Pacific Crossett Mill 9A Boiler was identified as BART eligible in the RH

SIP. Even though the visibility modeling provided in Appendix 9.2B of the RH SIP

shows that the 9A Boiler of the Georgia-Pacific Crossett Mill has visibility impacts

exceeding the 0.5 dv contribution threshold, ADEQ did not identify the boiler as being

subject to BART. ADEQ should clarify how it determined that the boiler is not subject to

BART. If additional modeling, not submitted with the SIP, was relied upon to make this

determination, we request that this additional modeling and all related documentation be

submitted to us.

Response: The original modeling that ADEQ conducted was based on the potential emissions

described in the Engineering Analysis. Subsequent to this modeling, Georgia-Pacific provided

stack test data that allowed for the modeling to be re-conducted with actual emissions. The

resulting impacts were below applicability thresholds. Documentation supporting this decision is

enclosed.

3. The Great Lakes Chemical Plant Boilers SN-301A and SN-302-A were not identified as

BART eligible in the RH SIP, but Great Lakes Chemical is one of the facilities ADEQ

evaluated to determine if it is subject to BART. We understand that ADEQ determined

that since the two boilers are not integral to the process, they are not BART eligible. We

request that ADEQ submit to us the documentation that provided the basis for concluding

the two boilers are not integral to the process.

Response: Language on Pg. 87 of Arkansas Operating Permit 1077-AOP-Rl states that these

boilers are used to "supply the plant with steam." Per an e-mail sent by J. Kordzi, EPA R6 on

06/01106, "These small Category 22 boilers that contribute only energy (e.g. steam or heat) to a

process are not considered to be BART-eligible." An excerpted page from Great Lakes Chemical

Corporation - Central Plant Permit No. 1077-AOP-Rl, containing this information, is enclosed.

4. The International Paper/Evergreen Packaging No.1 and No.2 Power Boilers were not

identified as BART eligible in the RH SIP, but International Paper is one of the facilities

ADEQ evaluated to determine if it is subject to BART. We understand ADEQ

determined the two boilers fall out of the startup date criteria for BART eligibility. We

request that ADEQ provide supporting documentation regarding the startup date of the

two boilers.

Response: The requested documentation is enclosed. The referenced facility was indeed one of

the facilities that ADEQ evaluated in regard to "subject to BART" determinations; however the

determinations were made on a unit by unit basis, not a facility-wide basis, as per the

requirements contained within the federal regulations. ADEQ never considered the units listed

above to be BART eligible and were not identified as such.

5. The Entergy Lake Catherine Unit 4 was identified as BART eligible and subject to BART

in the RH SIP. ADEQ adopted BART emission limits of 0.5621b/MMBtu for S02 and

2
Guy Donaldson - USEPA Region 6 September 27, 2011

0.037 IblMMBtu for PM for fuel oil firing conditions, but there is conflicting information

in the RH SIP regarding what percent sulfur content fuel oil corresponds to these

emission limits. Sections 3.2 and 5.0 of the BART analysis for Lake Catherine Unit 4

both state that use of 1% sulfur content fuel oil is BART for SOz and PM, while the RH

SIP narrative states the adopted BART emission limits correspond to use of 0.5% sulfur

content fuel oil (see Table 9.3a). We request that ADEQ clarify whether 0.5% or 1%

sulfur content fuel oil corresponds to the adopted BART emission limits, and provide

documentation (including any pertinent calculations) of how the SOz and PM emission

limits were derived.

Response: The fuel oil Sulfur content in the SIP (0.5 wt. %) is correct. Supporting calculations

documenting that the SOz emission limits in the SIP are based on 0.5 wt. % Sulfur and the

calculations used to develop PM emissions are enclosed.

It should be noted that, as per an inspection report dated 07/28/11, this facility is no longer

capable of burning fuel oil. The fuel tanks were emptied and the pipework necessary to bum fuel

oil was in the process of being removed. The facility, operated as a peaking unit, does maintain

the ability to bum natural gas. While ADEQ does not anticipate modifying the limits in the RH

SIP at this time, it appears that the fuel oil-based limits are no longer relevant.

6. In Appendices 5.2 and 5.3 of the RH SIP, ADEQ included formulas and other

information related to the estimation of natural and baseline visibility conditions for its

two Class I areas but did not include any actual calculations. We request that these

calculations be submitted to us.

Response: The natural and baseline visibility conditions calculations were performed off-site by

the VIEWS Steering Committee. The resultant values are contained in the "Natural Haze Levels

II (version 2) spreadsheet" on the VIEWS web site. [Ref. - Visibility Information Exchange Web

Site (VIEW), accessible at

http://vista.cira.colostate.edu/views/weblDataRepositorylDataRepository.htm (accessed

3/19/2008)]. Values in the RH SIP were extracted from this spreadsheet and incorporated in the

document.

7. The RH SIP did not contain information regarding the 2002 baseline emissions and

emissions resulting from BART controls on sources that Arkansas shared with the

CENRAP modeling workgroup for inclusion in the 2002 base case modeling and the

2018 future case modeling. We request that ADEQ submit this information to us.

Response: The Base-year modeling inventory was prepared by the CENRAP Modeling

Workgroup and consultants and was derived primarily from the 2002 National Emission

Inventory. A comprehensive description of the manner in which E. H. Pechan and Associates,

Inc. prepared and compiled a model-ready inventory is contained in Appendix 7.1-B of the RH

SIP. For the Future-Year run, ADEQ provided the workgroup and Pechan with the controlled

BART source emission limits that are contained in Regulation 19 and the RH SIP and they

replaced the base-year emissions for these sources with the BART emissions. ADEQ did not

3
Guy Donaldson - USEPA Region 6 September 27, 2011

provide these numbers in the form of emission reductions as this was not required in order to

accomplish the task at hand and was not a requirement of the Regional Haze Rule.

8. ADEQ performed initial BART screening modeling for all BART eligible sources, in

addition to the post-control modeling for all subject to BART sources. However, Entergy

hired a consultant (ENSR) to conduct additional CALPUFF modeling for Lake Catherine

and White Bluff. Although ENSR's modeling files were referred to in the BART analyses

for the two sources, they were not submitted with the SIP. There is also information on

PM speciation that was referred to in the submittal, but was not submitted with the SIP.

We request that ADEQ submit to us the information on PM speciation and ENSR's

modeling files for Lake Catherine and White Bluff.

Response: The requested documentation is contained on the CD enclosed herein.

Hopefully, the information and documentation contained in this letter and its enclosures will

provide you and your staff with sufficient evidence of the diligent efforts of ADEQ's Air

Division in its attempt to draft a RH SIP. If, for any reason, additional information would support

your review, please contact me directly.

Sincerely,

Mike Bates

Chief

Air Division

enclosures: Georgia-Pacific Crossett Mill Inspection Report for 6-A Boiler

Correspondence with Georgia Pacific regarding Actual Emissions

CD containing modeling file for Georgia-Pacific and ENSR files for Entergy

Excerpted page from Great Lakes Chemical Corporation Permit 1077-AOP-Rl

PDF File of Correspondence with International Paper Documenting Age of Boilers

S02 and Particulate Emission Calculations for Entergy - Lake Catherine Fuel Oil Burning

4
StandQr!:f Form for States and Cities Operating Under the ASME Cod"

BOILER- REPORT OF INSPECTION

3

5

6

7

9

12/04/2005 10:47 03 BOILER

NAT'l BOARD OR STATE STANDARD NO.

AtB, ;2tJ 9:L .

-- 1

15 CONDrrlON OF OUECT SI,lC~ THAT CERllACAU MAY Be ISSUeD (If N", .~p/.r" fully)

rgj Yel No .

PAGE 02/05

t

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",helh..r De/;V" or ;nceti"". Slam /oe..tlon ..nd exl.nf of o"y .ro.;o", rJro<>Y;nll, /wlll;ng. warpl"(;, cmcklng or .Imil"r e~lId;f;on. Reporl "" any d"fedlv" riv..t.;

bo,...,d, 100'0 Dr brok..n ,lay•• SIa", eon.;Jitlon of 011 fub••, 'ub" end., eoi/., nippl", .te. £le,er/be Clny "dv.r", condil,on, wilh NI,pect to preutJNI oogo/ WOftJr

tolumn, gogo (1101/1, ""11" <oeh, •.,k!ty Yl;llve" efc. Roporl condltiM of ...Iflng. Un;ng', bl;lffle., IICIpporlt, elc. D".";b,, any mQlor ehClng .. "r repoln mod..

•ineo 1"'1 ;/up<tdio".

Indemnity Company

11 REQUIREMENTS (U,I ••.1. vIolallon.)

NAME AND TITLE OF PE.RSON TO WHOM REQUIREMENTS WERE EXPLAINeD

\ AUG 15 1962
..Georgia.pacific

January 26,2007

Mike Bates

Chief, Air Division

Arkansas Department of Environmental Quality

Post Office Box 8913

Little Rock, AR 72219-8913

RE: Georgia-Pacific LLC Crossett Paper BART Emissions

AFIN: 02-00013 Pennit Number: 597-AOP-R8

Dear Mr. Bates:

Georgia-Pacific Corporation

Consumer Products

100 Mill Supply Road

P. O. Box 3333

Crossett, AR 71635

(870) 567-8000

{870} 364·9076 fax

V'lww.gp.com

lbis letter is in follow-up to an e-mail from Mary Pettyjohn in regards to the BART

determination for Georgia-Pacific LLC Crossett Paper Operation. Ms. Pettyjohn

requested that we summarize our participation in the BART process and present to you

the combined findings ofthe Department and Georgia-Pacific.

Initially, the Department developed a preliminary list ofBART-eligible facilities from

readily-available information. For our facility, the 9A Boiler (SN-22) was flagged as

being old enough and large enough to be subject to BART. The Department informed us

ofthis and asked us to quickly gather actual emissions data for PMIO, S02, and NOx for

the years of2001, 2002, and 2003. The Department had a short time-frame to formulate

its BART strategy, and as such, could not give us much time to respond.

Because it would be extremely difficult to gather the requested S02 data given the time

constraints and because there was no recent stack testing data for S02 at that source,

Georgia-Pacific instead submitted the permitted potential emissions for that time period

(which were based on AP-42 factors that did not include emissions scrubbing by the

bleach plant water). This approach was deemed to be the most conservative, and

Georgia-Pacific submitted it to allow for the Department to meet its deadlines. However,

the use ofpotential worst-case emissions in the dispersion model, as opposed to a more

realistic emissions figure based on source-specific testing, resulted in the Department's

determination that we did fall under the criteria ofBART regulations.

Since that time, we have performed stack testing that gives more accurate data for 802

emissions. The facility uses a scrubber for particulate control on the 9A Boiler, and the

water used in this scrubber is from the bleach plant. It has been established at other mills,

and now at ours, that the make-up ofthat water scrubs out an appreciable amount of802

emissions. This scrubber was used in this manner during the BART applicability period

of2001, 2002, and 2003.
In the e-mail from Ms. Pettyjohn referenced above, she included the updated modeling

results. The results show that the 6A Boiler and 9A Boiler, modeled individually and

combined, do not contribute a change in deciview (dv) equal to or greater than (=» 0.500

dv and do not cause a change in dv => 1.00 dv and thus are not subject to BART controls.

Her results are included as an attachment to this letter.

Using the updated model results, Georgia-Pacific believes that the 6A and 9A Boilers

should no longer be considered as BART regulated sources. We respectfully request that

the Department review our combined findings and respond in writing with your

concurrence.

If you have any questions, please contact Mark Aguilar at (404) 652-4293, Michael Watt

at (870) 567-8188, or myself at (870) 567-8144. We appreciate all your help in this

matter.

Sincerely,

~~~bJ.tJ&,;t£

o::~:~. Cutbirth

Supt. Environmental Services

Georgia-Pacific LLC

cc: Mark Aquilar, Georgia-Pacific LLC

Michael Watt, Georgia-Pacific LLC

mhw

enclosure

3
Copy of GPCR BART Results from Actuals

No of days No of days No of days No of days No of days No of days

wlth~ wlth~ wlth~ with ().dy with a>-dv with ().dy

=>0.50 for =>1.00 for Maximum =>0.50 for =>1.00 for Maximum =>0.50 for =>1.00 for Maximum

Facility NamelLocation (BART File Name) !-iass I Area 2001 2001 a> dv 2002 2002 a>cIv 2003 2003 CDdv

Georgia-Pacific PaperI Crossett (GPCR) CACR 0 0 0.167 0 0 0.339 0 0 0.221

HEGL 0 0 0.089 0 0 0.312 0 0 0.136

MING 0 0 0.132 0 0 0.095 0 0 0.162

SIPS 0 0 0.147 0 0 0.144 0 0 0.333

UPBU 0 0 0.116 0 0 0.101 0 0 0.368

Note: O>-dv =change in deciview

.. CACR =Caney Creek Wilderness

Area, AR; HEGl =Hercules-Glade

Wilderness Area, MO; MING = Mingo

Wilderness. MO; SIPS =Sipsey

Wilderness Area, Al; UPBU = Upper

Buffalo Wilderness Area, AR

Prepared by Mary Pettyjohn 1/26/2007 Page 1
..Georgia.pacific

January 26, 2007

Mike Bates

Chief, Air Division

Arkansas Department of Environmental Quality

Post Office Box 8913

Little Rock, AR 72219-8913

RE: Georgia-Pacific LLC Crossett Paper BART Emissions

AFIN: 02-00013 Permit Number: 597-AOP-R8

Dear Mr. Bates:

Georgia-Pacific Corporation

Consumer Products

100 Mill Supply Road

P. O. Box 3333

Crossett, AR 71635

(870) 567-8000

(870) 364-9076 fax

www.gp.com

This letter is in follow-up to an e-mail from Mary PettY,john in regards to the BART

determination for Georgia-Pacific LLC Crossett Paper Operation. Ms. Pettyjohn

requested that we summarize our participation in the BART process and present to you

the combined findings ofthe Department and Georgia-Pacific.

Initially, the Department developed a preliminary list ofBART-eligible facilities from

readily-available information. For our facility, the 9A Boiler (SN-22) was flagged as

being old enough and large enough to be subject to BART. The Department informed us

ofthis and asked us to quickly gather actual emissions data for PMIO, S02, and NOx for

the years of200 I,2002, and 2003. The Department had a short time-frame to fonnulate

its BART strategy, and as such, could not give us much time to respond.

Because it would be extremely difficult to gather the requested S02 data given the time

constraints and because there was no recent stack testing data for S02 at that source,

Georgia-Pacific instead submitted the permitted potential emissions for that time period

(which were based on AP-42 factors that did not include emissions scrubbing by the

bleach plant water). This approach was deemed to be the most conservative, and

Georgia-Pacific submitted it to allow for the Department to meet its deadlines. However,

the use ofpotential worst-case emissions in the dispersion model, as opposed to a more

realistic emissions figure based on source-specific testing, resulted in the Department's

determination that we did fall under the criteria ofBART regulations.

Since that time, we have performed stack testing that gives more accurate data for S02

emissions. The facility uses a scrubber for particulate control on the 9A Boiler, and the

water used in this scrubber is from the bleach plant. It has been established at other mills,

and now at ours, that the make-up ofthat water scrubs out an appreciable amount ofS02

emissions. This scrubber was used in this manner during the BART applicability period

of2001, 2002, and 2003.
We used the stack testing data to detennine a more accurate emission factor for 802

emissions. Then we used that factor with the worst-case actual monthly fuel usage for

that time period to determine an emission rate. We then submitted updated maximum

emissions to the Department. The updated emissions are also included in the following

table:

9A Boiler Emission Rates

Year 2001 2002 2003

Maximum Hourly 90.01blhr 90.01blhr 90.01blhr PMIO Emissions

Maximum Hourly 306.71b/hr 306.71blhr 306.71blhr 802 Emissions

Maximum Hourly 244.01blhr 244.01b/hr 244.01blhr NOx Emissions

At about this same time, Georgia-Pacific was informed by the Department that it had

found documentation that the 6A Boiler (8N-19) was inspected on August 6, 1962 and

had a hydrostatic test on July 3, 1962. These dates brought the 6A Boiler's BART

eligibility into question as well. Georgia-Pacific searched its own records and did not

find any documentation that would demonstrate that there was no steam production

during the trigger period.

We then gathered records offuel usage for the 6A Boiler during the years of 2001, 2002,

and 2003 to allow for calculation ofmaximum daily emissions for PMIO, 802, and NOx.

While the boiler is pennitted to bum oil, natural gas was the only fuel burned during that

period. We calculated emissions using AP-42 factors and the worst-case daily fuel usage.

The results were submitted to the Department and are also included in the table below:

6A Boiler Emission Rates

Year 2001 2002 2003

Maximum Daily 7,772MCF 5,685 MCF 5,039 MCF Gas Usage

Maximum Hourly 2.461blhr 1.801blhr 1.601blhr PMIO Emissions

Maximum Hourly 0.191b/hr O.l4lblhr O.13lblhr 802 Emissions

Maximum Hourly 32.381blhr 23.681blhr 21.00lblhr NOx Emissions

2
In the e-mail from Ms. Pettyjohn referenced above, she included the updated modeling

results. The results show that the 6A Boiler and 9A Boiler, modeled individually and

combined, do not contribute a change in deciview (dv) equal to or greater than (=» 0.500

dvand do not cause a change in dv => 1.00 dv and thus are not subject to BART controls.

Her results are included as an attachment to this letter.

Using the updated model results, Georgia-Pacific believes that the 6A and 9A Boilers

should no longer be considered as BART regulated sources. We respectfully request that

the Department review our combined findings and respond in writing with your

concurrence.

If you have any questions, please contact Mark Aguilar at (404) 652-4293, Michael Watt

at (870) 567-8188, or myself at (870) 567-8144. We appreciate all your help in this

matter.

Sincerely,

~~~w.t~-tt

(/:n~~~. Cutbirth

Supt. Environmental Services

Georgia-Pacific LLC

cc: Mark Aquilar, Georgia-Pacific LLC

Michael Watt, Georgia-Pacific LLC

mhw

enclosure

3
ATIACHMENTA

BART Modeling Results
Copy of GPCR BART Results from Actuals

No of days No of days No of days No of days No of days No of days

with (])..dv with Ol-dv with Ol-dv with a>-dv with Ol-dv with (])..dv

=>0.50 for =>1.00 for Maximum =>0.50 for =>1.00 for Maximum =:>0.50 for =>1.00 for Maximum

Facility NamelLocation (BART File Name) ~laS$IArea 2001 2001 Ol dv 2002 2002 Q)dv 2003 2003 Oldv

Georgia-Pacific Paper I Crossett (GPCR) CACR 0 0 0.167 0 0 0.339 0 0 0.221

HEGl 0 0 0.089 0 0 0.312 0 0 0.136

MING 0 0 0.132 0 0 0.095 0 0 0.162

SIPS 0 0 0.147 0 0 0.144 0 0 0.333

UPBU 0 0 0.116 0 0 0.101 0 0 0.368

Note: Ol-dv =change in deciview

* CACR =caney Creek Wilderness

Area, AR; HEGL = Hercules-Glade

Wilderness Area, MO; MING =Mingo

Wilderness, MO; SIPS =Sipsey

Wilderness Area, AL; UPBU = Upper

Buffalo Wilderness Area. AR

Prepared by Mary Pettyjohn 1/26/2007 Page 1
Great Lakes Chemical Corporation - Central Plant

Permit: 1077-AOP-Rl

AFIN: 70-00012

Boilers and NaHS Process

SN.301, 302,303,902,906,907, and 908

Boiler #2, Boiler #3, Boiler #4, Sour Gas Flare, Cooling Towers

Source Description

Boilers

Great Lakes Chemical Corporation operates three boilers which supply the plant with steam.

Boiler #2 (SN-301) is a 150 MMBTU/hr boiler which is permitted to operate on pipeline quality natural, fuel

gas from the NaHS Plant, or "sweetened" gas from the N Amine unit at Lion Oil Company's facility.

Boiler #3 (SN-302) is a 113 MMBTU/hr boiler which fires pipeline quality natural gas and "sweetened gas

from Lion Oil's N Amine Unit.

Boiler #4 (SN-303) is an 88.6 MMBTUlhr boiler which fires only pipeline quality natural gas. This boiler is

subject to the requirements ofNSPS Subpart Dc.

Boiler #2 and #3 have been permitted in the past to combust fuel oil in times ofnatural gas curtailment. The

boilers no longer have the capability offiring fuel oil.

NaBS Process

Thc major steps in the production are: Sour gas and sodium hydroxide (caustic) are reacted, NaBS product is

stored in tanks, and NaHS product is shipped via truck. The various NaBS storage tanks are insignificant

activities under category B-2 I.

Cooling towers, SN-906, 907, and 908, are used to cool the process water used in the NaHS unit.

Sour Gas Handling and Flaring Operations

Brine is pumped to the surface from the underlying Smackover foundation at GLCC's brine supply wells. The

brine may contain dissolved hydrogen sulfide gas (sour gas) and oil, which must be separated from the brine

before it is sent to the bromine towers. The brine and sour gas streams are piped to the plant. The crude oil is

stored in tanks for future sales. From the Central Plant GLCC processes the combined sour gas streams in one

ofthe following ways:

Scenario #1: Amine Operation. The combined sour gas streams are transported via pipeline to Lion Oil

Company, a neighboring petroleum refinery, where the sour gas is processed in Lion Oil's amine unit and

returned as "sweet gas" to GLCC for use as fuel in boilers #2 and #3; and/or

Scenario #2: NaBS/Amine Operation. All or a portion ofthe combined sour gas streams are processed in

GLCC's Sodium Hydrosulfide Plant (NaHS Plant) where the sour gas is partially sweetened and the partially

sweetened gas is routed to Lion Oils amine unit for further refinement and sweet gas is returned to GLCC for

use as a fuel in boilers #2 or #3; or

Scenario #3: NaHs Operation. When the sulfur-containing gas stream (sour gas or partially sweetened NaHS

gas) cannot be routed to Lion Oil's amine unit, the combined sour gas streams are processed in GLCC's NaHS

unit where the sour gas is sweetened and the NaHS gas is routed directly to GLeC's Boiler #2 for use as fuel.

In the event of a startup, shutdown, malfunction, or upset condition of Lion Oil's amine unit, the NaHS unit, or

equipment integral to the processing ofthe combined sour gas streams, GLCC's sour gas will be combusted in

87
ADEQ

ARK A N S A S

Department of Environmental Quality

August 30,2006

Ms. Kelly D. Bryant

Environmental Group Leader

International Paper Company

P.O. Box7069

Pine Bluff, Arkansas 71611-7069

Re: BART Eligibility of Power Boilers 1 and 2, SN-13 and SN-15

Dear Ms. Bryant:

This letter is to notify you that Power Boilers one and two were inadvertently classified

as being BART-eligible due to erroneous information in the permit application.

Therefore, neither boiler is subject to BART.

The data you supplied by fax on August 24, 2006 was sufficient to research the true

ages of the two boilers. The Arkansas Department of Labor, Boiler Inspection Division,

inspected both boilers on May 27,1958 and issued Annual Inspection Certificates for

the two boilers June 26, 1958. Enclosed are copies of the inspection certificates.

The new information does not require a modification to the permit at this time. But the

information should be included in the next permit application submitted for a

modification or renewal. The changes will be in the source description and the

Emission Rate Table.

Sincerely,

~£.~~ William E. Swafford

Engineer, P.E.

cc: Tom Rheaume

Mary Pettyjohn

AIR DIVISION ~~M ., ,T''''''''" "'DO\'e , DI"\"T I"\CC'I'"'C QI"\V DOl ':l I IITTI F ~("\rl( AI1I(AN!';A!'; 12'219.8913 / TELEPHONE 501.682.0739 / FAX 501.682.0753
08/29/2005 14:30 03 :•• ',. ,'" • " • .. • • '. ':. ", •• ','. "f •• ·.' • • ...' .. . BOILER PAGE 02/02

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PAGE 02/02

BOILER INSPECTION

Little Bock, Ark.

BOILER

.. State of Arkansas' . .

.DEPARTME.NT 'OF"LA'B:OR' ,.:.. ' . . . . :,' ,',,' . .' ..

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. . . .' ANNUAL' INSPECTION CERTIficATE' .. .•

This is tQ'ce1'tify that. the h~ein de~bed.·~teamBOu~ maybt opera~~d:at a pressure not to exceed '~'.'~, pounds per squl1'e inch· for. a peri04'~' o~ ·Yll!a.t" from tha' date inspeet~, wil~ss wtthctrawD for ca~~· '. "

'.Nameof 'User .±t1t~r.nati()U1. 'J:»a~~;~ur.: '.~ate Inspected '.ar.21 ' ...... , l~~:...·...

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600 ,.,.m8f~/hr

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Entergy Lake Catherine is permitted to burn #6 fuel oil. The average BTUs in a gallon of #6 fuel oil is

153,000. A gallon of #6 fuel oil has an average density of 8.3 pounds (Ibs). One pound (Ib) of sulfur

produces 2 Ibs of sulfur dioxide.

0.562 lbs Sulfur Dioxide * lIb SUlfur * 153,000 BTUs . * 1 Gallon #6 Fuel Oil = 0.00517988 *100 =

106 BTUs 2 lbs Sulfur Dioxide 1 Gallon #6 Fuel Oil 8.31bs

.5% Sulfur/ lb

Entergy Lake Catherine Unit 4 is a tangential boiler with a maximum heat input of 5850 MMBTUs/hr.

From AP-42 page 1.3-13

Total condensable particulate matter 2.5 (PM2.S) Emission Factor (EF) = 1.5 Ibs/103 gallons

From AP-42 page 1.3-15 uncontrolled utility boilers PM2.

S EF = 4.3A

Where A= 1.12(5) +0.37 and 5 = 0.5

A = 1.12(.5) +0.37

A = 0.93

Therefore, PM2.S= 4.3(0.93) = 4 Ibs PM2.s/103 gallons

Total PM2.5 = 1.5 +4 = 5.5 Ibs/l03 gallons

Boiler specs = 5850 MMBTUs/hr

From AP-42 page 1.3-8

150 MMBTUs/l03 gallons

5850 MMBTUs * 10

3

gallons = 39 X103 II n /h

hr 150MMBTUs ga 0 s r

39 X 103gallons * 5.51bs = 214.5 Ibs/hr

hr 103 gallons

214.51bs hr

hr * 5850 MMBTUs = 0.0366 Ibs/MMBTUs = 0.037 Ibs/MMBTUs