August 9 , 2011

Mark Spizzo M2Green Redevelopment, LLC c/o Green Investment Group, Inc. 601 E. Third Street, Suite 302

P.O. Box 249 Alton, Illinois 62002

RE: Administrative Amendment for Title V Operating Permit #OP 2589

- 07

Dear Mr. Spizzo :

The De partment of Environmental Quality has prepared the enclosed Final Operating Permit #OP 2589

- 07 , for M 2 Green , located in Missoula , Montana. Please review the cover page of the atta c hed permit for information pertaining to the action taking place on Permit # OP 2589

- 07.

If you have any questions, please contact Julie Merkel at (406) 444

- 3626 or by email at jmerkel @mt.gov

.

Sincerely,

Vickie Walsh Air Permitting Program Supervisor Air Resources Manage ment Bureau (406) 444

- 9741 Julie Merkel Air Quality Specialist Air Resources Management Bureau (406)444

- 3626

VW: JM

Enclosure

Cc: Christopher Ajayi, US EPA Region VIII 8P

- AR Caron Coate, US EPA Region VIII, Montana Office

Neal Marx er, Facility Contact PersonOP2589

- 07 i Date of Decision : 07/08/11

Effective Date: 08/09/11 STATE OF MONTANA Department of Environmental Quality Helena, Montana 59620

AIR QUALITY OPERATING PERMIT OP 2589

- 07

Issued to: M2Green Redevelopment, LLC

P.O. Box 4707 14377 Pulp Mill Road Missoula, MT 59806

- 4707

Fin al Date: August 9, 2011 Expiration Date: August 20, 2014

Effective Date: August 9, 2011

Date of Decision: July 8, 2011

Application Deemed Technically Complete: June 10, 2011 Application Deemed Administratively Complete: June 10, 2011

Admini strative Amendment Application Received: June 10, 2011

AFS Number: 030

- 063

- 0006 A

Permit Issuance and Appeal Processes: In accordance with Montana Code Annotated (MCA) Sections

75

- 2

- 217 and 218 and the Administrative Rules of Montana (ARM), ARM Title 17, C hapter 8, Subchapter 12, Operating Permit Program, this operating permit is hereby issued by the Department of Environmental Quality (Department) as effective and final on August 9, 2011 . This permit must be kept

on

- site at the above named facility.OP2589

- 07 ii Date of Decision : 07/08/11

Effective Date: 08/09/11 Mo ntana Air Quality Operating Permit Department of Environmental Quality

Table of Contents

SECTION I. GENERAL INFORMATION

................................ ................................ ............................. 1

SECTION II. SUMMARY OF EMISSION UNITS

................................ ................................ ................ 2

SECTION III. PERMIT CONDITIONS

- FACILITY WIDE

................................ .............................. 7

A. F ACILITY

- W IDE G ENERAL

................................ ................................ ................................ ................. 7

B. M ILL

- W IDE P ERMIT C ONDITIONS

................................ ................................ ................................ ... 12

SECTION IV. PERMIT CONDITIONS

- PULP, CHIP DOCK AND RECYCLED FIBER

DEPARTMENT

................................ ................................ ................................ ................................ ........ 14

A. S AWDUST H ANDLING

, C HIP H ANDLING

, B IO

- M ASS C ONVEYING

, H OG F UEL H ANDLING

............. 14

B. W ASHING

................................ ................................ ................................ ................................ ......... 18

C. C YCLONES

................................ ................................ ................................ ................................ ....... 20

D. M ICRO

- P ULSAIRE B AGHOUSE

................................ ................................ ................................ ......... 22

E. S TORAGE P ILES

................................ ................................ ................................ ................................ 23

SECTION V. PERMIT CONDITIONS

- POWER, RECOVERY, AND RECAUSTICIZING

DEPARTMENT

................................ ................................ ................................ ................................ ........ 24

A. N O

. 4 R ECOVERY B OILER

................................ ................................ ................................ ................ 24

B. N O

. 5 R ECOVERY B OILER

................................ ................................ ................................ ................ 29

C. N O

. 4 S MELT D ISSOLVING T ANK

................................ ................................ ................................ ..... 34

D. N O

. 5 S MELT D ISSOLVING T ANK

................................ ................................ ................................ ..... 36

E. M ULTI

- FUEL B OILER

................................ ................................ ................................ ....................... 38

F. L IME K ILNS

................................ ................................ ................................ ................................ ...... 44

G. L IME S LAKERS

................................ ................................ ................................ ................................ . 50

H. C ONDENSATE C OLLECTION (40 CFR 63, S UBPART S)

................................ ................................ .... 53

I. L OW V OLUME

, H IGH C ONCENTRATION (LVHC) AND H IGH V OLUME

, L OW C ONCENTRA TION (HVLC) N ON

- C ONDENSABLE G ASES (NCG) (40 CFR 63, S UBPART S)

................................ ......... 55

J. S TEAM S TRIPPER

................................ ................................ ................................ ............................. 57

K. T HERMAL O XIDIZER

................................ ................................ ................................ ........................ 59

L. N ATURAL G AS B OILERS

................................ ................................ ................................ .................. 62

M. M ISCELLANEOUS T ANKS /V ENT

................................ ................................ ................................ ....... 63

N. S ODA A SH S YSTEM

................................ ................................ ................................ .......................... 64

SECTION VI. PERMIT CONDITIONS

- PAPER MILL DEPARTMENT, ENVIRONMENTAL AND TECHNICAL DEPARTMENT, ENGINEERING AND MAINTENANCE DEPARTMENT 66

A. P APER M ACHINES

................................ ................................ ................................ ............................ 66

B. EU130

– E FFLUENT T REATMENT S YSTEM

................................ ................................ ...................... 68

C. EU120

– R OADS

, U NPAVED

................................ ................................ ................................ ............. 69

D. L IQUID F UEL H ANDLING

................................ ................................ ................................ ................. 70

E. EU152

– CFC R ECYCLING

................................ ................................ ................................ ............... 71

SECTION VII. NON

- APPLICABLE REQUIREMENTS

................................ ................................ ... 73

F ACILITY

- W IDE

................................ ................................ ................................ ................................ ....... 73

E MISSION U NITS

................................ ................................ ................................ ................................ ...... 73

SECTION VIII. GENERAL PERMIT CONDITIONS

................................ ................................ ........ 74

A. C OMPLIANCE R EQUIREMENTS

................................ ................................ ................................ ......... 74

B. C ERTIFICATION R EQUIREMENTS

................................ ................................ ................................ ..... 74

C. P ERMIT S HIELD

................................ ................................ ................................ ................................ 75

D. M ONITORING

, R ECORDKEEPING

, A ND R EPORTING R EQUIREMENTS

................................ ............... 76

E. P ROMPT D EVIATION R EPORTING

................................ ................................ ................................ ..... 77

F. E MERGENCY P ROVISIONS

................................ ................................ ................................ ................ 77

G. I NSPECTION AND E NTRY

................................ ................................ ................................ .................. 78

H. F EE P AYMENT

................................ ................................ ................................ ................................ .. 78OP2589

- 07 iii Date of Decision : 07/08/11

Effective Date: 08/09/11 I. M INOR P ERMIT M ODIFICATIONS

................................ ................................ ................................ ..... 79

J. C HANGES N OT R EQUIRING P ERMIT R EVISION

................................ ................................ ................ 79

K. S IGNIFICANT P ERMIT M ODIFICATIONS

................................ ................................ ............................ 80

L. R EOPENING FOR C AUSE

................................ ................................ ................................ ................... 80

M. P ERMIT E XPIRATION AND R ENEWAL

................................ ................................ ............................... 81

N. S EVERABILITY C LAUSE

................................ ................................ ................................ ................... 81

O. T RANSFER OR A SSIGNMENT OF O WNERSHIP

................................ ................................ ................... 82

P. E MISSIONS T RADING

, M ARKET ABLE P ERMITS

, E CONOMIC I NCENTIVES

................................ ........ 82 Q. N O P ROPERTY R IGHTS C ONVEYED

................................ ................................ ................................ .. 82

R. T ESTING R EQUIREMENTS

................................ ................................ ................................ ................ 82

S. S OURCE T ESTING P ROTOCOL

................................ ................................ ................................ .......... 82

T. M ALFU NCTIONS

................................ ................................ ................................ ............................... 82

U. C IRCUMVENTION

................................ ................................ ................................ ............................. 82

V. M OTOR V EHICLES

................................ ................................ ................................ ........................... 82

W. A NNUAL E MISSIONS I NVENTORY

................................ ................................ ................................ .... 83

X. O PEN B URNING

................................ ................................ ................................ ................................ 83

Y. M ONTANA A IR Q UALITY P ERMITS

................................ ................................ ................................ .. 83

Z. N ATIONAL E MISSION S TANDARD FOR A SBESTOS

................................ ................................ ........... 84

AA. A SBESTOS

................................ ................................ ................................ ................................ ........ 84

BB. S TRATOSPHERIC O ZONE P ROTECTION

– S ERVICING OF M OTOR V EHICLE A IR C OND ITIONERS

..... 84

CC. S TRATOSPHERIC O ZONE P ROTECTION

– R ECYCLING AND E MISSION R EDUCTIONS

....................... 84

DD. E MERGENCY E PISODE P LAN

................................ ................................ ................................ ............ 85

EE. D EFINITIONS

................................ ................................ ................................ ................................ .... 85

A PPENDICES

................................ ................................ ................................ ................................ ........... 86

APPENDIX A INSIGNIFICANT EMISSION UNITS

................................ ................................ .... A

- 1

APPENDIX B DEFINITIONS AND ABBREVIATIONS

................................ ................................ B

- 1

APPENDIX C NOTIFICATION ADDRESSES

................................ ................................ ............. C

- 1

APPENDIX D AIR QUALITY INSPECTOR INFORMATION

................................ .................... D

- 1

APPENDIX E COMPLIANCE ASSURANCE MONITORING (CAM) PLAN

............................. E

- 1

APPENDIX F AMBIENT AIR MONITORING PLAN

– S TATE

- O NLY

................................ ......... F

- 1OP2589

- 07 1 Date of Decision : 07/08/11

Effective Date: 08/09/11 Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this permit have the meaning assigned to them in the referenced regulations.

SECTION I. GENERAL INFORMATION

The following general information is provide d pursuant to ARM 17.8.1210(1).

Company Name: M2Green Redevelopment, LLC

Mailing Address : P.O. Box 249

City: Alton State: IL Zip: 62002

Plant Location: 14377 Pulp Mill Road, Section 24, Township 14 North, Range 21 West, Missoula

County, Mis soula, MT

Responsible Official: Mark Spizzo Phone: ( 618 ) 465

- 7985

Facility Contact Person: Neal Marxer Phone: (406) 626

- 4 451 (ext 848)

Primary SIC Code: 2631

Nature of Business: Production of linerboard used to make corrugated boxes.

Descrip tion of Process: M2Green ’s Missoula Mill is located close to Frenchtown, which is 10 miles northwest of Missoula. The mill produces unbleached linerboard products from a combination of sawmill residuals (sawdust and chips), roundwood, and recycled fiber. Pulp is produced in batch and continuous pulping digesters using the Kraft (sulfate) cooking process. Recycled fiber is also recovered from post

consumer paper sources on the recycling fiber line. Other major processes include raw materials handling, st eam and energy production, chemical recovery, paper production, and finished product handling and shipping. The mill has environmental control systems for air emissions and mill effluent.

The mill is divided in this permit into five major processes: 1) t he Pulp, Chip Dock, and Recycled Fiber Department, 2) the Paper Mill Department, 3) the Power, Recovery and Recausticizing Department, 4) the Environmental and Technical Department, and 5) the Engineering and Maintenance Department.

The mill’s daily limit s are defined by a mill day running from 5:00 am to 5:00 am.OP2589

- 07 2 Date of Decision : 07/08/11

Effective Date: 08/09/11 SECTION II. SUMMARY OF EMISSION UNITS

The emission units regulated by this permit are the following (ARM 17.8.1211):

Emission Unit

ID Description Pollution Control Device/Practice

PULP CHIP DOCK AND RECYCLED FIBER DEPARTMENT

EU004 Sawdust Handling Covered conveyors & limited drop heights

EU004a Sawdust Fines to Hog Fuel (& chip screening fines)

EU004b Sawdust Receipts

EU005 Chip Handling Covered conveyors

EU005a Chip Production

EU005b Chip Receipts

EU005c Chip Fines to Hog Fuel (& sawdust fines)

EU026 Washing

Base Stock Brownstock Washing Internal Washer Hood Design

EU026a No. 3 Base Stock Washer Feed Tank

EU026b Base Stock Washer Walkway Exhaust Thermal Oxidizer

EU026c No. 1 Base Stock Filtrate Tank Thermal Oxidizer

EU026d No. 2 Base Stock Filtrate Tank Thermal Oxidizer

EU026e Spill Collection Tank

– Base Washers

CB Washing Enclosed System

EU026f CB Washer Filtrate Tank EU026g CB Washers (M&D System)

E U026h M&D Foam Tower

PC Washing Wet Scrubber

EU026i Foam Tank Vents EU026j Intermediate Foam Tower

EU026k PC Washer Vent

EU026l PC Washer Stack I

EU026m PC Washer Stack II

Top Stock Washing Internal Washer Hood Design

EU026n Base Stock Reje ct Tank

EU026o Top Stock Foam Tower Tank and Filtrate Tanks Thermal Oxidizer EU026p Top Stock Reject Tank

EU026q Top Stock Washer Hood Exhaust Thermal Oxidizer

EU129 Bio

- Mass Conveying None

EU129a Bio

- Mass Conveyor & Pile

EU129b Bio

- Mass Conve yor to Hog Fuel Boiler

EU132 Cyclones None

EU132a M&D Sawdust Cyclone

EU132b No. 1 ADS Cyclone

EU132c No. 2 ADS Cyclone

EU132d No. 3 ADS Cyclone

EU132e No. 4 ADS Cyclone EU132g Sawdust Overs Cyclone

EU132h Unscreened Sawdust CycloneOP2589

- 07 3 Date of Decision : 07/08/11

Effective Date: 08/09/11 Emission Unit

ID Description Pollution Control Device/Practice

EU133 Micro

- Pulsaire Baghouse (Chip Thickness Baghouse) None

EU134 Storage Piles

EU134a Chip Pile Management Raw Chips Covered Conveyors

EU134c Sawdust Handling & Storage Emissions Covered Conveyors

EU134d Screened Batch Chip Pile None

EU134e Screened Kamyr Chip Pile None

EU134f Bio

- Mass Storage Pile None EU134g Hog Fuel Storage & Handling Emissions None

POWER, RECOVERY, AND RECAUSTICIZING

DEPARTMENT

EU002 No. 4 Recovery Boiler ESP

EU003 No. 5 Recovery Boiler ESP

EU011 No. 1 Lime Kiln Wet Venturi Scrubber

EU012 No. 2 Lime Kiln Wet Venturi Scrubber

EU013 No. 3 Lime Kiln Wet Venturi Scrubber

EU014 No. 4 Lime Kiln Wet Venturi Scrubber

EU016 No. 4 Smelt Dissolving Tank Wet Scrubbe r EU017 No. 5 Smelt Dissolving Tank Wet Scrubber

EU018 No. 1 Lime Slaker Wet Scrubber

EU019 No. 2 Lime Slaker Wet Scrubber

EU020 No. 3 Lime Slaker Wet Scrubber

EU021 Multi Fuel Boiler Two Parallel Wet Scrubber s EU024 No. 1 Power Boiler

EU101 Ash Ha ndling

EU039 Salt Cake/Lime Unloading

EU040 Soda Ash System Bin Vent Dust Collector

EU102 Black Liquor Handling None

EU102a No. 1 Concentrator Boil Out Tank

EU102b No. 1 Spill Collection Tank

EU102c No. 1 Weak Black Liquor Storage Tank Vent

EU1 02d No. 2 Spill Tank

EU102e No. 2 Weak Black Liquor Storage Tank Vent

EU102h No. 3 Weak Black Liquor Storage Tank Vent

EU102i No. 4 Recovery Boiler Dust Tank EU102j No. 4 Recovery Boiler Mix Tank

EU102k No. 4 Weak Black Liquor Storage Tank

EU1 02l No. 5 Recovery Boiler Dust Tank

EU102m No. 5 Recovery Boiler Mix Tank

EU102n 40% Black Liquor Tank Vent (No. 2 Tank)

EU102o 65% Black Liquor Tank EU102p No. 1 40% Heavy Black Liquor Tank EU102q No. 2 40% Heavy Black Liquor Tank

EU102r No. 3 40% Heavy Black Liquor Tank

EU102s No. 3 65% Black Liquor Storage Tank

EU102t No. 4 65% Black Liquor Tank

EU109 Condensate Collection

EU109a No. 1 and N. 2 Evaporators (Foul Condensate)

EU109b No. 3 Evaporator (Combined Condensate)

EU109c No. 3 Evaporator (Foul Condensate)

EU109d No. 4 Evaporator (Condensate from Effect No. 2)

EU109e No. 4 Evaporator (Foul Condensate)

EU109f No. 2 Condensate/No. 5 Evaporator (Foul Condensate)OP2589

- 07 4 Date of Decision : 07/08/11

Effective Date: 08/09/11 Emission Unit

ID Description Pollution Control Device/Pra ctice

EU109g No. 1 Concentrator (Foul Condesate)

EU109h Turpentine Decanter

EU109i Batch Digester Blow Heat Recovery System (Condensate from

Accumulator Secondary Condenser) EU109j LVHC

- NCG Line Drains

EU109k Foul Condensate Tank

EU109l Black Li quor Spill Tank No. 1

EU110 Low Volume High Concentration (LVHC) Non

- Condensable

Gas (NCG) Either the Thermal Oxidizer or the #3

Lime Kiln

EU110a No. 1 and No. 2 Evaporators: Vacuum Vents

EU110b No. 3 Evaporator: Vacuum Vents

EU110c No. 4 Evapor ator: Vacuum Vents

EU110d No. 5 Evaporator: Vacuum Vents

EU110e No. 2 Concentrator: Hotwell and Vacuum System Vent

EU110f No. 1 Concentrator: Hotwell and Vacuum System Vent EU110g M&D Digester: Blow Heat System Vent

EU110h Turpentine Condenser Ve nt

EU110Ii No, 1 and No. 2 Evaporators after condenser hotwell vents EU110j No. 3 and No. 4 Evaporator Hotwell Vents

EU110k No. 2 Concentrator, No. 5 Evaporator Spiral Condenser Vent, and

Hotwell Vent

EU110l No.1 Black Liquor Spill Blow Tanks

EU1 10m No. 3 Blow Tank

EU110n No. 1 and No.2 Blow Tanks

EU110o Foul Condensate Tank EU110p No. 2 Evaporator Auxiliary Surface Condenser and After

Condensers Vents EU110q Spill Collection Tank

– Weak Black Liquor (Secondary)

EU119 Quick Lime/Dry Lime Handling

EU119a Hot Lime Tank No.3 Lime Kiln

EU119b Hot Lime Tank Vent No. 4 Lime Kiln

EU119c No. 1 Fresh Lime Bin

EU119d No. 2 Fresh Lime Bin

EU119e No. 3 Fresh Lime Tank Vent

EU127 Tall Oil Reactor None

EU127a Tall Oil Reactor

EU1 27b Tall Oil Reactor Scrubber Vent

EU131 White Liquor Handling None

EU131a No. 1 Recausticizer Tanks

EU131b No. 1 Weak Wash Tank Vent

EU131c No. 1 White Liquor Clarifier Tank

EU131d No. 1 White Liquor Storage Tank Vent

EU131e No. 2 Recaustic izer Tank Sets

EU131f No. 2 Weak Wash Tank Vent EU131g No .3 Recausticizer Tank Sets

EU131h No. 3 White Liquor Clarifier Vents

EU131i No. 4 White Liquor Clarifier Vents EU131j No. 3 White Liquor Storage Tank VentOP2589

- 07 5 Date of Decision : 07/08/11

Effective Date: 08/09/11 Emission Unit

ID Description Pollution Control Device/Practice

EU153 Thermal Oxidizer Caustic Wet Scrubber

EU153a Thermal Oxidizer Scrubber Stack

EU154 Steam Stripper

EU154a Steam Stripper Vent

EU154b Steam Stripper Feed Tank

EU154c Steam Stripper

- off gas

PAPER MILL DEPARTMENT

EU030 No. 1 Paper Machine Wet End None

EU030a No. 1 Machine Press Section Area Exhaust

EU030b No. 1 Machine Refiner Room Exhaust

EU030c No. 1 Machine Wet End Ceiling Exhaust

EU030d No. 1 Machine Wet End Room Exhaust

EU030e No. 1 Mach ine Vacuum Pump Sump Exhaust

EU030f No. 1 Machine Vac

- u

- foil Exhausters

EU031 No. 1 Paper Machine Dryer None

EU031a No. 1 Machine Dryer Hood Exhaust

EU032 No. 2 Paper Machine Wet End None

EU032a No. 2 Machine Wet End False Ceiling Roof Exha ust

EU032b No. 2 Machine Flat Box Separator Exhaust Fan

EU032c No. 2 Machine Vacuum Pump Sump Exhaust

EU033 No. 2 Paper Machine Dryer None

EU033a No. 2 Machine Dryer Hood Exhaust No. 1

EU033b No. 2 Machine Dryer Hood Exhaust No. 2

EU033c No. 2 Machine Dryer Hood Exhaust No. 3

EU033d No. 2 Machine Dryer Hood Exhaust No. 4

EU033e No. 2 Machine Dryer Hood Exhaust No. 5

EU033f No. 2 Machine Dryer Hood Exhaust No. 6 EU033g No. 2 Machine Dryer Hood Exhaust No. 7

EU034 No. 3 Paper Mach ine Wet End None

EU034a No. 3 Machine Press Section Area Roof Exhaust

EU034b No. 3 Machine Wet End False Ceiling Exhaust Fans

EU034c No. 3 Machine Broke Building Roof Fan

EU034d No. 3 Machine Refiner Room Exhaust

EU034e No. 3 Machine Vacuum Pump P it Exhaust

EU035 No. 3 Paper Machine Dryer None

EU035a No. 3 Machine Dry End Roof Exhaust

EU035b No. 3 Machine Dryer Hood Exhaust

– 1 st Section

EU035c No. 3 Machine Dryer Hood Exhaust

– 2 nd Section

EU035d No. 3 Machine Dryer Hood Exhaust

– 3 rd Section

EU035e No. 3 Machine Dryer Hood Exhaust

– 4 th Section

EU035f No. 3 Machine Dryer Hood Exhaust

– 5 th Section EU035g No. 3 Machine Dryer Hood Exhaust

– 6 th Section

EU035h No. 3 Machine Dryer Hood Exhaust

– 7 th Section

EU037 Starch Handling Baghouse

EU038 Clay Handling Baghouse

EU107 Chemical Storage TanksOP2589

- 07 6 Date of Decision : 07/08/11

Effective Date: 08/09/11 Emission Unit

ID Description Pollution Control Device/Practice

ENVIRONMENTAL AND TECHNICAL DEPARTMENT

EU130 Effluent Treatment System None

EU130a Recaust/Paper Mill Raw Post C onsumer Effluent Vent

EU130b Sludge Holding Tank

EU130c Sludge Press

EU130d Sludge Press Building Vent

EU130e Sludge Storage Ponds

EU130f Primary Clarifier EU130g Aeration Basin No. 1

EU130h Aeration Basin No. 2

EU130i Aeration Basin No. 3 EU130j Treated Effluent Ponds

EU130k Polishing Ponds

ENGINEERING AND MAINTENANCE DEPARTMENT

EU120 Roads, Unpaved Reasonable Precautions

EU111 Liquid Fuel Handling Reasonable Precautions

EU152 CFC RecyclingOP2589

- 07 7 Date of Decision : 07/08/11

Effective Date: 08/09/11 SECTION III. PERMIT CONDITIONS

- F ACILITY WIDE

The following requirements and conditions are applicable to the facility or to specific emission units located at the facility (ARM 17.8.1211, 1212, and 1213).

A. Facility

- Wide General

Conditions Rule Citation Rule Description Pollutant/Par ameter Limit

A.1 ARM 17.8.105 Testing Requirements Testing Requirements

------

A.2 ARM 17.8.304(1) Visible Air Contaminants Opacity 40%

A.3 ARM 17.8.304(2) Visible Air Contaminants Opacity 20%

A.4 ARM 17.8.308(1) Particulate Matter, Airborne Fugitive O pacity 20%

A.5 ARM 17.8.308(2) Particulate Matter, Airborne Reasonable Precautions

------- A.6 ARM 17.8.308 Particulate Matter, Airborne Reasonable Precaution, Construction 20%

A.7 ARM 17.8.309 Particulate Matter, Fuel Burning Equipment Particulate Matt er E = 0.882 * H - 0.1664

or E = 1.026 * H - 0.233

A.8 ARM 17.8.310 Particulate Matter,

Industrial Processes Particulate Matter E = 4.10 * P 0.67

or E = 55 * P 0.11

- 40

A.9 ARM 17.8.322(4) Sulfur Oxide Emissions,

Sulfur in Fuel Sulfur in Fuel (liquid or solid fuels) 1 lb/MMBtu fired

A.10 ARM 17.8.322(5) Sulfur Oxide Emissions,

Sulfur in Fuel Sulfur in Fuel (gaseous) 50 gr/100 CF

A.11 ARM 17.8.324(3) Hydrocarbon Emissions,

Petroleum Products Gasoline Storage Tanks

-------

A.12 ARM 17.8.324 Hydrocarbon Emissio ns, Petroleum Products 65,000

- Gallon Capacity

-------

A.13 ARM 17.8.324 Hydrocarbon Emissions,

Petroleum Products Oil

- effluent Water Separator

-------

A.1 4 ARM 17.8.342 NESHAPs General

Provisions SSM Plans Submittal

A.15 ARM 17.8.342 40 CFR 63, Subpart S National Emission Standards for

Hazardous Air Pollutants from the Pulp and Paper Industry -------

A.16 ARM 17.8.340 40 CFR 60, Subpart D Standards of Performance for Fossil

Fuel

- Fired Steam Generation for

Which Construction is Commenced After August 17 , 1971. -------

A.17 ARM 17.8.340 40 CFR 60, Subpart BB Standards of Performance for Kraft Pulp Mills -------

A.18 ARM 17.8.342 40 CFR 63 Subpart MM National Emission Standards for

Hazardous Air Pollutants for Chemical Recovery Combustion

Sources at Kra ft, Soda, S u lfite, and

Stand

- Alone Semichemical Pulp

Mills -------

A.19 ARM 17.8.749 CEM Data Recovery Boilers, Limes Kilns, &

Multi

- fuel Boiler -------

A.20 State of Montana

Air Quality Control Implementation

Plan Missoula County

Regulations Emergency Episode Action Plan

-------

A.21 ARM 17.8.1212 Reporting Requirements Compliance Monitoring

------- A.22 ARM 17.8.1207 Reporting Requirements Annual Certification

-------OP2589

- 07 8 Date of Decision : 07/08/11

Effective Date: 08/09/11 Conditions

A.1. Pursuant to ARM 17.8.105, any person or persons responsible for the e mission of any air contaminant into the outdoor atmosphere shall, upon written request of the Department, provide the facilities and necessary equipment (including instruments and sensing devices) and shall conduct test, emission or ambient, for such perio ds of time as may be necessary using methods approved by the Department.

Compliance demonstration frequencies that list “as required by the Department” refer to ARM 17.8.105. In addition, for such sources, compliance with limits and conditions listing “a s required by the Department” as the frequency, is verified annually using emission factors and engineering calculations by the Department’s compliance inspectors during the annual emission inventory review; in the case of Method 9 tests, compliance is mon itored during the regular inspection by the compliance inspector.

A.2. Pursuant to ARM 17.8.304(1), M2Green shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed on or before November 23, 1968, that exhibit an opacity of 40% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.

A.3. Pursuant to ARM 17.8.304(2), M2Green shall not cause or authorize emissions to be discharged into the outdoor atmosphere f rom any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.

A.4. Pursuant to ARM 17.8.308(1), M2Green shall not cause or authorize t he production, handling, transportation, or storage of any material unless reasonable precautions to control emissions of particulate matter are taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity o f 20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.

A.5. Pursuant to ARM 17.8.308(2), M2Green shall not cause or authorize the use of any street, road or parking lot without taking reasonable precaut ions to control emissions of airborne particulate matter, unless otherwise specified by rule or in this permit.

A.6. Pursuant to ARM 17.8.308, M2Green shall not operate a construction site or demolition project unless reasonable precautions are taken to c ontrol emissions of airborne particulate matter. Such emissions of airborne particulate matter from any station ary source shall not exhibit an opacity of 20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this

per mit.

A.7. Pursuant to ARM 17.8.309, unless otherwise specified by rule or in this permit, M2Green shall not cause or authorize particulate matter caused by the combustion of fuel to be discharged from any stack or chimney into the outdoor atmosphere in ex cess of the maximum allowable emissions of particulate matter for existing fuel burning equipment and new fuel burning equipment calculated using the following equations:

For existing fuel burning equipment (installed before November 23, 1968):

E = 0.882 * H
- 0.1664

For new fuel burning equipment (installed on or after November 23, 1968):

E = 1.026 * H
- 0.233

Where H is the heat input capacity in million BTU (MMBtu) per hour and E is the maximum allowable particulate emissions rate in pounds per MMBtu.OP2589

- 07 9 Date of Decision : 07/08/11

Effective Date: 08/09/11 A. 8. Pursuant to ARM 17.8.310, unless otherwise specified by rule or in this permit, M2Green shall not cause or authorize particulate matter to be discharged from any operation, process, or activity into the outdoor atmosphere in excess of the maximum hourly allowable emissions of particulate matter calculated using the following equations:

For process weight rates up to 30 tons per hour: E = 4.10 * P 0.67
For process weight rates in excess of 30 tons per hour: E = 55.0 * P 0.11

– 40

Where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per

hour.

A.9. Pursuant to ARM 17.8.322(4), M2Green shall not burn liquid or solid fuels containing sulfur in excess of 1 pound per million BTU fired, unless otherwise specified by rule or in this permit.

A.10. Pursuant to ARM 17.8.322(5), M2Green shall not burn any gaseous fuel containing sulfur compounds in excess of 50 grains per 100 cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard conditions, unless otherwise s pecified by rule or in this permit.

A.11. Pursuant to ARM 17.8.324(3), M2Green shall not load or permit the loading of gasoline into any stationary tank with a capacity of 250 gallons or more from any tank truck or trailer, except through a permanent subm erged fill pipe, unless such tank is equipped with a vapor loss control device or is a pressure tank as described in ARM 17.8.324(1), unless otherwise specified by rule or in this permit.

A.12. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, M2Green shall not place, store or hold in any stationary tank, reservoir or other container of more than 65,000

- gallon capacity any crude oil, gasoline or petroleum distillate having a vapor pressure of 2.5 pounds per square inch absolut e or greater under actual storage conditions, unless such tank, reservoir or other container is a pressure tank maintaining working pressure sufficient at all times to prevent hydrocarbon vapor or gas loss to the atmosphere, or is designed and equipped wit h a vapor loss control device, properly installed, in good working order and in operation.

A.13. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, M2Green shall not use any compartment of any single or multiple

- compartment oil

- effluent water separator, which compartment receives effluent water containing 200 gallons a day or more of any petroleum product from any equipment processing, refining, treating, storing or handling kerosene or other petroleum product of equal or gre ater volatility than kerosene, unless such compartment is equipped with a vapor loss control device, constructed so as to prevent emission of hydrocarbon vapors to the atmosphere, properly installed, in good working order and in operation.

A.14. Pursuant to ARM 17.8.342 and 40 CFR 63.6, M2Green shall submit to the Department a copy of any startup, shutdown, and malfunction (SSM) plan required under 40 CFR 63.6(e)(3) within 30 days of the effective date of this operating permit (if not previously submitted ), within 30 days of the compliance date of any new National Emission Standard for Hazardous Air Pollutants (NESHAPs) or Maximum Achievable Control Technology (MACT) standard, and within 30 days of the revision of any such SSM plan, when applicable. The D epartment requests submittal of such plans in electronic form, when possible.

A.15. Pursuant to ARM 17.8.342 and 40 CFR 63, Subpart S, M2Green shall comply with all applicable standards and limitations, and the reporting, recordkeeping, and notification r equirements as required by 40 CFR 63, Subpart S

– National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry. The requirements include, but are not limited to, the following:OP2589

- 07 10 Date of Decision : 07/08/11

Effective Date: 08/09/11 a. The pulping process condensates from the listed e quipment systems that in total contain a total Hazardous Air Pollutant (HAP) mass of 3.6 kilograms or more of total HAP (measured as methanol) per megagram (7.2 pounds per ton) of oven

- dried pulp ( ODP ) for mills that do not perform bleaching (40 CFR 63.446 (c)(3) )

.

b. Treat the pulping process condensates to remove methanol by recycling collected condensates specified in Section V. H (EU109) to systems , including the evaporator system, equipped with vent control or by removal in the steam stripper of at least 9 2 percent (by weight) of methanol per oven

- dried ton pulp criteria (40 CFR 63.446(e)(3)).

c. Reduce total HAP emissions using a thermal oxidizer designed and operated at a minimum temperature of 871°C (1600°F) and a minimum residence time of 0.75 seconds (4 0 CFR 63.443(d)(3)).

d. Monitor the specified units in accordance with §63.453(k) and (n).

e. Maintain and operate in accordance to the SSM Plan.

f. Comply with the requirements of §63.8 including the requirements for a Quality Control

Plan.

A.16. Pursuant to A RM 17.8.340 and 40 CFR 60, Subpart D, M2Green shall comply with all applicable standards and limitations, and the reporting, recordkeeping, and notification requirements as required by 40 CFR 60, Subpart D

- Standards of Performance for Fossil

- Fuel

- Fired Ste am Generation for Which Construction is Commenced After August 17, 1971.

A.17. Pursuant to ARM 17.8.340 and 40 CFR 60, Subpart BB, M2Green shall comply with all applicable standards and limitations, and the reporting, recordkeeping, and notification requi rements as required by 40 CFR 60, Subpart BB

- Standards of Performance for Kraft Pulp

Mills.

A.18

. Pursuant to ARM 17.8.342 and 40 CFR 63, Subpart MM, M2Green shall comply with all applicable standards and limitations, and the reporting, recordkeeping, and notification requirements as required by 40 CFR 63, Subpart MM

- National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and

Stand

- Alone Semichemical Pulp Mills.

A.19. Failure to report CEM data required by Section V.A, B, E and G , which is not available because of monitor downtime or insufficient quality assurance, shall not be considered a violation of the reporting requirements of this section. However, the unavailability of such data ma y be violation of the monitoring requirements of Section V.A, B, E and G (ARM 17.8.749).

A.20. M2Green shall comply with the requirements contained in Chapter 4 of the Missoula City

- County Air Pollution Control Program (Chapter 32 of the State of Montana Air Quality Control Implementation Plan) with regards to emergency episodes.

A.21. On or before February 15 and August 15 of each year, M2Green shall submit to the Department the compliance monitoring reports required by Section VIII.D. These reports mu st contain all information required by Section VIII.D, as well as the information required by each individual emission unit. For the reports due by February 15 of each year, M2Green may submit a single report, provided that it contains all the information required by Section VIII.B & VIII.D. Per
ARM 17.8.1207,OP2589

- 07 11 Date of Decision : 07/08/11

Effective Date: 08/09/11 any application form, report, or compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including semiannual monitoring reports), shall contain certification by a

re sponsible official of truth, accuracy and completeness. This certification and any other certification required under ARM Title 17, Chapter 8, Subchapter 12, shall state that, “based on information and belief formed after reasonable inquiry, the statement s and information in the document are true, accurate and complete.”

A.22. By February 15 of each year, M2Green shall submit to the Department the compliance certification report required by Section VIII.B. The annual certification report required by Sect ion VIII.B must include a statement of compliance based on the information available that identifies any observed, documented or otherwise known instance of noncompliance for each applicable requirement. Per ARM 17.8.1207,

any application form, report, o r compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including annual certifications), shall contain certification by a responsible official of truth, accuracy and completeness. This certification and any other certific ation required under ARM Title 17, Chapter 8, Subchapter 12, shall state that, “based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete.”OP2589

- 07 12 Date of Decision : 07/08/11

Effective Date: 08/09/11 B



### . Mill

- Wide Permit Conditio ns

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

B.1, B.4, B.7, B.9, B.11, B.12, B.13 SO 2 Facility Wide 5,000 lb/day Calculate SO 2 Source Emission Daily Monthly

B.2, B.5, B.8,

B.1 1, B.12,

B.13 Wood Pulp

Production Facility

Wide 535,000 ODT per

rolling 12

- month period Calculate wood

pulp production Daily Monthly

B.3, B.6, B.10, B.12,

B.13 H 2 S Ambient Air Monitoring (State

- Only) Appendix F Appendix F Appendix F

Conditions

B.1. Total sulfur dioxide (SO 2 ) emissions from the mill shall not exceed 5,000 lb/day (ARM 17.8.1201(10)).

B.2 Total wood pulp production shall not exceed 535,000 oven

- dry tons (ODT) per rolling 12

- month period (ARM 17.8.749).

B.3. M2Green shall conduct an ambient air monitoring program consisting of the following in accordance with Appendix F of this permit ( ARM 17.8.204

, State

- O nly Requirement).

a. At least two analyzers to measure hydrogen sulfide (H 2 S).

b

. At least one wind system.

c

. Sampling sites, d ata reporting, and parameters to be monitored will be specified by the Department

.

Compliance Demonstration

B. 4

. M2Green shall calculate the daily SO 2 emissions from the mill in pounds per day to monitor compliance with Section III.B.1 (ARM 17.8.1213).

B.5

. M2Green shall calculate the total wood pulp production based on a mill day using the following methodology (equations a

- c) to monitor compliance with Section III.B.2 (ARM 17.8.749) :

a. Fiber usage on machines (tons, as produced) = Paper machine prod uction (tons, as produced) +/

- change in Cull production inventory (tons, as produced)

b. Fiber usage on machines (oven

- dry tons) = Fiber usage on machines (tons, as produced) x (1.0

– moisture content of paper

– chemical additive content of the linerboar d)

c. Wood pulp production (ODT) = Fiber usage on machines (ODT)

– OCC usage on machines (ODT) +/

- Wood pulp high density storage change (ODT).

B. 6

. M2Green shall operate and maintain the ambient air monitoring program in accordance with Appendix F of th is permit to monitor compliance with Section III.B. 3 ( ARM 17.8.204

, State

O nly Requirement )

.OP2589

- 07 13 Date of Decision : 07/08/11

Effective Date: 08/09/11 Recordkeeping

B. 7

. M2Green shall maintain, on site, the record of the daily SO 2 emissions (in pounds per day) from the facility (ARM 17.8.1212)

.

B.8

. M2Green sh all maintain, on site, the record of the daily wood pulp production from the facility (ARM 17.8.1212)

.

B. 9

. In the event of a total natural gas curtailment, M2Green shall report, in addition to the reports required by in this permit, the following (ARM 17 .8.1201(10)):

a. Daily SO 2 emissions from recovery boilers and power boilers.

b. Dates and times of curtailment.

c. Quantity and sulfur content of fuel oil burned.

d. All fuel oil burned must comply with ARM 17.8.322

– Sulfur In Fuel Oil rule, unless

su lfur dioxide emissions are controlled on an equivalent basis.

B. 10

. M2Green shall maintain records in accordance with Appendix F of this permit ( ARM 17.8.204

, State

- O nly Requirement )

.

Reporting

B. 11

. M2Green shall submit a monthly report to the Departme nt within 30 days following the end of the

month . The report shall include (ARM 17.8.1212) :

a. The average daily pulp production in air

- dried tons of pulp per day and oven

- dry tons of pulp per day ; and

b. The highest daily SO 2 emissions value for the mo nth.

B. 12

. The semiannual monitoring report shall contain the monthly total pulp production and the highest

12

- month rolling total pulp production and the highest daily total mill

- wide SO 2 emissions during the period, with all instances of deviations fro m any permit requirements identified (ARM 17.8.1212).

B.1 3

. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 14 Date of Decision : 07/08/11

Effective Date: 08/09/11 SECTION IV. PERMIT CONDITION S

- PULP, CHIP DOCK AND RECYCLED FIBER DEPARTMENT

A. Sawdust Handling, Chip Handling, Bio

- Mass Conveying, Hog Fuel Handling

EU004

– Sawdust Handling EU129

– Bio

- Mass Conveying

EU004a

– Sawdust Fines to Hog Fuel (& chip screening fines)

EU004b

– Sawdust Re ceipts EU129a

– Bio

- Mass Conveyor & Pile

EU005

– Chip Handling EU129b

– Bio

- Mass Conveyor to Hog Fuel Boiler

EU005a

– Chip Production EU134f

– Bio Mass Storage Pile EU005b

– Chip Receipts EU134g

– Hog Fuel Storage and Handling Emissions EU005c

– Chip Fines to Hog Fuel (& sawdust fines)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

A.1, A.13, A.14, A.20,

A.2 3 , A. 24

, A. 25 Opacity 20% Method 9 As Required by the Department

a nd Section

III.A.1 Semi

- annual

No. 1, 2, and 3 Truck Dump Usage Ongoing Semi

- annual

A.2, A.15,

A.2 0 , A

. 24

, A. 25 Sawdust Conveyors Control Fugitives Hood & Skirt w/ Max Drop Height of 10 ft Ongoing Semi

- annual

A.3, A.16, A.17, A. 22

, A. 23 , A. 24

, A. 25 S awdust Handled

PM

PM 10 (w/ 25% control)

0.75 lb/ton

0.27 lb/ton Calculations w/

Established Equations As Required

by the Department

and Section

III.A.1 Semi

- annual

Method 9 Quarterly Semi

- annual
A.4, A.17,

A. 23 , A. 24

, A. 25 Chips Handled

PM

PM 10 0.18 lb/ton

0.065 lb/ton
A.5, A.17,

A. 23 , A. 24

, A. 25 Hog Fuel Handled

PM

PM 10 1.0 lb/ton

0.36 lb/ton
A.6, A.17,

A. 23 , A. 24

, A. 25 Fines

– Chip Screen Handled

PM

PM 10 0.27 lb/ton

0.09 lb/ton
A.7, A.17,

A. 23 , A. 24

, A. 25 Fines

– Sawdust Screen Handle d

PM

PM 10 0.75 lb/ton

0.27 lb/ton
A.8, A.17,

A. 23 , A. 24

, A. 25 Screened Chips to Kamyr Pile

PM

PM 10 0.045 lb/ton

0.001 lb/ton
A.9, A.17,

A. 23 , A. 24

, A. 25 Screened Chips to Batch Pile

PM

PM 10 0.045 lb/ton

0.001 lb/ton

A.10, A.17,

A. 23 , A. 24

, A. 25 Screened Sawdust Overs to Chip Pile

PM

PM 10 0.09 lb/ton

0.005 lb/ton
A.11, A.18,

A.2 1 , A.2 4

, A.2 5 Chip Screen & Sawdust Screen

Fines to Hog Fuel Pile Operation of Target Plate and

Bunker to Control Fugitives Recordkeeping As Necessary Semi

- annua l

A.12, A.19, A.20, A.2 4

, A.2 5 Quantity of Sawdust Overs Weightometer on

Sawdust Overs Belt Maintain & Operate Operate During Belt Operations Semi

- annualOP2589

- 07 15 Date of Decision : 07/08/11

Effective Date: 08/09/11 Conditions

A.1. M2Green shall not cause or authorize emissions from the chip and sawdust handling, truck dumping, storage bin and the storage bin unloading system to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304 and ARM 17.8.308).

A.2. The sawdust conveyor(s) shal l be controlled by a hood and skirt at the end of the conveyor to limit the free drop height (the distance from the bottom of the skirt to the sawdust pile) to a maximum of 10 feet (ARM 17.8.1201(10)).

A.3. M2Green shall be limited to 0.75 lb/ton of sawd ust handled for total particulate and 0.27 lb/ton of

sawdust handled for PM 10 (SCC #3

- 07

- 008

- 03) with hood and skirt controls at 25% (ARM 17.8.1201(10)).

a. The total sawdust pile emissions shall be calculated as: TSP (total tons) = {(Qty Sawdust

overs )*(0.18*[1

- 0.25])/2000+(Qty Sawdust receipts

- Qty Sawdust overs)*(1.0*[1

- 0.25])/2000}.

b. The total sawdust pile emissions shall be calculated as: PM 10 (total tons) = {(Qty Sawdust overs)*(0.065*[1

- 0.25])/2000+(Qty Sawdust receipts

- Qty Sawdust overs)*(0.3 6*[1

- 0.25])/2000}.

c. M2Green shall ensure that the 10

- foot maximum distance is met at all times. When the material under the belt is reclaimed, M2Green shall shut down the conveyor, remove the material, and fill in the void with new material before rest arting the conveyor to ensure

the 10

- foot maximum distance is met.

A.4. M2Green shall be limited to 0.18 lb/ton of chips handled for total particulate and 0.065 lb/ton of chips handled for PM 10 (State emission estimate) (ARM 17.8.1201(10)).

A.5. M2Green shall be limited to 1.0 lb/ton of hog fuel handled for total particulate and 0.36 lb/ton of hog fuel handled for PM 10 (SCC #3

- 07

- 008

- 03) (ARM 17.8.1201(10)).

A.6. M2Green shall be limited to 0.27 lb/ton (controlled) of fines sent to hog fuel from chip sc reen handled for total particulate and 0.09 lb/ton (controlled) of fines sent to hog fuel from chip screen

handled for PM 10 ( M2Green emission estimate) (ARM 17.8.1201(10)).

A.7. M2Green shall be limited to 0.75 lb/ton (controlled) of fines sent to hog fue l from sawdust screen handled for total particulate and 0.27 lb/ton (controlled) of fines sent to hog fuel from sawdust

screen handled for PM 10 ( M2Green emission estimate) (ARM 17.8.1201(10)).

A.8. M2Green shall be limited to 0.045 lb/ton of screened chip s to Kamyr pile handled for total particulate and 0.001 lb/ton of screened chips to Kamyr pile handled for PM 10 ( M2Green emission estimate) (ARM 17.8.1201(10)).

A.9. M2Green shall be limited to 0.045 lb/ton of screened chips to batch pile handled for tota l particulate and 0.001 lb/ton of screened chips to batch pile handled for PM 10 ( M2Green emission estimate) (ARM 17.8.1201(10)).

A.10. M2Green shall be limited to 0.09 lb/ton of screened sawdust overs to chip pile handled for total particulate and 0.005 l b/ton of screened sawdust overs to chip pile handled for PM 10 ( M2Green emission estimate) (ARM 17.8.1201(10)).OP2589

- 07 16 Date of Decision : 07/08/11

Effective Date: 08/09/11 A.11. Emissions from the fines from the chip screen and sawdust screen being sent by the pneumatic conveying system to the hog fuel pile shall be controlled by a target plate and bunker at the end of the discharge pile (ARM 17.8.1201(10)).

A.12. M2Green shall maintain a weightometer on the sawdust overs belt to be used to determine the quantity of sawdust overs handled (ARM 17.8.1201(10)).

Compl iance Demonstration

A.13. As required by the Department and Section III.A.1, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual to monitor compliance with Section IV.A.1. Each observation perio d shall be a minimum of 6 minutes unless any one reading is 20% or greater; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

A.14. Monitoring compliance with the opacity requirements contained in Section IV.A.1 for truck dumping includes maintaining the proper use of dump areas (ARM 17.8.1201(10))

.

a. The #1 Dump is used to unload trucks only and uses a belt system to convey chips and sawdust to the stockpiles.

b. The #2 Dump is used to unload trucks only and uses a conveyor belt to convey chips to the stockpiles.

c. The #3 Dump is a combination truck or rail dump that conveys chips and sawdust using a belt system to the stockpiles.

A.15. A mechanism to allow for an inspector to measure the drop height must be provided at all times when sawdust is being processed to demonstrate compliance with Section IV.A.2 ( ARM 17.8.749

and ARM 17.8.1201(10) )

.

A.16. M2Green sha ll use the equations contained in Section IV.A.3.a and b to monitor compliance with the limitations in Section IV.A.3 at any time ( ARM 17.8.749 and ARM 17.8.1213)

.

A.17. Quarterly, M2Green shall perform Method 9 testing in accordance with the Montana Sour ce Test Protocol and Procedures Manual to monitor compliance with Section IV.A.3 through IV.A.10

. Each observation period shall be a minimum of 6 minutes unless any one reading is 20% or greater; then the observation period shall be a minimum of 20 minute s or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM

17.8.1213 ).

A.18. M2Green shall document any modifications to the target plate and bunker at the end of the discharge pile that have been used as emissions control to monitor compliance with Section

IV.A.11 (ARM 17.8.1213)

.

A.19. M2Green shall use a weightometer on the sawdust overs belt, when the belt is operating, to determine the quantity of sawdust overs handled to monitor complian ce with Section IV.A.12 (ARM 17.8.1213).OP2589

- 07 17 Date of Decision : 07/08/11

Effective Date: 08/09/11 Recordkeeping

A.20. M2Green shall maintain records on site documenting all instances when the requirements of Sections IV.A.14, A.15, and A.19 are not met . These records shall be submitted to the Department up on request (ARM 17.8.1212).

A.21

. M2Green shall maintain the records required by Section IV.A.18 on site and submit the information to the Department upon request (ARM 17.8.1212).

A.2 2

. M2Green shall maintain, on site, records of the quantity of sawdus t overs and sawdust receipts and submit calculations to the Department upon request (ARM 17.8.1212)

.

A.2 3

. All source test recordkeeping shall be performed in accordance with the test method used, and

shall be maintained on site. The reports must be subm itted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual ( ARM 17.8.106 and ARM 17.8.1212).

Reporting

A.2 4

. The semiannual monitoring report shall provide a summary of results of the last source testing that was pe rformed (ARM 17.8.1212):

A.2 5

. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 18 Date of Decision : 07/08/11

Effective Date: 08/09/11 B. Washing

EU026

- Washing Base Stock (Brown Stock) Washing CB Washing (M&D Washing)

EU026a

– No. 3 Base Stock Washer Feed Tank EU026f

– CB Washer Filtrate Tank

EU026b

– Base Stock Washer Walkway Exhaust EU026g

– CB Washers (M&D System)

EU026c

– No. 1 Base Stock Filtrate Tank EU026 h

– M&D Foam Tower

EU026d

– N o.2 Base Stock Filtrate Tank

EU026e

– Spill Collection Tank

– Base Washers

PC Washing Top Stock Washing

EU026i

– Foam Vent Tanks EU026n

- Base Stock Reject Tank EU026j

– Intermediate Foam Tower EU026o

– Top Stock Foam Tower Tank and

Filtrate Tank

EU026k

– PC Washer Vent EU026p

– Top Stock Reject Tank

EU026l

– PC Washer Stack I EU026q

– Top Stock Washer Hood Exhaust

EU026m

– PC Washer Stack II

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Repo rting Requirements

B.1, B.3, B.5, B.6,

B.7 Particulate emissions from #1

Base Washer, #2 Base Washer, and the Top Washer Control by

internal washer hood design Recordkeeping Monthly Semi

- annual

B.2, B.4, B.5, B.6,

B.7 HAP emissions from brown

stock wash ers, filtrate tanks, and

foam tower Collect & route

to Thermal

Oxidizer Verify vacuum is

maintained, pressure does not exceed set pressure points, and Booster

Fan vent valve is

closed Ongoing Semi

- annual (in MACT I

Excess

Emissions

and

Continuous

Monitorin g System

Performance and Summary Report)

Conditions

B.1. Particulate emissions from the #1 Base Washer, #2 Base Washer, and the Top Washer shall be controlled by internal washer hood design (ARM 17.8.1201(10)).

B.2. HAP e missions from the brown stock w ashers , filtrate tanks, and foam tower shall be collected with a closed vent system and routed to the existing Thermal Oxidizer (ARM 17.8.342 and 40 CFR 63, Subpart S).

Compliance Demonstration

B.3. M2Green shall monitor compliance with Section IV.B.1 by documenting any maintenance or repair activities affecting washer hood design and particulate removal capability

. The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.1213).OP2589

- 07 19 Date of Decision : 07/08/11

Effective Date: 08/09/11 B.4

. M2Green shall verify compliance with Section IV.B.2 by monitoring the following on a 15

- minute basis during operation of the washers to verify proper operation of the HAP collection

system (ARM 17.8.1213) :

a. Verify washer hood pressure does not exceed the Department

- approved pre

- determined venting setpoint ;

b. Verify filtrate tank and foam tower pressure does not exceed the Department

- approved

pre

- determined venting setpoint ; and

c. Verify the HVLC

- NCG Booster Fan vent valve is closed.

Recordkeeping

B.5. M2Green shall maintain, on site, records of the monitoring required in Sections IV.B.3 and B.4

above (ARM 17.8.1212)

.

Reporting

B.6. The semiannual monitoring report shall provide a summary of any maintenance or repair activities affecting washer h ood design and particulate removal (ARM 17.8.1212).

B.7. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 20 Date of Decision : 07/08/11

Effective Date: 08/09/11 C. Cyclones

EU132

- Cyclones

EU132a

– M&D Sawdust Cyclone

EU132b

– No. 1 ADS Cyclone

EU132c

– No. 2 ADS Cyclone

EU132d

– No. 3 ADS Cyclone

EU132e

– No. 4 ADS Cyclone EU132g

– Sawdust Overs Cyclone

EU132h

– Unscreened Sawdust Cyclone

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

C.1, C.9, C.12, C.14,

C.15 Opacity

M&D Sawdust Cyclone, No. 1 ADS Cyclone, No. 2 ADS Cyclone, No. 3 ADS Cyclone, No. 4 ADS Cyclone, Sawdust Overs Cyclone, Unscreened Sawdust Cyclone 20% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

C.2, C.10, C.12, C.14,

C.15 M&D Cyclone

TSP 60 lb/day

2.5 lb/hr 40 CFR 60, App. A

40 CFR 51, App.M As Required by the Department

and Section

III.A.1 Semi

- annual

C.3, C.10, C.12, C.14,

C.15 M&D Cyclone

PM 10 24 lb/day

1.0 lb/hr

C.4, C.10, C.12, C.14,

C.15 ADS Slicers and Cyclones

TSP 26.4 lb/day

1.10 lb/hr

C.5, C.10, C.12, C.14,

C.15 ADS Slicers and Cyclones

PM 10 26.4 lb/day

1.1 lb/hr

C.6, C.10, C.12, C.14,

C.15 Sawdust Overs Cyc lone

TSP 26.4 lb/day

1.1 lb/hr

C.7, C.10, C.12, C.14,

C.15 Sawdust Overs Cyclone

PM 10 26.4 lb/day

1.1 lb/hr

C.8, C.11, C.13, C.14,

C.15 All Cyclones Each Limited to 8,544 hr During Any 12

- Month Rolling Period Maintain a Log Monthly

Calculations Se mi

- annual

Conditions

C.1. M2Green shall not cause or authorize emissions to be discharged into the outdoor atmosphere from the M&D Sawdust Cyclone, No. 1 ADS Cyclone, No. 2 ADS Cyclone, No. 3 ADS Cyclone, No. 4 ADS Cyclone, Sawdust Overs Cyclone and the Unscreened Sawdust Cyclone that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

C.2. Total suspended particulate emissions from the M&D Cyclone shall be limited to 60 pounds per day ( lb/day ) and 2.5 pounds per hour ( lb/hr ) (ARM 17.8.1201(10)).

C.3. PM 10 emissions from the M&D Cyclone shall be limited to 24 lb/day and 1.0 lb/hr (ARM 17.8.1201(10)).OP2589

- 07 21 Date of Decision : 07/08/11

Effective Date: 08/09/11 C.4. Total suspended particulate emissions from the ADS Slicers and Cyclones shall not exceed 26.4 lb/day and 1.10 lb/hr for each cyclone (ARM 17.8.1201(10)).

C.5. PM 10 emissions from the ADS Slicers and Cyclones shall not exceed 26.4 lb/day and 1.1 lb/hr for each cyclone (ARM 17.8.1201(10)).

C.6. Total suspended particulate emissions from the Sawdust Overs Cyclone shall not exceed 26.4 lb/day and 1.1 lb/hr for each cyclone (ARM 17.8.1201(10)).

C.7. PM 10 emissions from the Sawdust Overs Cyclone shall not exceed 26.4 lb/day and 1.1 lb/hr for each cyclone (ARM 17.8.1201(10)).

C.8. The M&D Cyclone, ADS Slicers and Cyc lones, and the Sawdust Overs Cyclone shall each not be operated more than 8,544 hours during any 12

- month rolling period (ARM 17.8.1201(10)).

Compliance Demonstration

C.9. As required by the Department and Section III.A.1, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual to monitor compliance with Section IV.C.1. Each observation period shall be a minimum of 6 minutes unless any one reading is 20% or greater; then the observation period shal l be a minimum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

C.10. As required by the Department and Section III.A.1, monitoring compliance with Section IV. C.2 through C.7 above shall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix A. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may be used as a surrogate for PM 10 if the im pinger analysis ("back

half") is included (ARM 17.8.105 and ARM 17.8.1213)

.

C.11. M2Green shall document, by month, the total hours of operation of each of the cyclones and slicers listed in Section IV.C.8. By the 25 th day of each month, M2Green shall to tal the hours of operation of the cyclones and slicers for the previous month. The monthly information will be used to verify compliance with the rolling 12

- month limitation in Section IV.C.8 (ARM 17.8.1213)

.

Recordkeeping

C.12. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual ( ARM 17.8.106 and

ARM 17.8.1212).

C.13. The log of operational hours as required by Section IV.C.8 shall be maintained on site and submitted to the Department upon request (ARM 17.8.1212)

.

Reporting

C.14. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed; and

b. A summary of the log of operational hours.

C.15. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applica ble requirements (ARM 17.8.1212).OP2589

- 07 22 Date of Decision : 07/08/11

Effective Date: 08/09/11 D. Micro

- Pulsaire Baghouse

EU133

– Micro

- Pulsaire Baghouse

– Chip Thickness Baghouse

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

D.1, D.4,
D.6, D.7,

D.8 Opacity 20% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

D.2, D.3, D.5, D.6, D.7, D.8 Baghouse TSP

& PM 10 22.8 lb/day

0.95 lb/hr 40 CFR 60 App. A

40 CFR 51 App.M Annually Semi

- annual

Conditions

D.1. M2Green shall not cau se or authorize emissions to be discharged into the outdoor atmosphere

from the Micro

- Pulsaire Baghouse that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

D.2. Total suspended particulate emissions from this b aghouse shall be limited to 22.8 lb/day and 0.95 lb/hr (ARM 17.8.1201(10)).

D.3. PM 10 emissions from this baghouse shall be limited to 22.8 lb/day and 0.95 lb/hr (ARM 17.8.1201(10)).

Compliance Demonstration

D.4. As required by the Department and Sect ion III.A.1, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual to monitor compliance with Section IV.D.1. Each observation period shall be a minimum of 6 minutes unless any one reading is 20% o r greater; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

D.5. Annually, monitoring compliance with Section IV .D.2 and 3 shall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix A. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may be used as a surrogate

for PM 10 if the impinger anal ysis ("back

- half") is included (ARM 17.8.1213).

Recordkeeping

D.6. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in

a ccordance with the Montana Source Test Protocol and Procedures Manual ( ARM 17.8.106 and ARM 17.8.1212).

Reporting

D.7. The semiannual reporting shall provide a summary of results of the last source testing that was performed (ARM 17.8.1212).

D.8. The an nual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 23 Date of Decision : 07/08/11

Effective Date: 08/09/11 E. Storage Piles

EU134

– Storage Piles

EU134a

– Chip Pile Management Raw Chips

EU134c

– Sawdust Han dling & Storage Emissions

EU134d

– Screened Batch Chip Pile

EU134e

– Screened Kamyr Chip Pile

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

E.1, E .2, E.3, E.4, E.5 Opacity 20% Method 9 As Required by the Department and Section III.A.1 Semi

- annual

Conditions

E.1. M2Green shall not cause or authorize the production, handling, transportation, or storage of any material unless reasonable precautions to control emissions of particulate matter are taken. Such emissions of airborne particulate matter from EU134(a

- e) Storage Piles shall not exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.308(1)).

Compliance Demonstrati on

E.2. As required by the Department and Section III.A.1, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 minutes unless any one reading is 20% or greater; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

Recordkeeping

E.3. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual ( ARM 17.8.106 and

ARM 17.8 .1212)

.

Reporting

E.4. The semiannual monitoring report shall provide a summary of results of the last source testing that was performed (ARM 17.8.1212).

E.5. The annual compliance certification report required by Section VIII.B must contain a certifica tion statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 24 Date of Decision : 07/08/11

Effective Date: 08/09/11 SECTION V. PERMIT CONDITIONS

- POWER, RECOVERY, AND RECAUSTICIZING

DEPARTMENT

A. No. 4 Recovery Boiler

EU002

– No. 4 Recovery Boiler

Condition(s) Pollutant/Parameter Permit Limit Com pliance Demonstration Method Frequency Reporting Requirements

A.1, A.13,

A.24 , A.3 3

, A.3 6 Black Liquor Firing

Rate Daily Rate Maintain Log Daily Monthly

A.2, A.14, A.25, A.35,

A36 TSP 0.044 gr/dscf

corrected to 8% O 2 and 1,253 lb/day

52.21 lb/hr 40 CFR Part 60,

Appendix A Annually,

Semi

- annual

if above

80% of permit limit Semi

- annual

A.3, A.14,

A.25 , A.3 5

, A.3 6 PM 10 1,253 lb/day

52.21 lb/hr 40 CFR Part 51,

Appendix M Annually

,

Semi

- annual

if above

80% of permit limit Semi

- annual

A.4, A.14,

A. 2 5 , A.3 5

, A.3 6 Total Sulfate 1,253 lb/day

52.21 lb/hr 40 CFR Part 60,

Appendix A Annually Semi

- annual

A.5, A. 15

, A. 16 , A.25, A.33, A.35,

A.36 Total Reduced Sulfur ≤ 5 ppm,

24

- hr Average 40 CFR Part 60, Appendix A Every Two

Years Monthly

CEM 24

- hr Avg

A.6, A.1 6

, A.2 7 , A.3 5

, A.3 6 Total Reduced Sulfur CEM Operate and Maintain Ongoing Semi

- annual

A.7, A.1 7

, A.1 8

, A.26,

A.2 8 , A.3 3

, A.3 6 TSP 928 lb/Day

– Monthly Average COM Data &

Correlation Equations Monthly Monthly

A.8, A.1 9

, A.2 9 , A.3 5

, A.3 6 Correl ation Equations Proposed Changes Request Department Approval As

Necessary Semi

- annual

A.9, A. 18

, A. 20

, A.26,

A.3 4 , A.3 6 Opacity 20% COM Ongoing Monthly

A.10, A.2 1

, A. 30 , A.3 4

, A.35, A.3 6 Opacity COM Operate and Maintain Ongoing Semi

- annual
EER Report s As

Necessary Quarterly

A.11, A.2 2

, A. 3 1 , A.3 5

, A.3 6 Particulate Emissions Operate and Maintain

ESP Recordkeeping As Necessary Semi

- annual

A.12, A.2 3

, A.3 2 , A.3 5

, A.3 6 CAM Plan CAM Plan Appendix

E CAM Plan Appendix

E Ongoing Semi

- annual

Conditions

A. 1. M2Green shall report, monthly, the daily black liquor firing rate for the No. 4 Recovery Boiler (ARM 17.8. 749 ).OP2589

- 07 25 Date of Decision : 07/08/11

Effective Date: 08/09/11 A.2. Total suspended particulate emissions from the No. 4 Recovery Boiler shall not exceed 0.044 grains per dry standard cubic foot ( gr/dsc f ) corrected to 8% Oxygen ( O 2 ) concentration (ARM 17.8.342 and 40 CFR 63, Subpart MM) and in no case shall exceed 1

, 253 lb/day and 52.21 lb/hr (ARM 17.8.1201(10)).

A.3. PM 10 emissions from the No. 4 Recovery Boiler shall not exceed 1,253 lb/day and 52 .21 lb/hr (ARM 17.8.1201(10)).

A.4. Total sulfate emissions from the No. 4 Recovery Boiler shall not exceed 1,253 lb/day and 52.21 lb/hr (ARM 17.8.1201(10)).

A.5. Total reduced sulfur (TRS) emissions from the No. 4 Recovery Boiler shall not exceed 5 parts pe r million ( ppm ) , 24

- hour average (ARM 17.8.1201(10)).

A.6. A continuous emission monitor for TRS compounds is required by state permit for this source ( ARM 17.8.749 and ARM 17.8.1201(10)).

A.7. The monthly average total suspended particulate for the No . 4 Recovery Boiler shall not exceed 928 lb/day ( ARM 17.8.749 and ARM 17.8.1201(10)).

A.8. M2Green shall submit for approval to the Department any proposed changes to the correlation equations used to determine particulate mass emissions (ARM 17.8.1201(10 )).

A.9. M2Green shall not discharge into the outdoor atmosphere emissions from the No. 4 Recovery Boiler that exhibit 20% opacity or greater averaged over 6 consecutive minutes for more than 6%

of the 6

- minute time periods during which the No. 4 Recovery Boiler is operating within a calendar quarter (ARM 17.8.321).

A.10. Continuous Opacity Monitoring System ( COM S ) shall be operated and maintained on the No. 4

Recov ery Boiler (ARM 17.8.1201(10)).

A.11. M2Green shall operate and maintain an electrostatic precipitator ( ESP ) on the No. 4 Reco very Boiler (ARM17.8.1201(10)).

A.12. M2Green shall provide a reasonable assurance of compliance with the emission limitations or standards for the operation of the emitting unit by following the Compliance Assurance

Mo nitoring (CAM) plan contained in Appendix E of this permit (ARM 17.8.1504).

Compliance Demonstration

A.13. M2Green shall maintain a record of the daily black liquor firing rate for the No. 4 Recovery Boiler to monitor compliance with Section V.A.1 (ARM 1 7.8.1213)

.

A.14. Annually, monitoring compliance with the Section V.A.2 through A. 4 standards shall be determined by EPA source sampling methods specified in 40 CFR Part 60, Appendix A, including back

- half particulate. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may be used as a surrogate for PM 10 if the impinger analysis ("back

- half") is included. M2Green shall test the No. 4 Recovery Boiler for total particulate and PM 10 at 90% or greater of maximum rat ed capacity to monitor compliance with

Section V.A.2 and V.A.3 (ARM 17.8.1213)

.OP2589

- 07 26 Date of Decision : 07/08/11

Effective Date: 08/09/11 If the results from the annual testing are at 80% of the permit limitation or greater, then testing

shall occur on a semi

- annual basis. After M2Green tests’ results are be low 80% of the permit limitations, then M2Green may return to annual testing no later than 1 year from the last test date ( ARM 17.8.749 and ARM 17.8.1213)

.

A.15. M onitoring compliance with the Section V.A.5 shall be determined by EPA source sampling

metho ds specified in 40 CFR Part 60, Appendix A . This testing and compliance demonstration shall take place every two years or on another testing/monitoring schedule as may be a pproved by the Department (ARM 17.8.1213)

.

A.1 6

. The TRS CEM is not required to co nform to federal specifications. The monitor shall be of a type and installation approved by the Department, to monitor compliance with Section V.A.5 and

A.6 ( ARM 17.8.749 and ARM 17.8.1213)

.

A.1 7

. Monthly emissions shall be determined by continuous opac ity monitoring and the correlation equations to monitor compliance with Section V.A.7 (ARM 17.8.1213).

A.18. The COMS shall be installed, calibrated, and maintained in accordance with 40 CFR §63.864 to monitor compliance with the requirements of Section V .A.7 and V.A.9 (ARM 17.8.342 and 40 CFR 63, Subpart MM).

A.1 9

. M2Green shall notify the Department of any proposed changes to the correlation equations used to determine particulate mass emissions to monitor compliance with Section V.A.8 ( ARM

17.8.749 and ARM 17.8.1213).

A. 20

. Compliance with Section V.A.9 shall be determined with the COMS as the primary measure of compliance with the opacity limit, except that 40 CFR Part 60, Appendix A, Method 9, may be used as a measure of compliance when there is reas on to believe that COMS data is not accurate or when COMS data is unavailable (ARM 17.8.321(15)).

A.2 1

. The COMS are required to conform to federal specifications. The COMS are required to provide a daily (mill day) average opacity reading to monitor com pliance with Section V.A .10 ( ARM

17.8.749 and ARM 17.8.1213)

.

A.2 2

. M2Green shall monitor compliance with Section V. A.11 by documenting all maintenance and repair activities on the ESP on the No. 4 Recovery Boiler and by documenting whenever the ESP

is no t operated during recovery boiler operation. The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.1213)

.

A.2 3

. M2Green shall monitor compliance with Section V.A.12 by monitoring emissi ons according to the CAM Plan contained in Appendix E of this permit (ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

A.2 4

. The record of the daily black liquor firing rate for the No. 4 Recovery Boiler shall be maintained

on site and submitted to the De partment in the monthly report (ARM 17.8.1212).

A.2 5

. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in

accordance with the Montana Source Test Protocol and Procedures Manual ( ARM 17.8.106 and ARM 17.8.1212)

.OP2589

- 07 27 Date of Decision : 07/08/11

Effective Date: 08/09/11 A.2 6

. M2Green shall maintain records in accordance with 40 CFR §63.866 to verify operation and maintenance of the COMS required by Section V. A. 18 (ARM 17.8.342 and 40 CFR 63, Subpart MM)

.

A.2 7

. M2Green shall operate and maintain the TRS CEM and records shall be submitted to the Department upon request (ARM 17.8.1212)

.

A.2 8

. The opacity monitors required to monitor compliance with SectionV.A.7 will provide a 24

- hou r average opacity that will be converted to gr/dscf and then converted to lb/day and lb/day monthly average using the correlation between opacity and particulate emissions. M2Green shall maintain a correlation between opacity and particulate emissions (fr om stack test results) and use this correlation to calculate daily and monthly averages ( ARM 17.8.749 and ARM 17.8.1212)

.

A.2 9

. M2Green shall maintain records of all supporting documentation for any proposed changes to the correlation equations on site an d shall submit these records to the Depart ment upon request to monitor compliance with Section V.A.1 9

.

A. 30

. The COM S shall be operated and maintained and records shall be submitted to the Department upon request to monitor compliance with the opacity lim itation (ARM 17.8.1212)

.

A.3 1

. M2Green shall maintain records required by Section V.A.2 2 on site and submit the information to the Department upon request (ARM 17.8.1212).

A.3 2

. M2Green shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM Plan contained in Appendix E of this permit (ARM 17.8.1212 and 40 CFR Part 64).

Reporting

A.3 3

. M2Green shall submit a monthly report to the Department within 30 days following the end of

the month . The monthly report shall include ( ARM 17.8.749 and ARM 17.8.1212) :

a. The daily black liquor firing rate for the No. 4 Recovery Boiler.

b. Daily averages for TRS for the No. 4 Recovery Boiler.

c. A monthly average for pounds of sulfur emitted per 1000 pounds of black liquor burned

for the No. 4 Recovery Boiler.

d. Monthly average of the daily total particulate emissions as determined by the correlation equations for the No. 4 Recovery Boiler. This report shall include daily calculated grain loading (gr/dscf), air flow (dscfm), total particulate (lb/hour), and the 24

- hour average opacity.

e. A summary of opacities from the No. 4 Recovery Boiler equal to or greater than 20% averaged over 6 consecutive minutes.

A.3 4

. Quarterly, M2Green shall submit excess emission reports for the COM . This report shall include ( ARM 17.8.749 and ARM 17.8.1212) :

a. The magnitude of excess emissions computed in accordance with 60.13(h), any conversion factors used, and the date and time of commencement and completion of each time period of excess emiss ions.OP2589

- 07 28 Date of Decision : 07/08/11

Effective Date: 08/09/11 b. Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of the affected facility; the nature and cause of any malfunction (if known); the corrective action taken or preventative measure s adopted.

c. The date and time identifying each period during which the continuous monitoring system was inoperative, except for zero and span checks.

d. When no excess emissions have occurred, or the continuous monitoring systems have been inoperative such information shall be stated in the report.

e. The excess emission reports shall be completed in a format supplied or approved by the Department.

A.3 5

. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed ; and,

b. Notification of any proposed changes to the correlation equations , if applicable

.

A.3 6

. The annual compliance certification report required by Section VIII.B must contain a certification

statement for the a bove applicable requirements (ARM 17.8.1212).OP2589

- 07 29 Date of Decision : 07/08/11

Effective Date: 08/09/11 B. No. 5 Recovery Boiler

EU003

– No. 5 Recovery Boiler

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

B.1, B.14, B.25,

B.3 5

, B.3 8 Black Liquor Firing

Rate Daily Rate Maintain Log Daily Monthly

B.2, B.15, B.16, B.26, B.27, B.3 7

, B.3 8 TSP 0.044gr/dscf

corrected to 8% O 2 633.6 lb/Day

26.4 lb/hr 40 CFR Part 60,

Appendix A Annually /

Semi

- annual if

above 80% of permit limit Semi

- annual

COMs Ongoing Semi

- annual

B.3, B.15, B.26,

B.3 7 , B.3 8 PM 10 633.6 lb/ Day

26.4 lb/hr 40 CFR Part 51,

Appendix M Annually /

Semi

- annual if

above 80% of permit limit Semi

- annual

B.4, B.15, B.26,

B.3 7 , B.3 8 Total Sulfate 633.6 lb/ Day

26.4 lb/hr 40 CFR Part 60,

Appendix B Annually /

Semi

- annual if

above 80% of permit limit Semi

- annual

B.5, B.15, B.17, B.26, B.3 5

, B.3 7

, B.3 8 Total Reduced

Sulfur ≤ 5 ppm corrected to

8% O 2 , 12

- hr Average CEM Ongoing Monthly

B.6, B.17, B.28,

B.3 6 , B.3 7 , B.3 8 Total Reduced

S ulfur CEM Operate and Maintain Ongoing Semi

- annual
EER Reports As Necessary Quarterly
B.7, B.18, B.29,

B.3 5 , B.3 8 TSP 384 lb/Day

– Monthly Average COM Data &

Correlation Equations Monthly Monthly

B.8, B.19, B.30,

B.3 7 , B.3 8 Correlation Equations Prop osed Changes Request Department Approval As Necessary Semi

- annual

B.9, B.20, B.31,

B.3 5 , B.3 8 Opacity 20% COM

Method 9 Ongoing Monthly

B.10, B.21, B.31,

B.3 7 , B.3 8 Opacity COM Performance Specification 1 in 40
CFR Part 60, Appendix B Ongoing Semi

- annual

B.11, B.22, B.3 2

, B.3 7 , B.3 8 Particulate

Emissions Operate and Maintain

ESP Recordkeeping As Necessary Semi

- annual

B.12, B.23, B.3 3

, B.3 6 , B.3 7 , B.3 8 No. 5 Recovery

Boiler 40 CFR 60,

Subpart BB 40 CFR 60, Subpart BB 40 CFR 60,

Subpart BB Semi

- annual

EER Reports As Necessary Quarterly
B.13, B.24, B.3 4

, B.3 7 , B.3 8 CAM Plan CAM Plan Appendix

E CAM Plan Appendix

E Ongoing Semiannual

Conditions

B.1. M2Green shall report monthly the daily black liquor firing rate for the No. 5 Recovery Boiler (ARM 17 .8.749).

B.2. Total suspended particulate emissions from the No. 5 Recovery Boiler shall not exceed 0.044 gr/dscf corrected to 8% O 2 (ARM 17.8.340 ; 40 CFR 60

, Subpart BB and ARM 17.8.342 ; 40 CFR

63

, Subpart MM) and in no case shall exceed 633.6 lb/day and 26.4 lb/hr (ARM 17.8.1201(10)).

B.3. PM 10 emissions from the No. 5 Recovery Boiler shall not exceed 633.6 lb/day and 26.4 lb/hr (ARM 17.8.1201(10)).OP2589

- 07 30 Date of Decision : 07/08/11

Effective Date: 08/09/11 B.4. Total sulfate emissions from the No. 5 Recovery Boiler shall not exceed 633.6 lb/day and 26.4

lb/ hr (ARM 17.8.1201(10)).

B.5. Total reduced sulfur emissions from the No. 5 Recovery Boiler shall not exceed 5 ppm corrected to 8% oxygen, 12

- hour average (ARM 17.8.1201(10)).

B.6. A TRS CEM is required by state permit and federal regulation for the N o. 5 Recovery Boiler

. The TRS CEM is not required to be operated when the boiler is fired solely on natural gas (ARM 17.8.1201(10)).

B.7. The monthly average total suspended particulate for the No. 5 Recovery Boiler shall not exceed 384 lb/day ( ARM 17.8. 749 and ARM 17.8.1201(10)).

B.8. M2Green shall submit for approval to the Department any proposed changes to the correlation equations used to determine particulate mass emissions (ARM 17.8.1201(10)).

B.9. M2Green shall not discharge into the outdoor atm osphere emissions from the No. 5 Recovery

Boiler that exhibit 20% opacity or greater averaged over 6 consecutive minutes for more than 3%

of the 6

- minute time periods during which the No. 5 Recovery Boiler is operating within a calendar quarter (ARM 17.8.3 21).

B.10. A COMS is required by state permit and federal regulations for the No. 5 Recovery Boiler

. The COMS is not required to be operated when the boiler is fired solely on natural gas (ARM 17.8.1201(10))

.

B.11. M2Green shall operate and maintain an E SP on the No. 5 Recovery Boiler. ESP operation is not required when the boiler is fired solely on natural gas (ARM 17.8.1201(10)).

B.12. M2Green shall comply with all applicable standards and limitations, and the reporting, recordkeeping, and notificati on requirements contained in 40 CFR 60, Subpart BB

- Standards of Performance for Kraft Pulp Mills, that includes, but is not limited to, the completion of the quarterly excess emission reports (EERs) (ARM 17.8.340 and 40 CFR 60, Subpart BB ).

B.13. M2Green shall provide a reasonable assurance of compliance with the emission limitations or standards for the operation of the emitting unit by following the CAM plan contained in Appendix E of this permit (ARM 17.8.1504).

Compliance Demonstration

B.14. M2Gree n shall maintain a record of the daily black liquor firing rate for the No. 5 Recovery Boiler to monitor compliance with Section V.B.1 (ARM 17.8.1213).

B.15. Annually , monitoring compliance with the Section V.B.2 through B.4 standards shall be determined by EPA source sampling methods specified in 40 CFR Part 60, Appendix A. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M or total particulate results may be used as a surrogate for PM 10 if the impinger analysis ("back

- half") is included. M2Green shall test the No. 5 Recovery Boiler for total particulate and PM 10 at 90% or greater of maximum rated capacity to monitor compliance with Section V.B.2. TRS emissions are determined by continuous monitoring methods specified in 40 CFR Part 60, A ppendix B, Performance Specifications, 1 through 6, as applicable to monitor compliance with Section V.B.5. Back half is not required since this is an

NSPS source.OP2589

- 07 31 Date of Decision : 07/08/11

Effective Date: 08/09/11 If the results from the annual testing are at 80% of the permit limitation or greater, t hen testing

shall occur on a semi

- annual basis. After M2Green tests’ results are below 80% of the permit
limitations, then M2Green may return to annual testing no later than one year from the last test

date (ARM 17.8. 1213).

B.16. The COMS shall be instal led, calibrated, and maintained in accordance with 40 CFR §63.864 to monitor compliance with the requirements of Section V.B.2 (ARM 17.8.342 and 40 CFR 63, Subpart MM).

B.17. The TRS CEM shall conform to federal specifications as required by 40 CFR Part 6 0, Appendix B, Specification 5, to monitor compliance with Section V.B.5 and B.6. Quality Assurance/Quality Control (QA/QC) Procedures specified in 40 CFR Part 60, Appendix F must be followed, except that when a daily calibration drift test if failed, the only data invalidated is

that collected between the failed calibration drift check and the next successful calibration drift

check (ARM 17.8.1213)

.

B.18. Monthly emissions shall be determined by continuous opacity monitoring and the correlation equations to monitor compliance with Section V.B.7 (ARM 17.8.1213)

.

B.19. M2Green shall notify the Department of any proposed changes to the correlation equations used to determine particulate mass emissions to monitor compliance with Section V.B.8 (ARM 17.8.1213)

.

B.20. Monitoring compliance with Section V.B.9 shall be determined with COMS as the primary measure of compliance with the opacity limit, except that 40 CFR Part 60, Appendix A, Method 9, may be used as a measure of compliance when there is reason to be lieve COMS data is not accurate or when COMS data is unavailable (ARM 17.8.321(15)).

B.21. The COMS shall conform to Performance Specification 1 found in 40 CFR Part 60, Appendix B, to monitor compliance with Section V.B.10. This COMS shall have a span s et at 70 percent opacity as required by 40 CFR, Part 60, Appendix B and Subpart BB (ARM 17.8.1213, ARM 17.8.340 and 40 CFR 60, Subpart BB)

.

B.22. M2Green shall monitor compliance with Section V.B.11 by documenting all maintenance and repair activities on the ESP on the No. 5 Recovery Boiler and by documenting whenever the ESP is not operated during recovery boiler operation . The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8. 1213).

B.23. M2Green shall maintain compliance in accordance with 40 CFR 60, Subpart BB, to monitor compliance with Section V.B.12 (ARM 17.8.340 and 40 CFR 60, Subpart BB)

.

B.24. M2Green shall monitor compliance with Section V.B.13 by monitoring emissions accor ding to the CAM Plan contained in Appendix E of this permit (ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

B.25. The record of the daily black liquor firing rate for the No. 5 Recovery Boiler shall be maintained on site and submitted to the Department in the monthly report (ARM 17.8.1212)

.

B.26. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in

accordance with the Mont ana Source Test Protocol and Procedures Manual ( ARM 17.8.106 and ARM 17.8.1212)

.OP2589

- 07 32 Date of Decision : 07/08/11

Effective Date: 08/09/11 B.27

. M2Green shall maintain records in accordance with 40 CFR §63.866 to verify operation and maintenance of the COMS required by Section V.B.16 (ARM 17.8.342 and 40 CFR 63, Subpart MM)

.

B.28. M2Green shall operate and maintain the TRS CEM and records shall be submitted to the Department upon request . Records indicating the dates and hours that the No. 5 Recovery Boiler is fired solely on natural gas shall also be maintained (ARM 17.8.1212)

.

B.29. The opacity monitors required to monitor compliance with Section V.B.7 will provide a 24

- hour average opacity that will be converted to gr/dscf and then converted to lb/day and lb/day monthly average using the correlation equations

. M2Green shall maintain a correlation between opacity and particulate emissions (from stack test results) and use this correlation to calculate daily and monthly averages ( ARM 17.8.749 and ARM 17.8.1212)

.

B.30. M2Green shall maintain records of all supp orting documentation for any proposed changes to the correlation equations on site and shall submit these records to the Department upon request to monitor compliance with Section V.B.19 (ARM 17.8.1212)

.

B.31. The COM shall be operated and maintained and records shall be submitted to the Department

upon request . Records indicating the dates and hours that the No. 5 Recovery Boiler is fired solely on natural gas shall also be maintained (ARM 17.8.1212)

.

B.32. M2Green shall maintain the records required by Section V.B.22 on site and submit the information to the Department upon request (ARM 17.8.1212).

B.3 3

. M2Green shall maintain records in accordance with 40 CFR 60, Subpart BB (ARM 17.8.340 and 40 CFR 60, Subpart BB)

.

B.3 4

. M2Green shall maintain CAM ap plicable records in accordance with 40 CFR Part 64 and the CAM Plan contained in Appendix E of this permit (ARM 17.8.1212 and 40 CFR Part 64).

Reporting

B.3 5

. M2Green shall submit a monthly report to the Department within 30 days following the end of

the month . The monthly report shall include ( ARM 17.8.749 and ARM 17.8.1212) :

a. The daily black liquor firing rate for the No. 5 Recovery Boiler.

b

. M2Green shall include a report of the average TRS on a 12

- hour basis.

c

. A monthly average for pounds o f sulfur emitted per 1000 pounds of black liquor burned for the No. 5 Recovery Boiler.

d

. Monthly average the daily total particulate emissions as determined by the correlation equations for the No. 5 Recovery Boiler. This report shall include daily calc ulated grain loading (gr/dscf), air flow (dscfm), total particulate (lb/hour), and the 24

- hour average opacity. M2Green shall report percent O 2 and grain loading (gr/dscf) corrected for O 2

.

e

. M2Green shall provide a summary of opacit ies from the No. 5 R ecovery Boiler equal to or greater than 20% averaged over 6 consecutive minutes.

f. The dates and number of hours that the No. 5 Recovery Boiler was fired solely on natural

gas.OP2589

- 07 33 Date of Decision : 07/08/11

Effective Date: 08/09/11 B.3 6

. Quarterly, M2Green shall submit excess emission reports for the CEM an d COM required by NSPS as specified in 40 CFR Part 60.7(c). This report shall include ( ARM 17.8.749 and ARM 17.8.340) :

a. The magnitude of excess emissions computed in accordance with 60.13(h), any conversion factors used, and the date and time of commen cement and completion of each time period of excess emissions.

b. Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of the affected facility; the nature and cause of any malfunction (if kn own); the corrective action taken or preventative measures adopted.

c. The date and time identifying each period during which the continuous monitoring system was inoperative, except for zero and span checks.

d. When no excess emissions have occurred, or the continuous monitoring systems have been inoperative, such information shall be stated in the report.

e. The excess emission reports shall be completed in a format supplied or approved by the Department.

B.3 7

. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed ; and

b. Notification of any proposed changes to the correlation e quations.

B.3 8

. The annual compliance certification report required by Section VIII.B must c ontain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 34 Date of Decision : 07/08/11

Effective Date: 08/09/11 C. No. 4 Smelt Dissolving Tank

EU016

– No. 4 Smelt Dissolving Tank

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Rep orting Requirements

C.1, C.6, C.10, C.13,

C.14 Opacity 20% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

C.2, C.7, C.10, C.13,

C.14 TSP 0.20 lb/ton of black liquor

solids processed 607 lb/day

25.29 lb/hr 40 CFR Part 60,

Appendix A Annually Semi

- annual

C.3, C.7, C.10, C.13,

C.14 PM 10 607 lb/day

25.29 lb/hr 40 CFR Part 51

Appendix M Annually Semi

- annual

C.4, C.8, C.11, C.13,

C.14 Particulate Emissions Venturi

Scrubber 40 CFR 63 Subpart

MM Ongoing Semi

- annual (in MACT II

Excess

Emi ssions and

Continuous Monitoring System

Performance and Summary Report)
C.5, C.9, C.12, C.13,

C.14 CAM Plan CAM Plan Appendix E CAM Plan

Appendix E Ongoing Semi

- annual

Conditions

C.1. M2Green shall not cause or authorize emissions from the No. 4 Smelt Dissolving Tank to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

C.2. Total suspended particulate emissions from the No. 4 Smelt Dissolving Tank shall not exceed 0.20 lb/ton of black liquor solids processed (ARM 17.8.342 and 40 CFR 63, Subpart MM) and, in no case, shall exceed 607 lb/day and 25.29 lb/hr (ARM 17.8.1201(10)).

C.3. PM 10 emissions from the No. 4 Smelt Dissolving Tank shall not exceed 607 lb/day and 25.29 lb/hr (ARM 17.8.1201(10)).

C.4. M2Green shall operate and maintain a wet venturi scrubber on the No. 4 Smelt Dissolving Tank (ARM 17.8.1201(10)).

C.5. M2Green shall provide a reasonable assurance of compliance with the emission limitations or

st andards for the operation of the emitting unit by following the CAM plan contained in Appendix E of this permit (ARM 17.8.1504).

Compliance Demonstration

C.6. As required by the Department and Section III.A.1, M2Green shall perform a Method 9 test in

acc ordance with the Montana Source Test Protocol and Procedures Manual to monitor compliance with Section V.C.1. Each observation period shall be a minimum of 6 minutes unlessOP2589

- 07 35 Date of Decision : 07/08/11

Effective Date: 08/09/11 any one reading is 20% or greater; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

C.7. Annually, monitoring compliance with Section V.C.2 and C.3 standards for the No. 4 Smelt Dissolving Tank s hall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix A. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may be used as a surrogate for PM 10 if the impinger analysis ("back

half") is included (ARM 17.8.1213)

.

C.8. The continuous parameter monitoring systems (CPMS) shall be installed, calibrated, and maintained in accordance with the requirements of 40 CFR §63.864(e)(10) to measure the pressure drop across the scrubber and the scrubbing liquid recirculation flow rate to monitor compliance with Section V.C.4 (ARM 17.8.342 and 40 CFR 63

, Subpart MM).

C.9. M2Green shall monitor compliance with Section V.C.5 by monitoring emissions according to the CAM Plan contained in Append ix E of this permit (ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

C.10. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Departm ent in accordance with the Montana Source Test Protocol and Procedures Manual ( ARM 17.8.106 and ARM 17.8.1212)

.

C.11

. M2Green shall maintain records in accordance with 40 CFR 63.866 to verify operation and maintenance requirements in Section V. C .4 and C.8 (ARM 17.8.342 and 40 CFR 63, Subpart MM)

.

C.12

. M2Green shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM Plan contained in Appendix E of this permit (ARM 17.8.1212 and 40 CFR Part 64).

Reporting

C.13. The semiannual monitoring report shall provide a summary of results of the last source testing that was performed (ARM 17.8.1212).

C.14. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 36 Date of Decision : 07/08/11

Effective Date: 08/09/11 D. No. 5 Smelt Dissolving Tank

EU017

– No. 5 Smelt Dissolving Tank

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

D.1, D.7, D.12, D.16,

D.17 Opacity 2 0% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

D.2, D.8, D.12, D.16,

D.17 TSP 0.20 lb/ton Black Liquor Solids

Processed 120 lb/Day

5.0 lb/hr 40 CFR Part 60,

Appendix A Annually Semi

- annual

D.3, D.8, D.12, D .1 6,

D.17 PM 10 120 lb /Day

5.0 0 lb/hr 40 CFR Part 51,

Appendix M Annually Semi

- annual

D.4, D.9, D.13, D.16,

D.17 Particulate

Emissions Wet Scrubber 40 CFR 63, Subpart MM Ongoing Semi

- annual (in MACT II

Excess

Emissions and

Continuous Monitoring System

Performance and Summary

R eport)
D.5, D.10, D.14, D.16,

D.17 No.5 Smelt

Dissolving Tank 40 CFR 60, Subpart BB 40 CFR 60,

Subpart BB 40 CFR 60,

Subpart BB Semi

- annual

D.6, D.11, D.15, D.16,

D.17 CAM Plan CAM Plan Appendix E CAM Plan

Appendix E Ongoing Semi

- annual

Conditions

D.1

. M2Green shall not cause or authorize emissions from the No. 5 Smelt Dissolving Tank to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

D.2. Total suspended partic ulate emissions from the No. 5 Smelt Dissolving Tank shall be limited to 0.20 lb/ton black liquor solids processed (ARM 17.8.342 and 40 CFR 63, Subpart MM), but in no case shall it exceed 120 lb/day and 5.0 lb/hr. (ARM 17.8.340 and 40 CFR 60, Subpart BB.).

D.3. PM 10 emissions from the No. 5 Smelt Dissolving Tank shall not exceed 120 lb/day and 5.0 0 lb/hr (ARM 17.8.1201(10)).

D.4

. M2Green shall operate and maintain a wet scrubber on the No. 5 Smelt Dissolving Tank (ARM 17.8.1201(10)).

D.5. M2Green shall comply with all applicable standards and limitations, and the reporting, recordkeeping, and notification requirements contained in the 40 CFR 60, Subpart BB

- Standards of Performance for Kraft Pulp Mills (ARM 17.8.340 and 40 CFR 60, Subpart BB ).OP2589

- 07 37 Date of Decision : 07/08/11

Effective Date: 08/09/11 D.6. M2Gre en shall provide a reasonable assurance of compliance with the emission limitations or standards for the operation of the emitting unit by following the CAM plan contained in Appendix E F of this permit (ARM 17.8.1504).

Compliance Demonstration

D.7. As required by the Department and Section III.A.1, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual to monitor compliance with Section V.D.1. Each observation period shall be a minimum of 6 minut es unless any one reading is 20% or greater; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

D.8. Annually, mon itoring compliance with Section V.D.2 and D.3 shall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix A and Subpart BB. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may

be used as a surrogate for PM 10 if the impinger analysis ("back

- half") is included (ARM 17.8.1213)

.

D.9. During times when the No. 5 Smelt Dissolving Tank is operated, the continuous parameter monitoring systems (CPMS) shall be installed, calibrated, and ma intained in accordance with the requirements of 40 CFR §63.864(e)(10) using an alternative monitoring method. The alternative monitoring parameters shall include scrubber liquid flow, scrubber fan operation, and explosion damper position to demonstrate co mpliance with Section V.D.4 (ARM 17.8.342 and 40 CFR 63

, Subpart MM).

D.10

. M2Green shall monitor compliance with Section V.D.5 in accordance with 40 CFR 60, Subpart BB (ARM 17.8.340 and 40 CFR 60, Subpart BB ).

D.11. M2Green shall monitor compliance wi th Section V.D.6 by monitoring emissions according to the CAM Plan contained in Appendix E of this permit (ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

D.12. All compliance source test recordkeeping shall be performed in accordance with the test meth od used, and shall be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual ( ARM 17.8.106 and ARM 17.8.1212)

.

D.13

. M2Green shall maintain records in accordance with 40 CFR § 63.866 to verify operation and maintenance requirements in Section V. D .4 and D.9 (ARM 17.8.342 and 40 CFR 63, Subpart MM).

D.14

. M2Green shall maintain records in accordance with 40 CFR 60, Subpart BB (ARM 17.8.340 and 40 CFR 60, Subpart BB ).

D. 15. M2Green shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM Plan contained in Appendix E of this permit (ARM 17.8.1212 and 40 CFR Part 64).

Reporting

D.16. The semiannual monitoring report shall provide a summary of re sults of the last source testing that was performed (ARM 17.8.1212)

.

D.17. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 38 Date of Decision : 07/08/11

Effective Date: 08/09/11 E. Multi

- fuel B oiler

EU021

– Multi

- fuel Boiler

Condition(s) Pollutant/

Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

E.1, E.2 1 , E.3 5

, E. 48 , E. 49 Opacity 20% Method 9 As Required by the Department

and Section

III.A.1 Sem i

- annual

E.2, E. 22 , E. 36

, E. 46 , E. 49 Steam

Production Daily Production Maintain Log Daily Monthly

E.3, E. 2 3 , E. 3 7

, E. 48 , E. 49 Dewatered Sludge Consumption 21,900 ton/yr Maintain a Production Log Daily Logging Semi

- annual

E.4, E. 2 4 , E. 38

, E. 48 , E. 49 Dew atered Sludge ≤ 0.4% Sulfur Content Sulfur Analysis Annually Semi

- annual

E.5, E. 2 5 , E. 39

, E. 48 , E. 49 Multi

- fuel

Boiler Fuel Dewatered Sludge from

Primary Clarifier Recordkeeping As Necessary Semi

- annual

E.6, E. 25 , E. 39

, E. 48 , E. 49 Dewatered Sludge Thorou ghly Blended w/

Existing Hog Fuel Recordkeeping As Necessary Semi

- annual

E.7, E. 2 6 , E. 4 0

, E. 48 , E. 49 pH of

Scrub ber

Water pH Maintained > 7 pH check Weekly Semi

- annual

E.8, E. 24 , E. 3 7

, E. 38 , E. 48 , E. 49 SO 2 from

combustion of primary clarifier sludge 5.70 lb/hr Dewatered sludge consumption/sulfur

content Daily/

Annually Semi

- annual

E.9, E. 2 7 , E. 3 5

, E. 48 , E. 49 TSP 0.10 lb/MMBtu

52.04 lb/hr 1,249 lb/Day 40 CFR Part 60, Appendix A Annually Semi

- annual

E.10, E. 2 7 , E. 3 5

, E. 48 , E. 49 PM 10 0.1 lb/MMBtu

52.04 lb/ hr 1,249 lb/Day 40 CFR Part 51, Appendix M Annually Semi

- annual

E.11, E. 2 8 , E. 4 1

, E. 47 , E. 48 , E. 49 SO 2 0.80 lb/MMBtu 429.6 lb/hr Firing Liquid Fossil Fuel or Liquid Fossil

Fuel & Wood Residue CEMs Ongoing Quarterly

E.12, E. 2 8 , E. 3 0

, E. 3 5 , E. 4 1 , E. 47

, E. 4 8 , E. 49 NO

x 0.30 lb/MMBtu 161.1 lb/hr Firing Liquid or

Gaseous Fossil Fuel & Wood Residue, & Exclusively

Natural Gas CEMs Ongoing Quarterly

Method 7 As Required by

the Department

and Section

III.A.1 Semi

- annual

E.13, E. 28 , E. 41

, E. 48 , E. 49 SO 2 CEM 40 CFR 60 Appendix B Specification 2 Ongoing Semi

- annual

E.14, E. 2 8 , E. 4 1

, E. 48 , E. 49 NO

x CEM 40 CFR 60 Appendix B Specification 2 Ongoing Semi

- annual

E.15, E. 29 , E. 4 1

, E. 48 , E. 49 Either Oxygen

or Carbon

Dioxide CEM Operate and Maintain

in Accordance w/ 40

CFR Part 60.45 Ongoing Semi

- annual

E.16, E. 30 , E. 35

, E. 48 , E. 49 SO 2 1.2 lb/MMBtu Firing Solid

Fuel or Solid Fuel w/ Wood

Residue Method 8 As Required by the Department

and Section

III.A.1 Semi

- annualOP2589

- 07 39 Date of Decision : 07/08/11

Effective Date: 08/09/11 E.17, E. 3 1 , E. 4 2

, E. 47 , E. 48 , E. 49 Multi

- fuel

Boiler 40 CFR 60,

Subpart D 40 CFR 60, Subpart D 40 CFR 60,

Subpart D Semi

- annual

EER Reports As Necessary Quarterly

E.18, E. 3 2 , E. 4 3

, E. 48 , E. 49 Waste Plastic

Combustion

Rate 15.1 tons/Day

468 tons/Month 5,616 tons/12

- month rolling

per. Maintain a Log On going Semi

- annual

E.19, E.3 3 , E.4 4

, E. 48 , E. 49 Multi

- fuel

Boiler Operate and Maintain two wet

venturi scrubbers, in parallel Recordkeeping Weekly Semi

- annual

E.2 0 , E.3 4 , E. 45

, E. 48 , E. 49 CAM Plan CAM Plan Appendix E CAM Plan Appendix

E Ongoing Semi

- annua l

Conditions

E.1. M2Green shall not cause or authorize emissions from the Multi

- fuel Boiler to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes

, except for one 6

- minute period per ho ur of not more than 27% opacity (ARM 17.8.340 and 40 CFR 60, Subpart D).

E.2. M2Green shall report, monthly, the daily steam production for the Multi

- fuel Boiler (ARM 17.8.1201(10)).

E.3. Consumption of dewatered sludge from the sludge dewatering plant by the Multi

- fuel Boiler shall not exceed a total of 21,900 ton/year (ARM 17.8. 752 ).

E.4. Sulfur content of the dewatered sludge used as fuel for the Multi

- fuel Boiler shall not exceed 0.4% on an as received basis (ARM 17.8. 752 ).

E.5. Any dewatered sludg e used as fuel in the Multi

- fuel Boiler shall originate from the primary clarifier (ARM 17.8. 749 ).

E.6. The dewatered sludge shall be thoroughly blended with the existing hog fuel (ARM 17.8. 749 ).

E.7. The pH of the scrubber water on the Multi

- fuel Boiler shall be maintained at greater than 7 (ARM

17.8. 749 ).

E.8. Emissions of SO 2 from the combustion of primary clarifier sludge in the Multi

- fuel Boiler shall be limited to 5.70 lb/hr (ARM 17.8. 752 ).

E.9. Total suspended particulate emissions from the Multi

- fuel Boiler shall not exceed 0.10 pound per

million B ritish t hermal u nits (lb/MMBtu) fired and 52.04 lb/hr and 1,249 lb/day (ARM 17.8.340 and 40 CFR 60, Subpart D,).

E.10. PM 10 emissions from the Multi

- fuel Boiler shall not exceed 1,249 lb/day and 52.04 lb/hr and 0.1 lb/million Btu fired (ARM 17.8.1201(10)).

E.11. Sulfur dioxide emissions from the Multi

- fuel Boiler shall not exceed 0.80 lb/million Btu and 429.6 lb/hr when firing liquid fossil fuel or liquid fossil fuel and wood residue (ARM 17.8.340 and 40 CFR 60, Subpart D).

E.12. Nitrogen dioxide (NO 2 ) emissions from the Multi

- fuel Boiler shall not exceed 0.30 lb/million Btu and 161.1 lb/hr when firing liquid fossil fuel, liquid fossil fuel and wood residue, or gaseous

fossil fuel and wood residue. This limit also applies when firing exclusively on natural gas because of a malfunction of the wood feed or ash handling systems. NO 2 emissions from the

Multi

- fuel Boiler shall not exceed 0.20 lb/ million Btu when firing natural gas for more than 24

cons ecutive hours. (ARM 17.8.340 and 40 CFR 60, Subpart D).OP2589

- 07 4 0 Date of Decision : 07/08/11

Effective Date: 08/09/11 E.13. A sulfur dioxide CEM is required by federal regulation and state permit when the Multi

- fuel

Boiler is fir ed on oil (ARM 17.8.1201(10)).

E.14. A nitrogen oxides CEM is required by federal regul ation and state permit for the Multi

- fuel Boiler (ARM 17.8.1201(10)).

E.15. Either an oxygen or carbon dioxide CEM is required as provided in 40 CFR 60.45 (ARM

17.8. 340 and 40 CFR 60, Subpart D ).

E.16. Sulfur dioxide emissions from the Multi

- fuel Boil er shall not exceed 1.2 lb/million Btu when firing solid fuel or solid fuel with wood residue (ARM 17.8.340 and 40 CFR 60, Subpart D).

E.17. M2Green shall comply with all applicable standards and limitations, and the reporting, recordkeeping, and notifica tion requirements contained in 40 CFR 60, Subpart D

- Standards of

Performance for Fossil

- Fuel

- Fired Steam Generators for Which Construction is Commenced After August 17, 1971, that includes, but is not limited to, the completion of the quarterly EERs (ARM 1 7.8.340 and 40 CFR 60, Subpart D ).

E.18. M2Green shall be limited to the waste plastic combustion rate (on a dry basis) of 15.1 ton/day, 468 ton/month, and 5,616 tons during any 12

- month rolling period (ARM 17.8.1201(10)).

E.19. M2Green shall operate a nd maintain two wet ventur i scrubbers, operated in parallel, on the Multi

fuel Boiler . When firing only natural gas in the boiler, the entire stack gas flow may be routed through one scrubber and the other scrubber secured for maintenance purposes. (ARM 17.8.1201(10)).

E.2 0

. M2Green shall provide a reasonable assurance of compliance with the emission limitations or standards for the operation of the emitting unit by following the CAM plan contained in Appendix E of this permit (ARM 17.8.1504).

Complianc e Demonstration

E.2 1

. As required by the Department and Section III.A.1

, M2Green shall perform a Method 9 test in accordance with the Montana Source Test Protocol and Procedures Manual to monitor compliance with Section V.E.1. Each observation period sha ll be a minimum of 6 minutes unless any one reading is 20% or greater; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM

17.8.105 and ARM 17.8.1 213 ).

E.2 2

. M2Green shall maintain a record of the daily steam production for the Multi

- fuel Boiler to monitor compliance with Section V.E.2 (ARM 17.8.1213)

.

E.2 3

. M2Green shall maintain a log of the consumption of dewatered sludge by the Multi

- fuel Boil er to monitor compliance with Section V.E.3 (ARM 17.8.1213)

.

E.2 4

. Annually

, M2Green shall conduct an analysis of the dewatered sludge to monitor compliance

with the sulfur limitation contained in Section V.E.4 and V.E.8. M2Green does not have to

conduct separate analyses for the Multi

- fuel Boiler if the sample of the dewatered sludge is taken prior to introduction to the Multi

- fuel Boiler (ARM 17.8.1213)

.

E.2 5

. M2Green shall document whenever dewatered sludge used as fuel for the Multi

- fuel Boiler origi nated from other than the primary clarifier and the dewatered sludge is not thoroughly blended with existing hog fuel to monitor compliance with Section V.E.5 and E.6 (ARM 17.8.1213)

.OP2589

- 07 41 Date of Decision : 07/08/11

Effective Date: 08/09/11 E.2 6

. M2Green shall conduct weekly pH checks on the scrubber to monitor compliance with Section

V.E.7 (ARM 17.8.1213)

.

E.2 7

. Annually , monitoring compliance with Section V.E.9 and E.10 shall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix A and Subpart D. PM 10 sampling methods are specif ied by 40 CFR Part 51, Appendix M. Total particulate results may be used as a surrogate for PM 10 if the impinger analysis ("back

- half") is included. M2Green shall

test the Multi

- fuel Boiler for total particulate and PM 10 at 90% or greater of the maximum daily average steam production rate achieved during the last three whole calendar months preceding the test to monitor compliance with Section V.E.9 and E.10. Daily average steam production shall be the average hourly steam production during a mill day. As required by the Department and

Section III.A.1

, M2Green shall also complete chloride testing to monitor compliance when burning waste plastic (ARM 17.8.1213)

.

E.2 8

. The nitrogen oxides and sulfur dioxide CEMs shall conform to federal specifications as required by Specification 2, 40 CFR Part 60, Appendix B, to monitor compliance with Section V.E.11, E.12, E.13, and E.14. Quality Assurance/Quality Control (QA/QC) Procedures specified in 40 CFR Part 60, Appendix F must be followed, except that when a dai ly calibration drift test i s failed, the only data invalidated is that collected between the failed calibration drift check and the

next successful calibration drift check (ARM 18.7.1213)

.

E. 29

. M2Green shall verify that either the oxygen or carbon dioxid e CEM is operated and maintained

in accordance with 40 CFR Part 60.45 to monitor compliance with Section V.E.15. QA/QC Procedures specified in 40 CFR Part 60, Appendix F must be followed, except that when a daily

calibration drift test i s failed, the only data invalidated is that collected between the failed

calibration drift check and the next successful calibration drift check (ARM 17.8.1213)

.

E.3 0

. As required by the Department and Section III.A.1

, M2Green shall conduct Method 7 and

Method 8 source tes ts to monitor compliance with Section V.E.12 and V.E.16 (ARM 17.8.1213)

.

E.3 1

. M2Green shall maintain compliance as required by 40 CFR 60, Subpart D, to monitor compliance

with Section V.E.17 (ARM 17.8.340 and 40 CFR 60, Subpart D)

.

E.3 2

. M2Green shall m aintain a log of the amount of waste plastic that is transported to the hog fuel pile on a daily basis. By the 25 th day of each month, M2Green shall total the waste plastic material that has been transported to the hog fuel pile during the previous month. The monthly information will be used to verify compliance with the rolling 12

- month limitation in Section

V.E.18 (ARM 17.8.1213)

.

E.33

. M2Green shall monitor compliance with Section V.E.19 by documenting, weekl y, scrubber

shower water flows and the scru bber pressure differential (ARM 17.8.1201(10)).

E.3 4

. M2Green shall monitor compliance with Section V.E.2 0 by monitoring emissions according to the CAM Plan contained in Appendix E of this permit (ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

E.3 5

. Al l compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual ( ARM 17.8.106 and ARM 17.8.1212)

.OP2589

- 07 42 Date of Decision : 07/08/11

Effective Date: 08/09/11 E.3 6

. M2Green shall record the daily steam production for the Multi

- fuel Boiler. The daily steam production shall be maintained on site and submitted to the Department in the monthly report (ARM 17.8.1212)

.

E.3 7

. M2Green shall maintain records of the daily consumption of dewatered sludge off the press

, including r ecords of sludge plant flow rates and sludge solid s content. All sludge sampling records shall include the date, time, and initials of the person performing the analysis (ARM 17.8.1212)

.

E. 38

. M2Green shall maintain copies on site of all analyses of the dewatered sludge for a minimum of 5 years. Copies of the analyses shall be submitted to the Department upon request (ARM 17.8.1212)

.

E. 39

. M2Green shall mainta in the records required by Section V.E. 25 on site and submit the information to the Department upon request (ARM 17.8.1212)

.

E.4 0

. M2Green shall maintain a log of the pH checks that include the date and time, and the recorder’s

initials (ARM 17.8.1212)

.

E.4 1

. M2Green shall maintain the records for the CEMs on site and submit them to the Department in accordance with Specification 2, 40 CFR Part 60, Appendix B, and 40 CFR 60.45 (ARM 17.8.340 and 40 CFR 60, Subpart D)

.

E.4 2

. M2Green shall maintain records in accordance with 40 CFR 60, Subpart D (ARM 17.8.340 and 40 CFR 60, Subpart D)

.

E.4 3

. The log of the waste plastic as required by Section V.E

. 3 2 shall be maintained on site and submitted to the Department upon request (ARM 17.8.1212)

.

E.4 4

. M2Green shal l maintain records required by Section V.E.3 3 on site and submit the information to the Department upon request (ARM 17.8.1212).

E.4 5

. M2Green shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM Plan contained in Appendix E of this permit (ARM 17.8.1212 and 40 CFR 64).

Reporting

E.4 6

. M2Green shall submit a monthly report to the Department within 30 days following the end of

the month . The monthly report shall include (ARM 17.8.1212) :

a. The daily steam production for th e Multi

- fuel Boiler; and

b. The 3

- hour averages for SO 2 and NO

x (as lb/MMBtu) as specified by federal regulations

for the Multi

- fuel Boiler.

E. 47

. Quarterly, M2Green shall submit excess emission reports for NO

x and SO 2 continuous emission monitors requi red by NSPS as specified in 40 CFR Part 60.7(c). This report shall include ( ARM

17.8.749 and ARM 17.8.1212) :

a. The magnitude of excess emissions computed in accordance with 60.13(h), any conversion factors used, and the date and time of commencement and completion of each time period of excess emissions.OP2589

- 07 43 Date of Decision : 07/08/11

Effective Date: 08/09/11 b. Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of the affected facility; the nature and cause of any malfunction (if known); the corrective action taken or preventative measures adopted.

c. The date and time identifying each period during which the continuous monitoring system was inoperative, except for zero and span checks.

d. When no excess emissions have occurred, or the conti nuous monitoring systems have been inoperative, such information shall be stated in the report.

e. The excess emission reports shall be completed in a format supplied or approved by the Department.

E. 48

. The semiannual monitoring report shall provide (A RM 17.8.1212):

a. A summary of results of the last source testing that was performed;

b. Monthly totals of sludge burned in the boiler and the maximum 12

- month total for the period ;

c

. Monthly totals of waste plastic burned in the boiler and the maximu m 12

- month total for the period ;

d

. A summary of any excursions of the scrubber liquid flow or scrubber differential pressure as defined in the Compliance Assurance Monitoring plan in Appendix E

.

E. 49

. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 44 Date of Decision : 07/08/11

Effective Date: 08/09/11 F

. Lime Kilns

EU011

– No. 1 Lime Kiln (Currently curtailed)

EU012

– No. 2 Lime Kiln (Currently curtailed)

EU013

– No. 3 Lime Kiln

EU014

– No. 4 Lime Kiln

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

F. 1, F .24,

F

. 33 , F

. 41

, F

. 4 2 No. 1, 2, and 3 Lime

Kiln Opacity 40% Method 9 As Required by the Department

and Section

III.A. 1 Semi

- annual

F .2, F .24,

F

. 3 3

, F

. 4 1

, F

. 4 2 No. 4 Lime Kiln Opacity 20% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

F .3, F .25,

F

. 3 3

, F

. 4 1

, F

. 4 2 No. 1 Lime Kiln TSP 0.064 gr/dscf

Corrected to

10% O 2 288 lb/Day

12.0 lb/hr 40 CFR P art 60,

Appendix A & 40 CFR Part 51, Appendix M Once every two

years Semi

- annual

F .4, F .25,

F

. 33

, F

. 4 1

, F

. 4 2 No. 1 Lime Kiln PM 10 288 lb/Day

12.0 lb/hr

F.5, F.25,

F

. 33

, F

. 4 1

, F

. 4 2 No. 1 Lime Kiln Total

Sulfate 259 lb/Day

10.79 lb/hr

F.6, F.25,

F. 28 , F.3 3,

F.35 , F.3 9,

F.42 No. 1 Lime Kiln

Total Reduced Sulfur ≤20 ppm 24

- hr Average 40 CFR Part 60,

Appendix A Once every two

years Monthly

F.7, F.25,

F.33 , F.4 1

, F.4 2 No. 2 Lime Kiln TSP 0.064 gr/dscf

Corrected to

10% O 2 266 lb/Day

11.08 lb/hr 40 CFR Part 60,

Appendix A & 40 CFR Part 51, Appendix M Once every two

years Semi

- annual

F.8, F.25,

F.3 3 , F.4 1,

F.42 No. 2 Lime Kiln PM 10 266 lb/Day

11.08 lb/hr

F.9, F.25,

F.33 , F.4 1,

F.42 No. 2 Lime Kiln Total

Sulfate 239 lb/Day

9.96 lb/hr

F.10

, F .25,

F. 28 , F.3 3,

F.35 , F.3 9,

F.42 No. 2 Lime Kiln Total

Reduced Sulfur ≤20 ppm 24

- hr Average 40 CFR Part 60,

Appendix A Once every two

years Monthly

F.11, F.25, F.27, F.3 3, F.41, F.42 No. 3 Lime Kiln TSP 0.064 gr/dscf

Corrected to

10% O 2 359 lb/Day

14.96 lb/hr 40 CFR Part 60,

Appendix A & 40 CFR Part 51, Appendix M Once eve ry two

years Semi

- annual

F.12, F.25,

F.33 , F.4 1,

F.42 No. 3 Lime Kiln PM 10 359 lb/Day

14.96 lb/hr

F.13, F.25, F.33, F.41,

F.42 No. 3 Lime Kiln Total

Sulfate 323 lb/Day

13.46 lb/hrOP2589

- 07 45 Date of Decision : 07/08/11

Effective Date: 08/09/11 F.14, F .25,

F. 28 , F.3 3

, F.3 5 , F.3 9,

F.42 No. 3 Lime Kiln Total

Redu ced Sulfur ≤20 ppm 24

- hr Average 40 CFR Part 60,

Appendix A Once every two

years Monthly

F.15, F.26, F.27, F.33,

F.41 , F.4 2 No. 4 Lime Kiln TSP 0.064 gr/dscf

Corrected to

10% O 2 204.0 lb/Day

8.50 lb/hr 40 CFR Part 60,

Appendix A & 40 CFR Part 51, Appendix M &

40 C FR Part 60, Subpart BB Once every two

years Semi

- annual

F.16, F.26,

F.3 3 , F.4 1,

F.42 No. 4 Lime Kiln PM 10 204.0 lb/Day

8.50 lb/hr

F.17, F.26,

F.3 3 , F.4 1

, F.4 2 No. 4 Lime Kiln Total

Sulfate 204.0 lb /Day

8.50 lb/hr

F.18, F.26,

F.3 5 , F.3 9

, F.4 2 No. 4 Lime Kiln Total

Reduced Sulfur ≤8.0 ppm 12

- hr Average CEM Ongoing w/ 12

- hr Averages Monthly

F.19, F.2 9

, F.3 5

, F.4 1

, F.4 2 TRS

– No. 1, 2, & 3

Lime Kilns CEM by State

Permit Operate and

Maintain Ongoing Semi

- annual

F.20, F. 30

, F.3 6 , F.4 1,

F.42 TRS

– No. 4 Lime Kiln CEM by State

Permit & Federal Regulation Operate and

Maintain in

Accordance w/ 40 CFR 60, Appendix B Specification 5 Ongoing Semi

- annual

F. 21, F.31, F.37, F.40, F.41, F.42 No.4 Lime Kiln 40 CFR 60, Subpart BB 40 CFR 60,

Subpart BB 40 CFR 60,

Subpart BB Semi

- annual

EER Re ports As Necessary Quarterly

F .22, F .2 7

, F .3 4

, F

. 41

, F.4 2 All Four Lime Kilns Venturi

Scrubbers 40 CFR 63

Subpart MM Ongoing Semi

- annual (in MACT II

Excess

Emissions and

Continuous Monitoring System

Performance and Summary Report)
F.23, F.32, F.38, F.4 1

, F.4 2 CAM Plan CAM Plan Appendix E CAM Plan

Appendix E Ongoing Semi

- annual

Conditions

F .1. M2Green shall not cause or authorize emissions from each of the No. 1, 2, and 3 Lime Kilns to be discharged into the outdoor atmosphere that exhibit an opacity of 40% or greater averaged over 6 consecutive minutes (ARM 17.8.304(1)).

F .2. M2Green shall not cause or authorize emissions from the No. 4 Lime Kiln to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 co nsecutive minutes (ARM 17.8. 304(2) ).

F .3. Total suspended particulate emissions from the No. 1 Lime Kiln shall not exceed 0.064 gr/dscf

corrected to 10% O 2 (ARM 17.8.342 and 40 CFR 63, Subpart MM) and, in no case, shall exceed 288 lb/day and 12.0 lb/hr (A RM 17.8.1201(10)).OP2589

- 07 46 Date of Decision : 07/08/11

Effective Date: 08/09/11 F .4. PM 10 emissions from the No. 1 Lime Kiln shall not exceed 288 lb/day and 12.0 lb/hr (ARM 17.8.1201(10)).

F .5. Total sulfate emissions from the No. 1 Lime Kiln shall not exceed 259 lb/day and 10.79 lb/hr (ARM 17.8.1201(10)).

F .6

. Total reduced sulfur emissions from the No. 1 Lime Kiln shall not exceed 20 ppm, 24

- hour average (ARM 17.8.1201(10)).

F .7. Total suspended particulate emissions from the No. 2 Lime Kiln shall not exceed 0.064 gr/dscf

corrected to 10% O 2 (ARM 17.8.342 and 40 CFR 63, Subpart MM) and, in no case, shall exceed 266 lb/day and 11.08 lb/hr (ARM 17.8.1201(10)).

F .8. PM 10 emissions from the No. 2 Lime Kiln shall not exceed 266 lb/day and 11.08 lb/hr (ARM 17.8.1201(10)).

F .9. Total sulfate emissions from th e No. 2 Lime Kiln shall not exceed 239 lb/day and 9.96 lb/hr (ARM 17.8.1201(10)).

F .10. Total reduced sulfur emissions from the No. 2 Lime Kiln shall not exceed 20 ppm, 24

- hour average (ARM 17.8.1201(10)).

F .11. Total suspended particulate emissions from the No. 3 Lime Kiln shall not exceed 0.064 gr/dscf

corrected to 10% O 2 (ARM 17.8.342 and 40 CFR 63, Subpart MM) and, in no case, shall exceed 359 lb/day and 14.96 lb/hr (ARM 17.8.1201(10)).

F .12. PM 10 emissions from the No. 3 Lime Kiln shall not ex ceed 359 lb/day and 14.96 lb/hr (ARM 17.8.1201(10)).

F .13. Total sulfate emissions from the No. 3 Lime Kiln shall not exceed 323 lb/day and 13.46 lb/hr (ARM 17.8.1201(10)).

F .14. Total reduced sulfur emissions from the No. 3 Lime Kiln shall not excee d 20 ppm, 24

- hour average (ARM 17.8.1201(10)).

F .15. Total suspended particulate emissions from the No. 4 Lime Kiln shall be limited to 0.064 gr/dscf corrected to 10 percent O 2 (ARM 17.8.342 and 40 CFR, Subpart MM), and, in no case, shall it

exceed 204. 0 lb/day and 8.50 lb/hr ( ARM 17.8.340 and 40 CFR 60, Subpart BB.).

F .16. PM 10 emissions from the No. 4 Lime Kiln shall not exceed 204.0 lb/day and 8.50 lb/hr (ARM 17.8.1201(10)).

F .17. Total sulfate emissions from the No. 4 Lime Kiln shall not exceed 2 04.0 lb /day and 8.50 lb/hr (ARM 17.8.1201(10)).

F .18. Total reduced sulfur emissions from the No. 4 Lime Kiln shall not exceed 8.0 ppm corrected to

10% O 2 , 12

- hour average (ARM 17.8.1201(10)).

F .19. A TRS CEM is required by state permit for the No. 1, No. 2, and No. 3 Lime Kilns (ARM 17.8.1201(10)).

F .20. A TRS CEM is required by state permit and federal regulations for the No. 4 Lime Kiln (ARM 17.8.1201(10)).OP2589

- 07 47 Date of Decision : 07/08/11

Effective Date: 08/09/11 F .21. M2Green shall comply with all applicable standards and limitations, and the reporti ng, recordkeeping, and notification requirements contained in the New Source Performance Standards for, as appropriate: 40 CFR 60, Subpart BB

- Standards of Performance for Kraft Pulp Mills as it applies to the No. 4 Lime Kiln, which includes but is not limi ted to the completion of the quarterly EERs (ARM 17.8.340 and 40 CFR 60, Subpart BB ).

F .22. M2Green shall operate and maintain a wet venturi scrubber on each of the four lime kilns (ARM 17.8.1201(10)).

F .23. M2Green shall provide a reasonable assurance of compliance with the emission limitations or standards for the operation of the emitting unit by following the CAM plan contained in Appendix E of this permit (ARM 17.8.1504).

Compliance Demonstration

F .24. As required by the Department and Section II I.A.1

, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual to mon itor compliance

with Section V.F.1 and F .2. Each observation period shall be a minimum of 6 minutes unless any one reading is 40% or 20% or greater, whichever is applicable; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

F .25. Once every tw o years , monitoring compliance with the above Section V. F.3

- F .5, F .7

- F.9, and

F .11

- F .13 standards shall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix A, including back

- half particulate. PM 10 sampling methods are spe cified by 40 CFR Part 51, Appendix M, including back

- half particulate. Total particulate results may be used as a surrogate for PM 10 if the impinger analysis ("back

- half") is included (ARM 17.8.1213)

.

F .26. Once every two years , monitoring compliance wit h the Section V.F .15 through F .1 7 standards shall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix A and Subpart BB. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may be u sed as a surrogate for PM 10 if the impinger analysis ("back

- half") is included. TRS emissions are determined by continuous monitoring, with 12

- hour averages to monitor compliance with Section V.F.18 (ARM 17.8.1213)

.

F .27. The CPMS shall be installed, cal ibrated, and maintained in accordance with the requirements of 40 CFR §63.864(e)(10) to measure the pressure drop across the scrubber and the scrubbing liquid recirculation rate for the scrubbers. Scrubbing liquid flow rate monitoring for the No. 3 and 4 Lime Kilns will be limited to the recirculation liquid flow rate to the “racetrack” portion of the quench section to demonstrate compliance with Section V. F .11 and F .15 (ARM 17.8.342 and 40

CFR 63

, Subpart MM).

F .28. Monitoring compliance with the Section s V.F.6, F.10, and F.14 shall be determined by EPA source sampling methods specified in 40 CFR Part 60, Appendix A. This testing and compliance demonstration shall take place once every two years or on another testing/monitoring schedule as may be approve d by the Department (ARM 17.8.1213).

F .29

. The TRS CEM required by Section V. F .19 is not required to conform to federal specifications. The monitors shall be of a type and installation approved by the Department (ARM 17.8.1213)

.

F

. 30

. The TRS CEM requir ed by Section V. F .20 shall conform to federal specifications as required by 40 CFR Part 60, Appendix B, Specification 5. Quality Assurance/Quality Control (QA/QC) Procedures specified in 40 CFR Part 60, Appendix F must be followed, except that when a dail y calibration drift test i s failed, the only data invalidated is that collected between the failed

calibration drift check and the next successful calibration drift check (ARM 17.8.1213)

.OP2589

- 07 48 Date of Decision : 07/08/11

Effective Date: 08/09/11 F .31

. M2Green shall monitor compliance as required by 40 CFR 60, Sub part BB (ARM 17.8.340 and 40 CFR 60, Subpart BB)

.

F .3 2

. M2Green shall monitor compliance with Section V.F .23 by monitoring emissions according to the CAM Plan contained in Appendix E of this permit (ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

F .3 3

. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212)

.

F

. 3 4

. M2Green shall maintain records in accordance with 40 CFR §63.866 to verify operation and maintenance requirements in Section V. F .27 (ARM 17.8.342 and 40 CFR 63, Subpart MM)

.

F

. 3 5

. M2Green shall maintain records of the daily average TRS for the No. 1, No. 2 and No. 3 Lime

Kilns. M2Green shall maintain records of the 12

- hour average TRS for the No. 4 Lime Kiln (ARM 17.8.1212)

.

F

. 3 6

. M2Green shall maintain the records for the CEMs on site and submit them to the Depa rtment in accordance with 40 CFR Part 60, Appendix B, Specification 5 (ARM 17.8.1212)

.

F

. 3 7

. M2Green shall maintain records in accordance with 40 CFR 60, Subpart BB (ARM 17.8.340 and 40 CFR 60, Subpart BB)

.

F

. 3 8

. M2Green shall maintain CAM applicable rec ords in accordance with 40 CFR Part 64 and the CAM Plan contained in Appendix E of this permit (ARM 17.8.1212 and 40 CFR Part 64).

Reporting

F

. 3 9

. M2Green shall submit a monthly report to the Department within 30 days following the end of

the month . The monthly report shall include the daily average TRS concentrations on the No.1, No.2, and No. 3 Lime Kilns. M2Green shall include a report on a 12

- hour basis for the No. 4

Lime Kiln. M2Green shall also include the number of hours the corresponding piece of equipment was down or malfunctioning ( ARM 17.8.749 and ARM 17.8.1212)

.

F

. 40

. Quarterly, M2Green shall submit excess emission report for the No 4 Lime Kiln TRS continuous emission monitor required by NSPS as specified in 40 CFR Part 60.7(c). This repor t shall include (ARM 17.8.340 and 40 CFR 60, Subpart BB) :

a. The magnitude of excess emissions computed in accordance with 60.13(h), any conversion factors used, and the date and time of commencement and completion of each time period of excess emissions.

b. Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of the affected facility; the nature and cause of any malfunction (if known); the corrective action taken or preventative measures ado pted.

c. The date and time identifying each period during that the continuous monitoring system was inoperative, except for zero and span checks.OP2589

- 07 49 Date of Decision : 07/08/11

Effective Date: 08/09/11 

### d. When no excess emissions have occurred, or the continuous monitoring systems have been inoperative, such inf ormation shall be stated in the report.



### e. The excess emission reports shall be completed in a format supplied or approved by the Department.

F

. 4 1

. The semiannual monitoring report shall provide a summary of results of the last source testing that was perf

ormed (ARM 17.8.1212)

.

F

. 4 2

. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 50 Date of Decision : 07/08/11

Effective Date: 08/09/11 G

. Lime Slakers

EU018

– No. 1 Lime Slaker EU020

– No.3. L ime Slaker

EU019

– No. 2 Lime Slaker EU039

– Salt Cake/Lime Unloading

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

G .1, G.11,

G .15, G.17,

G .18 No. 1 Lime Slaker Opacity 40% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

G .2, G.11,

G .15, G.17,

G .18 No. 2 and No. 3 Lime

Slaker, Salt Cake/Lime Unloading Opacity 20% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

G .3, G.12,

G .15, G.17,

G

. 18 No. 1 Lime Slaker TSP 110 lb/day

4.58 lb/hr 40 CFR Part 60,

Appendix A
40 CFR Part 51, Appendix M Annually Semi

- annual

G .4, G.12,

G .15, G.17,

G .18 No. 1 Lime Slaker PM 10 110 lb/day

4.58 lb/hr

G .5, G .13,

G .15, G.17,

G .18 No. 2 Lime Slaker TSP 146 l b/day

6.08 lb/hr 40 CFR Part 60,

Appendix A 40 CFR Part 51, Appendix M As Required by

the Department

and Section

III.A.1 Semi

- annual

G .6, G .13,

G .15, G.17,

G .18 No. 2 Lime Slaker PM 10 146 lb/day

6.08 lb/hr

G .7, G .1 3

, G .15, G.17,

G .18 No. 3 Lime Slake r TSP 72 lb/day

3.00 lb/hr 40 CFR Part 60,

Appendix A 40 CFR Part 51, Appendix M As Required by

the Department

and Section

III.A.1 Semi

- annual

G .8, G.1 3

, G .15, G.17,

G .18 No. 3 Lime Slaker PM 10 72 lb/day

3.00 lb/hr

G .9, G .14,

G .16, G.17,

G .18 No. 1, 2 , and 3 Lime

Slakers Operate and

Maintain

Wet

Scrubbers Recordkeeping Monthly Semi

- annual

G .10, G.14, G.16, G.17,

G .18 Salt Cake/Lime Unloading Operate and

Maintain a Baghouse Recordkeeping Monthly Semi

- annual

Conditions

G .1. M2Green shall not cause or authorize emissions from the No. 1 Lime Slaker to be discharged into the outdoor atmosphere that exhibit an opacity of 40% or greater averaged over 6 consecutive minutes (ARM 17.8.304(1)).

G .2. M2Green shall not cause or authorize emissions from the No. 2 and No. 3 Lime Slakers, Salt Cake/Lime Unloading to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

G .3. Total suspended particulate emissions from the No. 1 Lime Slaker shall not exceed 110 lb/day and 4.58 lb/hr (ARM 17.8.1201(10)).

G .4. PM 10 emissions from the No. 1 Lime Slaker shall not exceed 110 lb/day and 4.58 lb/hr (ARM 17.8.1201(10)).OP2589

- 07 51 Date of Decision : 07/08/11

Effective Date: 08/09/11 G .5. Total suspended particulate emissions from the No. 2 Lime Slake r shall not exceed 146 lb/day and 6.08 lb/hr (ARM 17.8.752).

G .6. PM 10 emissions from the No. 2 Lime Slaker shall not exceed 146 lb/day and 6.08 lb/hr (ARM 17.8.752).

G .7. Total suspended particulate emissions from the No. 3 Lime Slaker shall not exceed 72 lb/day and

3 .00 lb/hr (ARM 17.8.1201(10)).

G .8. PM 10 emissions from the No. 3 Lime Slaker shall not exceed 72 lb/day and 3.00 lb/hr (ARM 17.8.1201(10)).

G .9

. M2Green shall operate and maintain a wet scrubber on each of the three lime slakers (ARM

17 .8.1201(10)).

G .10. M2Green shall operate and maintain a baghouse on the salt cake/lime unloading (ARM 17.8.1201(10)).

Compliance Demonstration

G .11. As required by the Department and Section III.A.1

, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual to monitor compliance with Section V. G .1 and G .2. Each observation period shall be a minimum of 6 minutes unless any one reading is 40% or 20% or greater, whichever is applicable; then the

observ ation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

G .12. Annually, monitoring compliance with the above Section V. G .3 and G .4 sta ndards shall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix A. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may be used as a surrogate for PM 10 if the impinger analysis ("back

- half") is included (ARM 17.8.1213)

.

G .13. As required by the Department and Section III.A.1 , monitoring compliance with the above

Section V. G .5, G .6 , G.7, and G.8 standards shall be accomplished by EPA source sampling methods specified in 40 CFR P art 60, Appendix A. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may be used as a surrogate for PM 10 if the impinger analysis ("back

- half") is included (ARM 17.8.1213)

.

G .14. M2Green shall monitor complian ce with Sections V. G .9 and V. G .10 by documenting whenever the wet scrubbers on each of the three lime slakers and the baghouse on the salt cake/lime unloading are not operated during source operation and shall keep records of repair and maintenance activit ies to the wet scrubbers and baghouse. The records must include, but are not limited to, the date, time, and action(s) taken for repair an d maintenance (ARM 17.8.1213).

Recordkeeping

G .15. All compliance source test recordkeeping shall be performed in a ccordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212)

.OP2589

- 07 52 Date of Decision : 07/08/11

Effective Date: 08/09/11 G .16. M2Green shall maintain the records required by Section V.G .14 on site and submit the information to the Department upon request (ARM 17.8.1212).

Reporting

G .17. The semiannual monitoring report shall provide a summary of results of the last source testing that was performed (ARM 17.8.1212):

G .18. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 53 Date of Decision : 07/08/11

Effective Date: 08/09/11 H

. Condensate Collection (40 CFR 63, Subpart S)

EU109

– Condensa te Collection

EU109a

– No. 1 and No. 2 Evaporators (Foul Condensate)

EU109b

– No. 3 Evaporator (Combined Condensate)

EU109c

– No. 3 Evaporator (Foul Condensate)

EU109d

– No. 4 Evaporator (Condensate from Effect No. 2)

EU109e

- No. 4 Evaporator (Foul Conden sate)

EU109f

- No. 2 Concentrator/No. 5 Evaporator (Foul Condensate) EU109g

- No. 1 Concentrator (Foul Condensate)

EU109h

- Turpentine Decanter (Condensate)

EU109i

- Batch Digester Blow Heat Recovery System

- (Condensate from Accumulator Secondary

Condense r) EU109j

- LVHC

- NCG Line Drains

EU109k

- Foul Condensate Tank

EU109l

- Black Liquor Spill Tank No. 1

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

H

. 1, H .3, H.6,

H .8 , H .9 Digester Production Measure as ODT Pulp Calculation Daily Semi

- annual (in MACT I

Excess

Emissions

and

Continuous Monitoring System

Performance and Summary Report)

H .2, H .4, H .5,

H .6, H .7, H .8

, H .9 Mass MeOH in

Collected Specified

Co ndensate Collect via Closed

Drain System Visual Inspection Each Calendar Month Semi

- annual

7.2 lb MeOH/ODT Pulp Initial Test

– NCASI

94.03 Direct Injection

Test Methods for

Methanol 60

- Day Initial Test &

Every 5

- Years & 60

- Day Rolling Average Semi

- annua l (in MACT I

Excess

Emissions

and

Continuous Monitoring System

Performance and Summary Report)

Conditions

H .1. M2Green shall measure the mill

- wide batch and continuous digester production as oven

- dried tons of pulp per day ( ARM 17.8.342 and 40 CFR 63.44 6(c)(3)).

H .2. M2Green shall collect in a closed drain system sufficient condensate from the specified sources above, so that the combined condensates from the specified sources shall contain at least 7.2 lbs methanol per oven dried ton pulp (MeOH/ODTP) o n a 60

- day rolling average ( ARM 17.8.342

and 40 CFR 63.446(c)(3)(d)).

Compliance DemonstrationOP2589

- 07 54 Date of Decision : 07/08/11

Effective Date: 08/09/11 H

. 3

. M2Green shall calculate the mill

- wide daily pulp production using the following methodology (equations a

- c) to monitor compliance with Section V. H .1 (AR M 17.8.1213) :

a. Fiber usage on machines (tons, as produced) = Paper machine production (tons, as produced) +/

- change in Cull production inventory (tons, as produced)

b. Fiber usage on machines (oven

- dry tons) = Fiber usage on machines (tons, as produce d) x (1.0

– moisture content of paper

– chemical additive content of the linerboard)

c. Wood pulp production (ODT) = Fiber usage on machines (ODT)

– OCC usage on machines (ODT) +/

- Wood pulp high density storage change (ODT).

H .4. M2Green shall visually ins pect the closed drain system’s integrity at least once each calendar

month for leaks to mon itor compliance with Section V.H .2 ( ARM 17.8.342 and 40 CFR 63.453).

H

. 5

. M2Green has performed an initial 60

- day test to determine condensate flow and, using the NCASI 94.03 direct injection test method for methanol, the concentration and mass of methanol in the collected condensate. The collected test data will be used to develop methanol collection

factors. M2Green shall do a subsequent test once every five ye ars to verify or revise the methanol collection factors as appropriate. M2Green shall determine the methanol collected on a

60

- day rolling average to monitor compliance with Section V. H .2 using the methanol collection factors from the initial or subsequen t tests (ARM 17.8.1213)

.

Recordkeeping

H

. 6

. M2Green shall maintain the calculations, on site, of the digesters production and the mass of methanol and the methanol collection factors as required by Section V. H .3 and H .5. The

calculations shall be submi tted to the Department upon request (ARM 17.8.1212)

.

H

. 7

. M2Green shall maintain on site logs of the visual inspections when completing the compliance demonstrations as required by Sections V. H .4. The logs shall include the date of the inspection, equipm ent type and identification, results of negative pressure tests for enclosures, results of leak detection tests, the nature of the defect or leak and the method of detection, and the observer’s initials ( ARM 17.8.342 and 40 CFR 63.454).

Reporting

H

. 8

. T he semiannual monitoring report shall provide a summary of any corrective actions taken to correct leaks in the closed drain system (ARM 17.8.1212 ).

H

. 9

. The annual compliance certification report required by Section VIII.B must contain a certification

st atement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 55 Date of Decision : 07/08/11

Effective Date: 08/09/11 I

. Low Volume, High Concentration (LVHC) and High Volume, Low Concentration (HVLC)

Non

- Condensable Gas es (NCG) (40 CFR 63, Subpart S)

EU110

– LVHC

- NCG

EU110a

- No. 1 and No. 2 Evaporators: Vacuum Vents

EU110b

– No. 3 Evaporator: Vacuum Vents

EU110c

– No. 4 Evaporator: Vacuum Vents

EU110d

– No. 5 Evaporator: Vacuum Vents

EU110e

– No. 2 Concentrator: Hotwell and Vacuum System Vent

EU110f

– No. 1 Concentrator: Hotwell and Vacuum System Vent EU110g

– M&D Digester: Blow Heat System Vent

EU110h

– Turpentine Condenser Vent

EU110I

- No. 1 and No. 2 Evaporators After Condenser Hotwell Vents EU110j

- No. 3 and No. 4 Evaporators Hotwell Vents

EU110k

- No. 2 Concentrator, No. 5 Evaporator Spiral Con denser Vent, and Hotwell Vent

EU110l

- No. 1 Black Liquor Spill Tank Vent

EU110m

- No. 3 Blow Tank

EU110n

- No. 1 and No. 2 Blow Tanks

EU110o

- Foul Condensate Tank EU110p

- No. 4 Evaporator Auxiliary Surface Condenser and After Condensers Vents

EU 154c

- S team Stripper

- off gas EU110q

– Spill Collection Tank

– Weak Black Liquor (Secondary)

EU026b

– Base Stock Washer Exhaust

EU026c

– No. 1 Base Stock Filtrate Tank

EU026d

– No. 2 Base Stock Filtrate Tank

EU026o

– Top Stock Foam Tower and Filtrate Tank EU026q

– Top Stock Washer Exhaust

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

I .1, I .2, I .3,

I .4, I .5 LVHC

- NCG and

HVLC

- NCG Closed Vent

System Visual Inspection

– Integrity of the

Closed V ent System Each Calendar

Month Semi

- annual

§63.457(d) No Detectable Leaks Initially & Annually Potential Excess Emission Reports Ongoing

Conditions

I .1. M2Green shall operate and maintain a closed vent system for the specified LVHC

- NCG and

HVL C

- NCG that is routed to a control device that meets the requirements specified in 40 CFR 63.443(d) and 63.446(e) ( ARM 17.8.342 ; 40 CFR 63.443(c) ; and 40 CFR 63.446(d) ).

Compliance Demonstration

I .2. M2Green shall inspect the closed vent system’s integri ty at least once every calendar month. The visual inspection shall include the valves, piping, ductwork, enclosures, and connections for visible evidence of defects. If leaks are identified, M2Green shall start repairs within 5 days and complete repairs w ithin 15 days (40 CFR 63.453). M2Green has conducted an initial leak test on the closed vent system that has demonstrated compliance with Section V. I .1. M2Green shall conduct annual leak tests on the closed vent system to monitor compliance with Section V. I .1. The initial and annual tests to monitor no detectable leaks shall be completed as required by §63.457(d) (ARM 17.8.342 and 40 CFR 63, Subpart S)

.OP2589

- 07 56 Date of Decision : 07/08/11

Effective Date: 08/09/11 Recordkeeping

I .3. M2Green shall maintain on site, logs when completing the monitoring demonstrati ons as required by Sections V. I .2. The logs shall include the date of the inspection, equipment type and identification, results of the nature of the defect or leak and the method of detection, and the observer’s initials ( ARM 17.8.342 and 40 CFR 63.454).

Reporting

I .4. The semiannual mon i toring report shall provide a summary of any corrective actions taken to correct leaks in the closed vent system and the closed drain system with a summary of any testing completed (ARM 17.8.1212)

.

I .5. The annual comp liance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 57 Date of Decision : 07/08/11

Effective Date: 08/09/11 J

. Steam Stripper

EU154

– Steam Stripper

EU154a

– Steam Stripper Vent

EU154b

– Steam Stripper Feed Tank

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

J .1, J .4, J.7, J.10, J .11 Gaseous Emissions

from Steam Stripper Ducted to Thermal

Oxidizer Recordkeeping As Necessary Semi

- annual

J.2, J.3, J.5, J.6, J.8, J.9, J.10, J.11 Steam Stripper 92 percent (by weight)

methanol removed in specified collected

condensate Initial Test

– NCASI

94.03 Direct Injection

Test Methods for

Methanol 60

- Day Initial

Test & Every 5

Years & 60

- Day Rolling

Aver age Semi

- annual

(in MACT I

Excess

Emissions

and

Continuous Monitoring System

Performance and Summary Report) Parameter Monitoring Ongoing

Excess emissions from steam stripper and

evaporator systems
shall not exceed 10 percent (including

SSM event s) Parameter Monitoring Ongoing

Conditions

J .1. All gaseous emissions from the Steam Stripper shall be ducted to the thermal oxidizer for oxidation of reduced sulfur compounds (ARM 17.8.749).

J .2. M2Green shall determine the methanol mass, concentrati on, and methanol treated in the collected condensate sent to, and from the Steam Stripper ( ARM 17.8.342 and 40 CFR 63.446(e)(3)).

J .3. M2Green shall reduce hazardous air pollutants ( HAPs ) , measured as methanol, on a 60

- day rolling average by recycling col lected condensates specified in Section V. H (EU109) to systems, including the evaporator system, equipped with vent control or by removal in the steam stripper of at least 92 percent (by weight) of methanol per oven

- dried ton pulp criteria ( ARM 17.8.342

an d 40 CFR 63.446(e)(3)).

Excess emissions for the steam stripper system and, when used as an alternative means of treating collected condensates, the evaporator system shall not exceed 10 percent (including startup, shutdown, or malfunction) during a sem i

- annual period ( ARM 17.8.342 and 40 CFR 63.446 (g))

.

Compliance Demonstration

J .4. M2Green shall document all instances , on a 15

- minute basis

, that the gaseous emissions from the Steam Stripper are not ducted to the thermal oxidizer to monit or complian ce with Section V.J .1 (ARM 17.8.121 3 )

.

J .5. Once every five years after the initial test, M2Green shall perform a 60

- day test to determine the methanol treatment factors. The test shall be conducted to determine condensate flow, using the

NCASI 94.03 di rect injection test method for methanol and the concentration and mass of methanol treated in the steam stripper. M2Green will use the collected test data and steam stripper operating parameters (Section IV. J .6) to develop methanol treatment factors. M2G reen shall determine the methanol treatment on a 60

- day rolling average to monitor compliance withOP2589

- 07 58 Date of Decision : 07/08/11

Effective Date: 08/09/11 Section V. J .2 and J .3 using the methanol collection factors from the initial or subsequent tests (ARM 17.8.1213)

.

J .6. M2Green shall continuously monitor th e following parameters for methanol rem oval as required by Section IV.J .3. The data will be used to monitor compliance on a 60

- day rolling average (ARM 17.8.1213)

.

a. Steam Stripper

- Steam feed rate,

b. Steam Stripper

- Process wastewater (collected c ondensate) feed rate

c. Steam Stripper

- Column feed temperature and

d. Collected condensate overflow from the feed tanks for the steam stripper system and

evaporator system.

Recordkeeping

J .7. M2Green shall maintain the records required by Section V

. J .4 on site and submit the information to the Department upon request (ARM 17.8.1212).

J .8. M2Green shall maintain on site the daily averages of the steam stripper operating parameters

listed in V. J .5, and the calculations demonstrating methanol treatmen t by the steam stripper. The calculations shall be submitted to the Department upon request (ARM 17.8.1212)

.

J .9. M2Green shall maintain a summary of the continuous data collected as required by Section V. J .6 and submit it to the Department as required b y 40 CFR 63, Subpart S (ARM 17.8.342 and 40 CFR 63, Subpart S)

.

Reporting

J .10. The semiannual monitoring report shall provide a summary of all instances when gaseous emissions from the Steam Stripper are not ducted to the thermal oxidizer (ARM 17.8.1212 )

.

J .11. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 59 Date of Decision : 07/08/11

Effective Date: 08/09/11 K

. Thermal Oxidizer

EU153

– Thermal Oxidizer

EU153a

– Thermal Oxidizer Scrubbe r Stack

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

K .1, K .7,

K .12, K.17,

K .18 LVHC

- NCG and

HVLC

- NCG Ducted to Thermal

Oxidizer Recordkeeping Ongoing Semi

- annual

K .2, K .8,

K .13, K.17,

K .18 Combustion Chamber

temperature ≥1600 °F CMS Daily Average Semi

- annual

Continuously monitor temp. Accurately to 1% Audit monitor Annually Semi

- annual

K .3, K .9,

K .14, K.17,

K .18 Steam Stripper Off

gas and Combined

LVHC NCG a nd

HVLC

- NCG Closed Vent Gas

System Bypass Opening Excess emissions not

to Exceed 4 % Verify Valve Position

Every 15 Minutes Semi

- annual

K .4, K .10,

K .15, K.17,

K .18 Combustion Chamber

Residence Time 0.75 seconds Parametric Monitoring Monthly Semi

- annual

K

. 5, K .11,

K .16, K.17,

K .18 Opacity 20% Method 9 As Required by the Department and

Section III.A.1 Semi

- annual

K .6, K .11,

K .16, K .1 7,

K .18 Particulate Matter 0.10 gr/dscf

Corrected to 10%

O 2 Method 5 As Required by the Department and

Section III.A.1 Semi

- an nual

Conditions

K .1. LVHC

- NCG and HVLC

- NCG shall be routed to the Thermal O xidizer for combustion of hazardous air pollutants and oxidation of reduced sulfur compounds . If the Thermal O xidizer is unavailable, combustion of the LVHC

- NCG in the No. 3 Lim e Kiln will satisfy the HAP destruction requirements (ARM 17.8. 1201(10) )

.

K .2. M2Green must operate a continuous temperature monitoring system accurate to +/

- 1 percent in the combustion zone of the Thermal Oxidizer, and maintain on a daily average the Th ermal Oxidizer combustion chamber temperature of at least 1,600 °F during the periods when the

Thermal Oxidizer is used for combustion of the combined low

- volume high concentration non

condensable gas (LVHC

- NCG) and steam stripper off

- gas ( ARM 17.8.342, 40 CFR 63.443(d)(3)

, and ARM 17.8.321(3)).

K .3. M2Green shall limit bypass vent ing, from the combined LVHC

- NCG, HVLC

- NCG, and steam stripper off

- ga s, of the combustion system to 4 % or less, excluding start

- ups, shutdowns, and malfunctions ( ARM 17.8.342 and 40 CFR 63. 443(e)(3 )).

K .4. M2Green must design and operate the Thermal Oxidizer combustion chamber with a minimum of

0.75 seconds residence time for treatment of the combined LVHC

- NCG , HVLC

- NCG, and steam stripper off

- gas ( ARM 17.8.342, 40 CFR 63.443(d)( 3)

, and ARM 17.8.321(3)).

K .5. M2Green shall not cause or authorize to be discharged into the atmosphere, from the T hermal

O xidizer, any visible emissions that exhibit an opacity of 20% or greater (ARM 17.8.752).OP2589

- 07 60 Date of Decision : 07/08/11

Effective Date: 08/09/11 K .6. M2Green shall not cause or authoriz e to be discharge d into the atmosphere from the T hermal

O xidizer, any particulate matter emissions in excess of 0.10 gr/dscf corrected to 10% O 2 (ARM 17.8.752).

Compliance Demonstration

K .7. M2Green shall document , on a 15

- minute basis, all instances tha t the gaseous emissions from the

LVHC

- NCG system is not ducted to either the Thermal Oxidizer or the No. 3 Lime Kiln and

when the HVLC

- NCG system is not ducted to the Thermal O xidizer to monitor compliance with

Section V. K .1 (ARM 17.8.1213)

.

K .8. Annually

, M2Green shall audit the Thermal O xidizer CMS temperature monitoring instrumentation to monitor compliance with Section V. K .2 (ARM 17.8.1213)

.

K .9. M2Green shall operate a CMS that will record the bypass vent valve position for the combined

LVHC

- NCG and steam stripper off gas (open or closed) at least every 15 minutes to monitor compliance with Section V. K .3 ( ARM 17.8.342 and 40 CFR 63.450(d)).

K .10. The Thermal Oxidizer residence time shall be calculated using the designated parameters on a monthly bas is (ARM 17.8.1213)

.

K .11. As required by the Department and Section III.A.1

, M2Green shall conduct a Method 9 opacity test and a Method 5 source test on the Thermal Oxidizer to monitor compliance with the

limitations contained in Section V. K .5 and K .6. T hese tests shall be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.105 and ARM

17.8.1213 ).

Recordkeeping

K .12. M2Green shall maintain the records required by Section V.K .7 on site and submit the information to the Department upon request (ARM 17.8.1212).

K .13. M2Green shall maintain CMS records of the daily average temperature in the combustion zone of the Thermal Oxidizer, and the annual temperature audit in accordance with 40 CFR 63, Subpart S, and shall s ubmit them to the Department upon request (ARM 17.8.342, 40 CFR 63, Subpart S, and ARM 17.8.1212)

.

K .14. M2Green shall maintain the records of by

- pass venting for the combined LVHC

- NCG and steam stripper off gas, as required by Section V.K .3, and report t he percent time of excess emissions,

from the combined LVHC

- NCG and steam stripper off gas, that the combustion system was bypassed, semi

- annually to the Department as required by 40 CFR 63.10 (e)(vi) (ARM 17.8.342 and 40 CFR 63, Subpart S)

.

K .15. M2Green shall maintain a log of the calculation as re quired by Section V.K .10. The log shall include the parameter calculations, date, time, and reviewer’s initials (ARM 17.8.1212)

.

K .16. All compliance source test recordkeeping shall be performed in accordanc e with the test method used, and shall be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212)

.OP2589

- 07 61 Date of Decision : 07/08/11

Effective Date: 08/09/11 Reporting

K .17. The semiannual mo nitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last so urce testing that was performed; and

b. T he lowest daily average Thermal Oxidizer temperature and lowest thermal residence time during the period

.

K .18. The annual comp liance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 62 Date of Decision : 07/08/11

Effective Date: 08/09/11 L

. Natural Gas Boilers

EU024

– No. 1 Power Boiler

Condition(s) Pollutant/Parameter Permit Limit Complian ce Demonstration Method Frequency Reporting Requirements

L .1, L .2, L.3, L.4, L .5 Opacity 40% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

Conditions

L .1. M2Green shall not cause or authorize emissions from the No.1 Pow er Boiler to be discharged into the outdoor atmosphere that exhibit an opacity of 40% or greater averaged over 6 consecutive minutes (ARM 17.8.304(1)).

Compliance Demonstration

L .2. As required by the Department and Section III.A.1

, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 minutes unless any one reading is 40% or greater; then the observation period shall be a minimum of 20 minutes or u ntil a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

Recordkeeping

L .3. All compliance source test recordkeeping shall be performed in accordance with the test method used, and sha ll be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212)

.

Reporting

L .4. The semiannual monitoring report shall provide a summary of results of the last source testing that was performed (ARM 17.8.1212).

L .5. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 63 Date of Decision : 07/08/11

Effective Date: 08/09/11 M

. Miscel laneous Tanks/Vent

EU102(a

- t)

– Black Liquor Handling EU119(a

- e)

– Quick Lime/Dry Lime Handling EU127(a

- b)

– Tall Oil Reactor EU131(a

- j)

– White Liquor Handling

EU107

- Chemical Storage Tanks

Condition(s) Pollutant/Parameter Permit Limit Compliance Demons tration Method Frequency Reporting Requirements

M .1, M .2,

M .3, M.4,

M .5 Opacity 20% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

Conditions

M .1. M2Green shall not cause or authorize emissions from the Miscellaneous Tan ks/Vents to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

Compliance Demonstration

M .2. As required by the Department and Section III.A.1

, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 minutes unless any one reading is 20% or greater; then the observation period shall be a minimum of 20 minutes or un til a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

Recordkeeping

M .3. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shal l be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212)

.

Reporting

M .4. The semiannual monitoring report shall provide a summary of results of the last source testing that was performed (ARM 17.8.1212).

M .5. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 64 Date of Decision : 07/08/11

Effective Date: 08/09/11 N. Soda Ash System

EU 040

– Soda Ash System

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

N.1, N.4, N.7, N.9, N.10 Opacity 20% Method 9 As Required by the Department

and Section

III.A.1 Semi

- an nual

N.2 , N.5, N.8, N.9, N.10 PM/PM 10 Controlled with a

bin vent dust

collector Recordkeeping As Necessary Semi

- annual

N.3 , N.6, N.7, N.9, N.10 PM/PM 10 0.02 gr/dscf 40 CFR Part 60, Appendix A 40 CFR Part 51, Appendix M As required by

the Department

and Section

III.A.1 Semi

- annual

Conditions

N.1. M2Green shall not cause or authorize emissions from the Soda Ash System to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8. 304(2)).

N.2. PM/PM 10 emissions from the soda ash storage silo and associated pneumatic truck unloading station shall be controlled with a bin vent dust collector (ARM 17.8.752).

N.3. PM/PM 10 emissions from the soda ash storage silo and associated pneuma tic truck unloading station shall not exceed 0.02 gr/dscf (ARM 17.8.752).

Compliance Demonstration

N. 4

. As required by the Department and Section III.A.1, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Proce dures Manual. Each observation period shall be a minimum of 6 minutes unless any one reading is 20% or greater; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213).

N.5. M2Green shall monitor compliance with Section V.N.2 by documenting all maintenance activities on soda ash storage silo bin vent dust collector. The records must include, but are not limited to, the da te, time, and action(s) taken for repair and maintenance (ARM 17.8.1213).

N.6. As required by the Department and Section III.A.1

, monitoring compliance with Section V. N.3 shall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Ap pendix

A. PM 10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may be used as a surrogate for PM 10 if the impinger analysis ("back

- half") is included (ARM 17.8.1213).

Recordkeeping

N.7

. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and

ARM 17. 8.1212)

.OP2589

- 07 65 Date of Decision : 07/08/11

Effective Date: 08/09/11 N.8. M2Green shall maintain the records required by Section V.N.5 on site and submit the information to the Department upon request (ARM 17.8.1212).

Reporting

N. 9

. The semiannual monitoring report shall provide a summary of results of the last source testing that was performed (ARM 17.8.1212).

N. 10

. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 66 Date of Decision : 07/08/11

Effective Date: 08/09/11 SECTION VI. PERMIT CONDITIONS

- PAPER MILL DEPARTMENT, ENVIRONMENTAL AND TECHNICAL DEPARTMENT, ENGINEERING AND MAINTENANCE DEPARTMENT

A. Paper Machines

EU030

- No. 1 Paper Machine Wet End

EU031

- No. 1 Paper Machine Dryer

EU032

- No. 2 Paper Machine Wet End

EU033

- No. 2 Paper Mac hine Dryer

EU034

– No. 3 Paper Machine Wet End

EU035

- No. 3 Paper Machine Dryer

EU037

– Starch Handling

EU038

– Clay Handling

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

A.1, A.5, A.8, A.11,

A.12 No.1 and no.2 Paper

Machine Opacity 40% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

A.2, A.5, A.8, A.11,

A.12 No. 3 Paper Machine,

Starch Handling, Clay Handling, and

Salt Cake/Lime Handling Opacity 20%

A.3, A.6, A.9, A.11,

A.12 No. 3 Paper Machine

Production 481,000 Tons AD P / 12

-

Month Rolling Period Maintain a Log Monthly

Calculations Semi

- annual

A.4, A.7, A.10, A.11,

A.12 Starch Handling &

Clay Handling, Operate and Maintain Baghouses Recordkeeping Monthly Semi

- annual

Conditions

A.1. M2Green shall not cause or authorize emissions from the No. 1 and No. 2 Paper Machines to be discharged into the outdoor atmosphere that exhibit an opacity of 40% or greater averaged over 6 consecutive minutes (ARM 17.8.304( 1)).

A.2. M2Green shall not cause or authorize emissions from the No. 3 Paper Machine, Starch handling, Clay handling, and Salt cake/Lime handling to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 conse cutive minutes (ARM 17.8.304(2)).

A.3. The yearly production from the No. 3 Paper Machine shall be limited to 481,000 tons of air

- dried finished product (i.e . liner board ) during any rolling 12

- month period. This limit includes pulp input from the pulp m ill, as well as other sources (i.e., the OCC plant) (ARM 17.8.1201(10))

.

A.4. M2Green shall operate and maintain baghouses on the starch handling and the clay handling (ARM 17.8.1201(10)).

Compliance Demonstration

A.5. As required by the Department and Section III.A.1

, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual to monitor compliance with Section VI.A.1 and A.2. Each observation period shall be a minimum of 6 minutes unless any one read ing is 40% or 20%, as applicable, or greater; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).OP2589

- 07 67 Date of Decision : 07/08/11

Effective Date: 08/09/11 A.6. M2Green shall document by month, the total production of the No. 3 Paper Machine. By the 25 th
day of each month, M2Green shall total the production of the No. 3 Paper Machine for the previous month . The monthly information will be used to verify compliance with the r olling 12

- month limitation in Section VI.A.3 (ARM 17.8.1213)

.

A.7. M2Green shall monitor compliance with Section VI.A.4 by documenting all maintenance activities on the starch and clay baghouses . The records must include, but are not limited to, the

date , time, and action(s) taken for repair an d maintenance (ARM 17.8.1213).

Recordkeeping

A.8. All compliance source test recordkeeping shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitte d to the Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212)

.

A.9. The production log required by Section VI.A.6 shall be maintained on site and submitted to the Department upon request (AR M 17.8.1212).

A.10. M2Green shall maintain the records required by Section VI.A.7 on site and submit the information to the Department upon request (ARM 17.8.1212).

Reporting

A.11. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A su mmary of results of the last source testing that was performed; and

b. The monthly total production and the highest 12

- month rolling total production from the No. 3 Paper Machine during the period.

A.12. The annual compliance certification report requir ed by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 68 Date of Decision : 07/08/11

Effective Date: 08/09/11 B. EU130

– Effluent Treatment System

EU130a

- Paper Mill Raw Post Consumer Effluent Vent

EU130b

- Sludge Holding Tank

EU130c

- Sludge Press

EU130d

- Sludge Press Building Vent

EU130e

- Sludge Storage Ponds

EU130f

- Primary Clarifier EU130g

- Aeration Basin No. 1

EU130h

- Aeration Basin No. 2

EU130i

- Aeration Basin No. 3 EU130j

- Treated Effluent Ponds

EU130k

- Polishing Ponds

Condition(s) Pol lutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

B.1, B.2, B.3, B.4, B.5 Effluent Treatment

System Opacity 20% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

Conditions

B.1. M2Green shall not cause or authorize emissions from the Effluent Treatment System to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

Compliance Demonstration

B.2. As required by the Department and Section III.A.1

, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 minutes unless any one reading is 20% or gr eater; then the observation period shall be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

Recordkeeping

B.3. All compliance source test recordkeep ing shall be performed in accordance with the test method used, and shall be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212)

.

R eporting

B.4. The semiannual monitoring report shall provide a summary of results of the last source testing that was performed (ARM 17.8.1212).

B.5. The annual compliance certification report required by Section VIII.B must contain a certification

state ment for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 69 Date of Decision : 07/08/11

Effective Date: 08/09/11 C. EU120

– Roads, Unpaved

EU120

– Unpaved Road Fugitives

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

C.1, C.2, C.3, C .4,

C.5 Fugitive Emissions Reasonable Precautions Maintain a Log of

Corrective Actions As Necessary Semi

- annual

Conditions

C.1. M2Green shall not cause or authorize the use of any street, road or parking lot without taking reasonable precautions to cont rol emissions of airborne particulate matter (ARM 17.8.308(2)).

Compliance Demonstration

C.2. M2Green shall use reasonable precautions to control fugitive emissions and maintain a log of any

actions taken (ARM 17.8.1213).

Recordkeeping

C.3. M2Green sha ll maintain the log, on site, of any corrective action taken to control fugitive

emissions (ARM 17.8.1212).

Reporting

C.4. The semiannual monitoring report shall include a summary of any corrective actions taken ( ARM 17.8.1212).

C.5. The annual complian ce certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 70 Date of Decision : 07/08/11

Effective Date: 08/09/11 D. Liquid Fuel Handling

EU111

– Liquid Fuel Handling

Condition(s) Pollutant/Parameter Permit Limit Complianc e Demonstration Method Frequency Reporting Requirements

D.1, D.2, D.3, D.4, D.5 Liquid Fuel Handling

Opacity 20% Method 9 As Required by the Department

and Section

III.A.1 Semi

- annual

Conditions

D.1. M2Green shall not cause or authorize emissio ns from the Liquid Fuel Handling to be discharged into the outdoor atmosphere that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

Compliance Demonstration

D.2. As required by the Department and Section III.A.1

, M2Green shall perform a Method 9 test in

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 minutes unless any one reading is 20% or greater; then the observation period shall be a min imum of 20 minutes or until a violation of the standard has been documented, which ever is a shorter period of time (ARM 17.8.105 and ARM 17.8.1213 ).

Recordkeeping

D.3. All compliance source test recordkeeping shall be performed in accordance with the te st method used, and shall be maintained on site. The reports must be submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212)

.

Reporting

D.4. The semiannual monitoring report shall provide a summary of results of the last source testing that was performed (ARM 17.8.1212).

D.5. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2589

- 07 71 Date of Decision : 07/08/11

Effective Date: 08/09/11 E. EU152

– CFC Recycling

EU152

– CFC Recycling

– Freon Recycling
Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

E.1, E.6, E.7, E.8 , E.9 Appliance or Industrial

Process R efrigeration Equipment No Venting CFCs and

HCFCs Compliance

in

Accordance

w/ 40 CFR

Part 82 As

Necessary Semi

- a nnual

E.2, E.6, E.7, E.8 , E.9 Equipment Manufactured

After November 15, 1993 Prior to November 15, 1993 EPA Approved Testing org.

Stds in Table 3 of 40 CFR 82.158(c)
E.3, E.6, E.7, E.8 , E.9 Equipment Repair Leaks and Develop

Plan
E.4, E.6, E.7, E.8 , E.9 Equipment Servicing and

Refrigerant Purchases for Equipment Maintain Records if >50 lb of

CFC

E.5, E.6, E.7, E.8 , E.9 Mandatory Recyc ling

Technician Certification Maintain

Conditions

E.1. M2Green shall not intentionally vent chlorofluorocarbons ( CFCs ) and hydro

- chlorofluorocarbons ( HCFCs ) used as refrigerants when maintaining, servicing, repairing, or disposing of an appliance

or industrial process refrigeration equipment (40 CFR 82.154; EPA

- E nforceable O nly).

E.2. Recycling equipment manufactured after November 15, 1993, must be tested by an EPA

approved testing organization. Recycling equipment manufactured prior to November 15 , 1993, shall meet the standards specified in Table 3 of §82.158(c) (40 CFR 82.158; EPA

- E nforceable

O nly).

E.3. M2Green shall repair substantial leaks in accordance with 40 CFR Part 82 or develop a 1

- year equipment retrofit or retirement plan for leaking equipment (40 CFR 82.156 and 166; EPA

E nforceable O nly).

E.4. M2Green shall keep records of equipment servicing and refrigerant purchases for equipment holding more than 50 lb of CFC (40 CFR 82.166(k); EPA

- E nforceable O nly).

E.5. M2Green shall comply wi th the mandatory recycling technician certification (40 CFR 82.161;

EPA

- E nforceable O nly).

Compliance Demonstration

E.6. M2Green shall monitor compliance in accordance with 40 CFR Part 82 (40 CFR Part 82; EPA

Enforceable Only)

.

Recordkeeping

E.7. M2Gre en shall maintain records in accordance with 40 CFR Part 82 and submit the records to the Department upon request (40 CFR Part 82; EPA

- Enforceable Only).

ReportingOP2589

- 07 72 Date of Decision : 07/08/11

Effective Date: 08/09/11 E.8

. The semiannual monitoring report shall include any instances in which the leak rate for a unit holding more than 50 lbs of CFC exceeded 15% on an annual basis and the corrective action

taken (ARM 17.8.1212).

E.9

. The annual compliance certification report required by Section VIII.B must contain a certification statement for the above ap plicable requirements (ARM 17.8.1212).OP2589

- 07 73 Date of Decision : 07/08/11

Effective Date: 08/09/11 SECTION VII. NON

- APPLICABLE REQUIREMENTS

Air Quality Administrative Rules of Montana (ARM) and Federal Regulations identified as not applicable to the facility or to a specific emission unit at the time of the per mit issuance are listed below (ARM 17.8.1214). The following list does not preclude the need to comply with any new requirements that may become applicable during the permit term.

Facility

- Wide

The following table contains non

- applicable requirements wh ich are administrated by the Air Resources Management Bureau of the Department of Environmental Quality.

Rule Citation Reason 40 CFR 60, Subparts C, Cb

- Ce 40 CFR 60, Subparts E, Ea

- Ec 40 CFR 60, Subparts F

- Aaa 40 CFR 60, Subparts CC

- WWW 40 CFR 61, Subpar t B to L 40 CFR 61, Subpart N to FF 40 CFR 63, Subparts B to R 40 CFR 63, Subparts T to LL 40 CFR 63, Subpart NN to QQ 40 CFR 63, Subparts SS to JJJ

40 CFR 68 These requirements are not applicable because the facility is not an affected source as defined in these regulations.

40 CFR 82

ARM 17.8.316

ARM 17.8.320

ARM 17.8.326

ARM 17.8.330

ARM 17.8.323

ARM 17.8.324

ARM 17.8.331

ARM 17.8.332

ARM 17.8.333

ARM 17.8.334 These rules refer to a process, equipment, or activity that is not used at the facility.

E mission Units

The permit application identified applicable requirements: non

- applicable requirements for individual or specific emission units were not listed. The Department has listed all non

- applicable requirements in Section VIII.A; these requirement s relate to each specific unit, as well as facility wide.OP2589

- 07 74 Date of Decision : 07/08/11

Effective Date: 08/09/11 SECTION VIII. GENERAL PERMIT CONDITIONS

A. Compliance Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(a)

- (c)&(e), §1206(6)(c)&(b)

1. The permittee must comply with all condi tions of the permit. Any noncompliance with the terms or conditions of the permit constitutes a violation of the Montana Clean Air Act, and may result in enforcement action, permit modification, revocation and reissuance, or termination, or denial of a pe rmit renewal application under ARM Title 17, Chapter 8, Subchapter 12.

2. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

3. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. If appropriat e, this factor may be considered as a mitigating factor in assessing a penalty for noncompliance with an applicable requirement if the source demonstrates that both the health, safety or environmental impacts of halting or reducing operations would be more serious than the impacts of continuing operations, and that such health, safety or environmental impacts were unforeseeable and could not have otherwise been

avoided.

4. The permittee shall furnish to the Department, within a reasonable time set by the Depa rtment (not to be less than 15 days), any information that the Department may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Department copies of those records that are required to be kept pursuant to the terms of the permit. This subsection does not impair or otherwise limit the right of the permittee to assert the confidentiality of the information requested by the Department, as provided in 75

- 2

- 105, MCA.

5. Any schedule of compliance for applicable requirements with which the source is not in compliance with at the time of permit issuance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it was based.

6. For applicable requirements that will become effective during the permit term, the source shall meet such requirements on a timely basis unless a more detailed plan or schedule is requ ired by the applicable requirement or the Department.

B. Certification Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1207 and §1213(7)(a)&(c)

- (d)

1. Any application form, report, or compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12, shall contain certification by a responsible official of truth, accuracy and completeness. This certification and any other certification required under ARM Title 17, Chapter 8, Subchapter 12, shall state that, based on infor mation and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete.

2. Compliance certifications shall be submitted by February 15 of each year, or more frequently if otherwise specified in an ap plicable requirement or elsewhere in the permit. Each certification must include the required information for the previous calendar year (i.e., January 1

– December 31).OP2589

- 07 75 Date of Decision : 07/08/11

Effective Date: 08/09/11 3. Compliance certifications shall include the following:

a. The identification of each te rm or condition of the permit that is the basis of the certification;

b. The identification of the method(s) or other means used by the owner or operator for determining the status of compliance with each term and condition during the certification period, c onsistent with ARM 17.8.1212;

c. The status of compliance with each term and condition for the period covered by the certification, including whether compliance during the period was continuous or

intermittent (based on the method or means identified in ARM 17.8.1213(7)(c)(ii), as described above); and

d. Such other facts as the Department may require to determine the compliance status of the

source.

4. All compliance certifications must be submitted to the Environmental Protection Agency, as well as to the Depar tment, at the addresses listed in the Notification Addresses Appendix of this permit.

C. Permit Shield ARM 17.8, Subchapter 12, Operating Permit Program §1214(1)

- (4)

1. The applicable requirements and non

- federally enforceable requirements are included and specifically identified in this permit and the permit includes a precise summary of the requirements not applicable to the source. Compliance with the conditions of the permit shall be deemed compliance with any applicable requirements and any non

- federal ly enforceable requirements as of the date of permit issuance.

2. The permit shield described in 1 above shall remain in effect during the appeal of any permit action (renewal, revision, reopening, or revocation and reissuance) to the Board of

Environmental Review (Board), until such time as the Board renders its final decision.

3. Nothing in this permit alters or affects the following:

a. The provisions of Sec. 7603 of the FCAA, including the authority of the administrator under that section;

b. The liability of a n owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance;

c. The applicable requirements of the Acid Rain Program, consistent with Sec. 7651g(a) of the FCAA;

d. The ability of the administrator to obtain information from a source pursuant to Sec. 7414 of the FCAA;

e. The ability of the Department to obtain information from a source pursuant to the Montana Clean Air Act, Title 75, Chapter 2, MCA;

f. The emergency powers of the Department under the Montan a Clean Air Act, Title 75, Chapter 2, MCA; andOP2589

- 07 76 Date of Decision : 07/08/11

Effective Date: 08/09/11 g. The ability of the Department to establish or revise requirements for the use of r easonably

a vailable c ontrol t echnology (RACT) as defined in ARM Title 17, Chapter 8. However, if

the inclusion of a RACT into the permit pursuant to ARM Title 17, Chapter 8, Subchapter 12, is appealed to the Board, the permit shield, as it applies to the source’s existing permit,

shall remain in effect until such time as the Board has rendered its final decision.

4. Nothing in this permit alters or affects the ability of the Department to take enforcement action for a violation of an applicable requirement or permit term demonstrated pursuant to ARM 17.8.106, Source Testing Protocol.

5. Pursuant to ARM 17.8.132, for the purpose of sub mitting a compliance certification, nothing in these rules shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance. However, when compliance or noncompliance i s demonstrated by a test or procedure provided by permit or other applicable requirements, the source shall then be presumed to be in compliance or noncompliance unless that presumption is overcome by other relevant credible evidence.

6. The permit shield wi ll not extend to minor permit modifications or changes not requiring a permit revision (see Sections I & J).

7. The permit shield will extend to significant permit modifications and transfer or assignment of ownership (see Sections K & O ).

D. Monitoring, Re cordkeeping, and Reporting Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1212(2)&(3)

1. Unless otherwise provided in this permit, the permittee shall maintain compliance monitoring records that include the following information:

a. The date, place as defined in the permit, and time of sampling or measurement;

b. The date(s) analyses were performed;

c. The company or entity that performed the analyses;

d. The analytical techniques or methods used;

e. The results of such analyses; and

f. The operating con ditions at the time of sampling or measurement.

2. The permittee shall retain records of all required monitoring data and support information for a period of at least 5 years from the date of the monitoring sample, measurement, report, or application. Suppo rt information includes all calibration and maintenance records and all original strip

- chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. All monitoring data, support information, and required rep orts and summaries may be maintained in computerized form at the plant site if the information is made available to Department personnel upon request, which may be for either hard copies or computerized format. Strip

- charts must be maintained in their ori ginal form at the plant site and shall be made available to Department personnel upon request.OP2589

- 07 77 Date of Decision : 07/08/11

Effective Date: 08/09/11 3. The permittee shall submit to the Department, at the addresses located in the Notification Addresses Appendix of this permit, reports of any required monitorin g by February 15 and August 15 of each year, or more frequently if otherwise specified in an applicable requirement or elsewhere in the permit. The monitoring report submitted on February 15 of each year must include the required monitoring information fo r the period of July 1 through December 31 of the previous year. The monitoring report submitted on August 15 of each year must include the required monitoring information for the period of January 1 through June 30 of the current year.

All instances of deviations from the permit requirements must be clearly identified in such reports. All required reports must be certified by a responsible official, consistent with ARM

17.8.1207.

E. Prompt Deviation Reporting ARM 17.8, Subchapter 12, Operating Permit P rogram §1212(3)(c)

The permittee shall promptly report deviations from permit requirements, including those attributable to upset conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. To be considered prompt, deviations shall be reported to the Department within the following timeframes (unless otherwise specified in an applicable requirement):

1. For deviations which may result in emissions potentially in violation of permit lim itations:

a. An initial phone notification (or faxed or electronic notification) describing the incident within 24 hours (or the next business day) of discovery; and,

b. A follow

- up written, faxed, or electronic report within 30 days of discovery of the deviat ion that describes the probable cause of the reported deviation and any corrective actions or preventative measures taken.

2. For deviations attributable to malfunctions, deviations shall be reported to the Department in accordance with the malfunction repor ting requirements under ARM 17.8.110; and

3. For all other deviations, deviations shall be reported to the Department via a written, faxed, or electronic report within 90 days of discovery (as determined through routine internal review by the permittee).

Pr ompt deviation reports do not need to be resubmitted with regular semiannual (or other routine) reports, but may be referenced by the date of submittal.

F. Emergency Provisions ARM 17.8, Subchapter 12, Operating Permit Program §1201(13) and §1214(5), (6)& (8)

1. An “emergency” means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation and causes the source to exceed a technology

based emission limitation under this permit due to the unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of rea sonable preventive maintenance, careless or improper operation, or operator error.

2. An emergency constitutes an affirmative defense to an action brought for noncompliance with a technology

- based emission limitation if the permittee demonstrates through pro perly signed, contemporaneous logs, or other relevant evidence, that:OP2589

- 07 78 Date of Decision : 07/08/11

Effective Date: 08/09/11 a. An emergency occurred and the permittee can identify the cause(s) of the emergency;

b. The permitted facility was at the time being properly operated;

c. During the period of the emergency t he permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in the permit; and

d. The permittee submitted notice of the emergency to the Department within 2 working days

of the time when emission limitations were exceeded due to the emergency. This notice fulfills the requirements of ARM 17.8.1212(3)(c). This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken.

3. These em ergency provisions are in addition to any emergency, malfunction or upset provision contained in any applicable requirement.

G. Inspection and Entry ARM 17.8, Subchapter 12, Operating Permit Program §1213(3)&(4)

1. Upon presentation of credentials and other requirements as may be required by law, the permittee shall allow the Department, the administrator, or an authorized representative (including an authorized contractor acting as a representative of the Department or the administrator) to perform the foll owing:

a. Enter the premises where a source required to obtain a permit is located or emissions

related activity is conducted, or where records must be kept under the conditions of the permit;

b. Have access to and copy, at reasonable times, any records that m ust be kept under the conditions of the permit;

c. Inspect at reasonable times any facilities, emission units, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and

d. As auth orized by the Montana Clean Air Act and rules promulgated thereunder, sample or monitor, at reasonable times, any substances or parameters at any location for the purpose of assuring compliance with the permit or applicable requirements.

2. The permittee sha ll inform the inspector of all workplace safety rules or requirements at the time of inspection. This section shall not limit in any manner the Department’s statutory right of entry and inspection as provided for in 75

- 2

- 403, MCA.

H. Fee Payment

ARM 17.8 , Subchapter 12, Operating Permit Program §1210(2)(f) and ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation, and Open Burning Fees §505(3)

- (5) (STATE ONLY)

1. The permittee must pay application and operating fees, pursuant to ARM Title 17, Ch apter 8, Subchapter 5.

2. Annually, the Department shall provide the permittee with written notice of the amount of the fee and the basis for the fee assessment. The air quality operation fee is due 30 days after receipt of the notice, unless the fee assess ment is appealed pursuant to ARM 17.8.511. If anyOP2589

- 07 79 Date of Decision : 07/08/11

Effective Date: 08/09/11 portion of the fee is not appealed, that portion of the fee that is not appealed is due 30 days after receipt of the notice. Any remaining fee, which may be due after the completion of an appeal,

is due i mmediately upon issuance of the Board’s decision or upon completion of any judicial

review of the Board’s decision.

3. If the permittee fails to pay the required fee (or any required portion of an appealed fee) within 90 days of the due date of the fee, the Department may impose an additional assessment of 15% of the fee (or any required portion of an appealed fee) or $100, whichever is greater, plus interest on the fee (or any required portion of an appealed fee), computed at the interest rate

established un der 15

- 31

- 510(3), MCA.

I. Minor Permit Modifications ARM 17.8, Subchapter 12, Operating Permit Program §1226(3)&(11)

1. An application for a minor permit modification need only address in detail those portions of the permit application that require revision , updating, supplementation, or deletion, and may reference any required information that has been previously submitted.

2. The permit shield under ARM 17.8.1214 will not extend to any minor modifications processed pursuant to ARM 17.8.1226.

J. Changes Not Requiring Permit Revision ARM 17.8, Subchapter 12, Operating Permit Program §1224(1)

- (3), (5)&(6)

1. The permittee is authorized to make changes within the facility as described below, provided the following conditions are met:

a. The proposed changes do not r equire the permittee to obtain a Montana Air Quality Permit under ARM Title 17, Chapter 8, Subchapter 7;

b. The proposed changes are not modifications under Title I of the FCAA, or as defined in ARM Title 17, Chapter 8, Subchapters 8, 9, or 10;

c. The emission s resulting from the proposed changes do not exceed the emissions allowable under this permit, whether expressed as a rate of emissions or in total emissions;

d. The proposed changes do not alter permit terms that are necessary to enforce applicable

emission limitations on emission units covered by the permit; and

e. The facility provides the administrator and the Department with written notification at least 7 days prior to making the proposed changes.

2. The permittee and the Department shall attach each notice provided pursuant to 1.e above to their respective copies of this permit.

3. Pursuant to the conditions above, the permittee is authorized to make Section 502(b)(10) changes, as defined in ARM 17.8.1201(30), without a permit revision. For each such change, the written notification required under 1.e above shall include a description of the change within the source, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longer applicable as a result of t he change.OP2589

- 07 80 Date of Decision : 07/08/11

Effective Date: 08/09/11 4. The permittee may make a change not specifically addressed or prohibited by the permit terms and conditions without requiring a permit revision, provided the following conditions are met:

a. Each proposed change does not weaken the enforceabilit y of any existing permit conditions;

b. The Department has not objected to such change;

c. Each proposed change meets all applicable requirements and does not violate any existing permit term or condition; and

d. The permittee provides contemporaneous written no tice to the Department and the administrator of each change that is above the level for insignificant emission units as defined in ARM 17.8.1201(22) and 17.8.1206(3), and the written notice describes each such change, including the date of the change, any change in emissions, pollutants emitted, and any applicable requirement that would apply as a result of the change.

5. The permit shield authorized by ARM 17.8.1214 shall not apply to changes made pursuant to ARM 17.8.1224(3) and (5), but is applicable to te rms and conditions that allow for increases and decreases in emissions pursuant to ARM 17.8.1224(4).

K. Significant Permit Modifications ARM 17.8, Subchapter 12, Operating Permit Program §1227(1), (3)&(4)

1. The modification procedures set forth in 2 below must be used for any application requesting a significant modification of this permit. Significant modifications include the following:

a. Any permit modification that does not qualify as either a minor modification or as an administrative permit amendment;

b. Every significant change in existing permit monitoring terms or conditions;

c. Every relaxation of permit reporting or recordkeeping terms or conditions that limit the Department’s ability to determine compliance with any applicable rule, consistent with t he requirements of the rule; or

d. Any other change determined by the Department to be significant.

2. Significant modifications shall meet all requirements of ARM Title 17, Chapter 8, including those for applications, public participation, and review by affec ted states and the administrator, as they apply to permit issuance and renewal, except that an application for a significant permit modification need only address in detail those portions of the permit application that require revision, updating, supplemen tation or deletion.

3. The permit shield provided for in ARM 17.8.1214 shall extend to significant modifications.

L. Reopening for Cause ARM 17.8, Subchapter 12, Operating Permit Program §1228(1)&(2)

This permit may be reopened and revised under the follow ing circumstances:

1. Additional applicable requirements under the FCAA become applicable to the facility when the permit has a remaining term of 3 or more years. Reopening and revision of the permit shall be completed not later than 18 months after promulg ation of the applicable requirement. No reopening is required under ARM 17.8.1228(1)(a) if the effective date of the applicableOP2589

- 07 81 Date of Decision : 07/08/11

Effective Date: 08/09/11 requirement is later than the date on which the permit is due to expire, unless the original permit or any of its terms or cond itions have been extended pursuant to ARM 17.8.1220(12) or 17.8.1221(2);

2. Additional requirements (including excess emission requirements) become applicable to an affected source under the Acid Rain Program. Upon approval by the administrator, excess

emis sion offset plans shall be deemed incorporated into the permit;

3. The Department or the administrator determines that the permit contains a material mistake or that inaccurate statements were made in establishing the emission standards or other terms or

con ditions of the permit; or

4. The administrator or the Department determines that the permit must be revised or revoked and reissued to ensure compliance with the applicable requirements.

M. Permit Expiration and Renewal ARM 17.8, Subchapter 12, Operating Pe rmit Program §1210(2)(g), §1220(11)&(12), and §1205(2)(d)

1. This permit is issued for a fixed term of 5 years.

2. Renewal of this permit is subject to the same procedural requirements that apply to permit issuance, including those for application, content, pu blic participation, and affected state and

administrator review.

3. Expiration of this permit terminates the permittee’s right to operate unless a timely and administratively complete renewal application has been submitted consistent with ARM

17.8.1221 and 1 7.8.1205(2)(d). If a timely and administratively complete application has been submitted, all terms and conditions of the permit, including the application shield, remain in effect after the permit expires until the permit renewal has been issued or denie d.

4. For renewal, the permittee shall submit a complete air quality operating permit application to the Department not later than 6 months prior to the expiration of this permit, unless otherwise specified. If necessary to ensure that the terms of the exis ting permit will not lapse before renewal, the Department may specify, in writing to the permittee, a longer time period for submission of the renewal application. Such written notification must be provided at least 1 year before the renewal application d ue date established in the existing permit.

N. Severability Clause ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(i)&(l)

1. The administrative appeal or subsequent judicial review of the issuance by the Department of an initial permit under this subchapter shall not impair in any manner the underlying applicability of all applicable requirements, and such requirements continue to apply as if a final permit decision had not been reached by the Department.

2. If any provision of a permit is found to be invalid, all valid parts that are severable from the invalid part remain in effect. If a provision of a permit is invalid in one or more of its applications, the provision remains in effect in all valid applications that are severable from the

invalid applications.OP2589

- 07 82 Date of Decision : 07/08/11

Effective Date: 08/09/11 O. Transfer or Assignment of Ownership ARM 17.8, Subchapter 12, Operating Permit Program §1225(2)&(4)

1. If an administrative permit amendment involves a change in ownership or operational control, the applicant must include in its request t o the Department a written agreement containing a specific date for the transfer of permit responsibility, coverage and liability between the current and new permittee.

2. The permit shield provided for in ARM17.8.1214 shall not extend to administrative perm it

amendments.

P. Emissions Trading, Marketable Permits, Economic Incentives ARM 17.8, Subchapter 12, Operating Permit Program §1226(2)

Notwithstanding ARM 17.8.1226(1) and (7), minor air quality operating permit modification procedures may be used for p ermit modifications involving the use of economic incentives, marketable permits, emissions trading, and other similar approaches, to the extent that such minor permit modification procedures are explicitly provided for in the Montana State Implementation Plan or in applicable requirements promulgated by the administrator.

Q. No Property Rights Conveyed ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(d)

This permit does not convey any property rights of any sort, or any exclusive privilege.

R. Testing Requirements ARM 17.8, Subchapter 1, General Provisions §105

The permittee shall comply with ARM 17.8.105.

S. Source Testing Protocol ARM 17.8, Subchapter 1, General Provisions §106

The permittee shall comply with ARM 17.8.106.

T. Malfunctions ARM 17.8, Subchapter 1, General Provisions §110

The permittee shall comply with ARM 17.8.110.

U. Circumvention ARM 17.8, Subchapter 1, General Provisions §111

The permittee shall comply with ARM 17.8.111.

V. Motor Vehicles ARM 17.8, Subchapter 3, Emis sion Standards §325

The permittee shall comply with ARM 17.8.325.OP2589

- 07 83 Date of Decision : 07/08/11

Effective Date: 08/09/11 W. Annual Emissions Inventory ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation and Open Burning Fees §505 (STATE ONLY)

The permittee shall supply the Department with ann ual production and other information for all emission units necessary to calculate actual or estimated actual amount of air pollutants emitted during each calendar year. Information shall be gathered on a calendar

- year basis and submitted to the Departmen t by the date required in the emission inventory request, unless otherwise specified in this permit. Information shall be in the units required by the Department.

X. Open Burning ARM 17.8, Subchapter 6, Open Burning §604, 605 and 606

The permittee shall comply with ARM 17.8.604, 605 and 606.

Y. Montana Air Quality Permits ARM 17.8, Subchapter 7, Permit, Construction and Operation of Air Contaminant Sources §745 and

764 (ARM 17.8.745(1) and 764(1)(b) are STATE ENFORCEABLE ONLY until approval by the

EPA a s part of the SIP)

1. Except as specified, no person shall construct, install, modify or use any air contaminant source or stack associated with any source without first obtaining a permit from the Department or Board. A permit is not required for those sou rces or stacks as specified by ARM 17.8.744(1)(a)

- (k).

2. The permittee shall comply with ARM 17.8.743, 744, 745, 748, and 764.

3. ARM 17.8.745(1) specifies de minimis changes as construction or changed conditions of operation at a facility holding a Montana A ir Quality Permit (MAQP) issued under Chapter 8 that does not increase the facility’s potential to emit by more than 5 tons per year of any pollutant, except (STATE ENFORCEABLE ONLY until approved by the EPA as part of the SIP):

a. Any construction or change d condition that would violate any condition in the facility’s existing MAQP or any applicable rule contained in Chapter 8 is prohibited, except as provided in ARM 17.8.745(2);

b. Any construction or changed conditions of operation that would qualify as a ma jor modification under Subchapters 8, 9 or 10 of Chapter 8;

c. Any construction or changed condition of operation that would affect the plume rise or dispersion characteristic of emissions that would cause or contribute to a violation of an ambient air quali ty standard or ambient air increment as defined in ARM 17.8.804;

d. Any construction or improvement project with a potential to emit more than 5 tons per year may not be artificially split into smaller projects to avoid Montana Air Quality Permitting;

or

e. Em ission reductions obtained through offsetting within a facility are not included when determining the potential emission increase from construction or changed conditions of operation, unless such reductions are made federally enforceable.OP2589

- 07 84 Date of Decision : 07/08/11

Effective Date: 08/09/11 4. Any facility ma king a de minimis change pursuant to ARM 17.8.745(1) shall notify the Department if the change would include a change in control equipment, stack height, stack diameter, stack gas temperature, source location or fuel specifications, or would result in an

i ncrease in source capacity above its permitted operation or the addition of a new emission unit. The notice must be submitted, in writing, 10 days prior to start up or use of the proposed de minimis change, or as soon as reasonably practicable in the even t of an unanticipated circumstance causing the de minimis change, and must include the information requested in ARM 17.8.745(1) (STATE ENFORCEABLE ONLY until approval by the EPA as part of the SIP).

Z. National Emission Standard for Asbestos 40 CFR, Part 61, Subpart M

The permittee shall not conduct any asbestos abatement activities except in accordance with 40 CFR 61, Subpart M (National Emission Standard for Hazardous Air Pollutants for Asbestos).

AA. Asbestos ARM 17.74, Subchapter 3, General Provision s and Subchapter 4, Fees

The permittee shall comply with ARM 17.74.301, et seq ., and ARM 17.74.401, et seq . (State only)

BB. Stratospheric Ozone Protection

– Servicing of Motor Vehicle Air Conditioners 40 CFR, Part 82, Subpart B

If the permittee perform s a service on motor vehicles and this service involves ozone

- depleting substance/refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements as specified in 40 CFR 82, Subpart B.

CC. Stratospheric Ozone Protection

– Recycling and Emission Reductions 40 CFR, Part 82, Subpart F

The permittee shall comply with the standards for recycling and emission reductions in 40 CFR 82, Subpart F, except as provided for MVACs in Subpart B:

1. Persons opening applia nces for maintenance, service, repair, or disposal must comply with the required practices pursuant to §82.156;

2. Equipment used during the maintenance, service, repair or disposal of appliances must comply with the standards for recycling and recovery equi pment pursuant to §82.158;

3. Persons performing maintenance, service, repair or disposal of appliances must be certified by an approved technical certification program pursuant to §82.161;

4. Persons disposing of small appliances, MVACs and MVAC

- like (as defi ned at §82.152) appliances must comply with recordkeeping requirements pursuant to §82.166;

5. Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to §82.156; and

6. Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to §82.166.OP2589

- 07 85 Date of Decision : 07/08/11

Effective Date: 08/09/11 DD. Emergency Episode Plan

The permittee shall comply with the requirements contained in Chapter 9.7 of the State of Montana Air Quality Control Implementation Plan.

Each major source emitting 100 tons per year located in a Priority I Air Quality Control Region, shall submit to the Department a legally enforceable Emergency Episode Action Plan (EEAP ) that details how the source will curtail emissions during an air pollutant emergency episode. The industrial EEAP shall be in accordance with the Department’s EEAP and shall be submitted according to a timetable developed by the Department, following Pr iority I reclassification.

EE. Definitions

Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this permit, shall have the meaning assigned to them in the referenced regulations.OP2589

- 07 86 Date of Decision : 07/08/11

Effective Date: 08/09/11 APPENDICESOP2589

- 07 A

- 1 Date of Decision : 07/08/11

Effective Date : 08/09/11 APPENDIX A INSI GNIFICANT EMISSION UNITS

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to

assist M2Green , the permitting authority, inspectors, and the public.

Pursuant to ARM 17.8.1201(22)(a), an insignificant emis sion s unit means any activity or emission unit located within a source that: (i) has a potential to emit less than 5 tons per year of any regulated pollutant; (ii) has a potential to emit less than 500 pounds per year of lead; (iii) has a potential to emit less than 500 pounds per year of hazardous air pollutants listed pursuant to Sec

. 7412 (b) of the FCAA; and (iv) is not regulated by an applicable requirement, other than a generally applicable requirement that applies to all emission units subject to Sub chapter 12.

List of Insignificant Activities:

The following table of insignificant sources and/or activities was provided by M2Green . Because there are no requirements to update such a list, the emission units and/or activities may change from those

spe cified in the table.

Emission Unit ID Description

IEU01 Chip Fines to Hog Fuel (& Sawdust Fines)

IEU02 Shower Water Tank Stack

IEU03 Black Liquor Charge Tank

IEU04 Liquor Filter Vent

IEU05 No. 1 Filtrate Tank Vent (SD Filtrate)

IEU06 No. 4 Evaporato r Feed Tank

IEU07 Spill Tank in Batch Area

IEU08 Pins Kamyr Low Pressure Feeder Relief Cyclone

IEU09 M&D Digester Chip Feeder Vent

IEU10 Kamyr Chip Bin Vent

IEU11 Recycled Fiber Bale Storage

IEU12 Turpentine Storage Tank

IEU13 No. 5 Recovery Buildin g Roof Steam Vents

IEU14 Coke Storage Tank

IEU15 No.6 Fuel Oil Tank

IEU16 Dregs Wash Tank

IEU17 No. 1 Green Liquor Clarifier Tank Vents

IEU18 No. 1 Green Liquor Storage Tank Vents

IEU19 No. 2 Green Liquor Clarifier Tank Vents

IEU20 Raw Green Liquor Storage Tank Vent

IEU21 No. 3 Mud Washer Tank Vents

IEU22 No. 1 Mud Washer Tank Vents

IEU23 No. 1 & No. 2 Mud Filter Hood

IEU24 No. 1 Mud Storage Tank

– Serves No. 1 & No. 2 Lime Kilns

IEU25 No. 2 Mud Washer Tank Vent

IEU26 No. 2 Mud Storage Tank

IE U27 No. 3 Kiln Mud Filter Hood

IEU28 No. 3 Lime Kiln Mud Filter Vacuum Pump Exhaust Stack

IEU29 No. 3 Mud Storage Tank Vents

IEU30 No. 4 Lime Kiln Mud Filter Hood

IEU31 No. 4 Lime Kiln Mud Filter Vacuum Pump Exhaust Stack

IEU32 Warehouse/Shipping Dock Roof Vents

IEU33 Diesel Tank Vent

IEU34 Gasoline Tank Vent

IEU35 Paved Road FugitivesOP2589

- 07 B

- 1 Date of Decision : 0708/11

Effective Date : 08/09/11 APPENDIX B DEFINITIONS and ABBREVIATIONS

"Act" means the Clean Air Act, as amended, 42 U.S. 7401, et seq

.

"Administrative permit amendment" means an air quality operating permit revision that:

(a) Corrects typographical errors;

(b) I dentifies a change in the name, address or phone number of any person identified in the air quality operating permit, or identifies a similar minor administrative change at the sourc e;

(c) Requires more frequent monitoring or reporting by M2Green ;

(d) Requires changes in monitoring or reporting requirements that the Department deems to be no less stringent than current monitoring or reporting requirements;

(e) A llows for a change i n ownership or operational control of a source if the Department has determined that no other change in the air quality operating permit is necessary, consistent with ARM 17.8.1225; or

(f) Incorporates any other type of change which the Department has det ermined to be similar to those revisions set forth in (a)

- (e), above.

"Applicable requirement" means all of the following as they apply to emission units in a source requiring an air quality operating permit (including requirements that have been promulga ted or approved by the Department or the administrator through rule making at the time of issuance of the air quality operating permit, but have future

- effective compliance dates, provided that such requirements apply to sources covered under the operating permit):

(a) A ny standard, rule, or other requirement, including any requirement contained in a consent decree or judicial or administrative order entered into or issued by the Department, that is contained in the Montana state implementation plan approv ed or promulgated by the administrator through rule making under Title I of the FCAA;

(b) A ny federally enforceable term, condition or other requirement of any air quality preconstruction permit issued by the Department under Subchapters 7, 8, 9 and 10 of this chapter, or pursuant to regulations approved or promulgated through rule making under Title I of the FCAA, including P arts C and D;

(c) Any standard or other requirement under Sec. 7411 of the FCAA, including Sec. 7411(d);

(d) A ny standard or other requirement under Sec. 7412 of the FCAA, including any requirement concerning accident prevention under Sec. 7412(r)(7), but excluding the contents of any risk management plan required under Sec. 7412(r);

(e) Any standard or other requirement of the acid rain program under Title IV of the FCAA or regulations promulgated thereunder;

(f) Any requirements established pursuant to Sec. 7661c(b) or Sec. 7414(a)(3) of the FCAA;

(g) Any standard or other requirement governing solid waste incineration, under Sec . 7429 of the
FCAA;OP2589

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- 2 Date of Decision : 0708/11

Effective Date : 08/09/11 (h) Any standard or other requirement for consumer and commercial products, under Sec. 7511b(e) of the FCAA;

(i) Any standard or other requirement for tank vessels, under Sec. 7511b(f) of the FCAA;

(j) A ny standard or other requireme nt of the regulations promulgated to protect stratospheric ozone under Title VI of the FCAA, unless the administrator determines that such requirements need not be contained in an air quality operating permit;

(k) A ny national ambient air quality standard or increment or visibility requirement under P art C of Title I of the FCAA, but only as it would apply to temporary sources permitted pursuant to Sec. 7661c(e) of the FCAA; or

(l) Any federally enforceable term or condition of any air quality open burnin g permit issued by the Department under S ubchapter 6.

"Department" means the Montana Department of Environmental Quality.

"Emissions unit" means any part or activity of a stationary source that emits or has the potential to emit any regulated air polluta

nt or any pollutant listed under Sec. 7412(b) of the FCAA. This term is not meant to alter or affect the definition of the term "unit" for purposes of Title IV of the FCAA.

"FCAA" means the Federal Clean Air Act, as amended.

"Federally enforceable" mean s all limitations and conditions which are enforceable by the administrator, including those requirements developed pursuant to 40 CFR Parts 60 and 61, requirements within the Montana state implementation plan, and any permit requirement established pursua nt to 40 CFR 52.21 or under regulations approved pursuant to 40 CFR Part 51, Subpart I, including operating permits issued under an EPA approved program that is incorporated into the Montana state implementation plan and expressly requires adherence to any permit issued under such program.

"Fugitive emissions" means those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening.

"General air quality operating permit" or "general permit" means an ai r quality operating permit that meets the requirements of ARM 17.8.1222, covers multiple sources in a source category, and is issued in lieu of individual permits being issued to each source.

"Hazardous air pollutant" means any air pollutant listed as a h azardous air pollutant pursuant to Sec

. 112(b) of the FCAA.

“Mill Day” means the 24

- hr period from 5:00 am to 5:00 am.

"Non

- federally enforceable requirement" means the following as they apply to emission units in a source requiring an air quality opera ting permit:

(a) A ny standard, rule, or other requirement, including any requirement contained in a consent decree, or judicial or administrative order entered into or issued by the Department, that is not contained in the Montana state implementation pla n approved or promulgated by the administrator through rule making under Title I of the FCAA;OP2589

- 07 B

- 3 Date of Decision : 0708/11

Effective Date : 08/09/11 (b) A ny term, condition or other requirement contained in any air quality preconstruction permit issued by the Department under S ubchapters 7, 8, 9 and 10 of thi s chapter that is not federally enforceable;

(c) Does not include any Montana ambient air quality standard contained in Subchapter 2 of this chapter.

"Permittee" means the owner or operator of any source subject to the permitting requirements of this

sub chapter, as provided in ARM 17.8.1204, that holds a valid air quality operating permit or has submitted a timely and complete permit application for issuance, renewal, amendment, or modification pursuant to this subchapter.

"Regulated air pollutant" means the following:

(a) Nitrogen oxides or any volatile organic compounds;

(b) Any pollutant for which a national ambient air quality standard has been promulgated;

(c) Any pollutant that is subject to any standard promulgated under Sec. 7411 of the FCAA;

(d) A ny Class I or II substance subject to a standard promulgated under or established by Title VI of the FCAA; or

(e) Any pollutant subject to a standard or other requirement established or promulgated under Sec. 7412 of the FCAA, including but not limit ed to the following:

(i) Any pollutant subject to requirements under Sec. 7412(j) of the FCAA. If the administrator fails to promulgate a standard by the date established in Sec

. 7412(e) of the FCAA, any pollutant for which a subject source would be majo r shall be considered to be regulated on the date 18 months after the applicable date established in Sec

. 7412(e) of the FCAA;

(ii) Any pollutant for which the requirements of Sec

. 7412(g)(2) of the FCAA have been met but only with respect to the individ ual source subject to Sec. 7412(g)(2) requirement.

"Responsible official" means one of the following:

(a) For a corporation: a president, secretary, treasurer, or vice

- president of the corporation in charge of a principal business function, or any other person who performs similar policy or

decision

- making functions for the corporation, or a duly authorized representative of such person if the representative is responsible for the overall operation of one or more manufacturing, production, or operating fa cilities applying for or subject to a permit and

either:

(i) The facilities employ more than 250 persons or have gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars); or

(ii) The delegation of authority to such repre sentative is approved in advance by the Department.

(b) For a partnership or sole proprietorship: a general partner or the proprietor; respectively.OP2589

- 07 B

- 4 Date of Decision : 0708/11

Effective Date : 08/09/11 (c) For a municipality, state, federal, or other public agency: either a principal executive officer

or r anking elected official. For the purposes of this part, a principal executive officer of a federal agency includes the chief executive officer having responsibility for the overall operations of a principal geographic unit of the agency (e.g., a regional administrator of the Environmental Protection Agency).

(d) For affected sources: the designated representative in so far as actions, standards, requirements, or prohibitions under Title IV of the FCAA or the regulations promulgated

thereunder are concerne d, and the designated representative for any other purposes under this subchapter.OP2589

- 07 B

- 5 Date of Decision : 0708/11

Effective Date : 08/09/11 Abbreviations:

ARM Administrative Rules of Montana

ASTM American Society of Testing Materials

BACT Best Available Control Technology

BDT bone dry tons

BTU British Thermal Unit

CEMS Continuous Emission Monitoring System

CFC Chlorofluorocarbons

CFR Code of Federal Regulations

CMS Continuous Monitoring System

CO carbon monoxide

COMS Continuous Opacity Monitoring System DEQ Department of Environmental Quality

dscf dry standard cubic foot

dscfm dry standard cubic foot per minute

EEAP Emergency Episode Action Plan

EER Excess Emission Report

EPA U.S. Environmental Protection Agency

EPA Method Test methods contained in 40 CFR 60, Appendix A

ESP Electrostatic Precipitator

EU emission unit

FCAA Federal Clean Air Act

gr grains

HAP hazardous air pollutant

HCFC Hydro

- Chlorofluorocarbons

IEU insignificant emission unit

Mbdft thousand Board feet

MCA Montana Code Annotated

Method 5 40 CFR 60, Appendix A, Method 5

Method 9 40 CFR 60, Appendix A, Method 9

MMbdft million Board feet

MMBTU million British Thermal Units

NO

x oxides of nitrogen

NO 2 nitrogen dioxide

NSPS New Source Performance Standard

O 2 oxygen OCC Old Corrugated Container

ODP Oven Dried Pulp

ODT Oven Dried Ton

ORSAT Name brand of th e analyzer

Pb lead

PM particulate matter

PM 10 particulate matter less than 10 microns in size psi pounds per square inch

RACT Reasonably Available Control Technology

scf standard cubic feet

SIC Source Industrial Classification

SO 2 sulfur dioxide

SO

x oxides of sulfur

tpy tons per year
TRS Total Reduced Sulfur

U.S.C. United States Code

VE visible emissions

VOC volatile organic compoundOP2589

- 07 C

- 1 Date of Decision : 07/08/11

Effective Date : 08/09/11 APPENDIX C NOTIFICATION ADDRESSES

Compliance Notifications:

Montana Department of Environmental Quality Permitting and Co mpliance Division Air Resources Management Bureau

P.O. Box 200901 Helena, MT 59620

- 0901

United States EPA Air Program Coordinator Region VIII, Montana Office

10 W. 15 th Street, Suite 3200 Helena, MT 59626

Permit Modifications:

Montana Department of En vironmental Quality Permitting and Compliance Division Air Resources Management Bureau

P.O. Box 200901 Helena, MT 59620

- 0901

Office of Partnerships and Regulatory Assistance Air and Radiation Program US EPA Region VIII 8P

- AR 1595 Wynkoop Street
Denver, C O 80202

- 1129OP2589

- 07 D

- 1 Date of Decision : 07/08/11

Effective Date : 08/09/11 APPENDIX D AIR QUALITY INSPECTOR INFORMATION

Disclaimer: The information in this appendix is not State or Federally enforceable but is presented to

assist M2Green , permitting authority, inspectors, and the public.

Direction to Plant: The f acility is located at 14377 Pulp Mill Road, Missoula, Montana. This is near Frenchtown, Montana, which is 10 miles northwest of Missoula.

Safety Equipment Required: While on site, safety glasses, steel toed shoes, and ear protection are required. A M2Gr een staff member will cover any other recommended safety instructions prior to entering the plant.

Facility Plot Plan: A copy of the facility plot plan is on file with the Department and was submitted with the application on June 7, 1996.OP2589

- 07 E

- 1 Date of Decision : 07/08/11

Ef fective Date : 08/09/11 APPENDIX E COM PLIANCE ASSURANCE MONITORING (CAM) PLAN

EU011 No. 1 Lime Kiln

– PM and PM 10

Applicable Regulations, Emission Limits, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM 10 288 lbs/day

12.0 lbs/hr Wet Venturi Scrubber

Cur rent Monitoring Requirements: Continuous Parametric Monitoring of wet scrubber l iquid flow rates and venturi differential pressure is required in accordance with 40 CFR 63 Subpart MM should the k iln be operated in the future.

CAM Monitoring

Indicator No . 1 Indicator No. 2 Parametric Monitoring System (PMS) Source Testing Measurement Approach Monitor wet scrubber liquid flow rates and venturi differential pressure Indicator Range Action level will be any block 3

- hour average scrubber liquid flow or v enturi differential pressure outside of the target ranges established for MACT II compliance in accordance with 40 CFR 63 Subpart MM Not Applicable

Corrective Action Audible alarm sounds continuously until operations personnel respond to identify, correc t and document any problem. Not Applicable

Performance Criteria

Collection of Representative Data Scrubber liquid flow meters and differential pressure transmitters will be installed prior to future operation of

the kiln. A source test is a direct me asurement of the particulate emissions. Testing equipment and protocols, calibration methods and frequencies, and analytical methods comply with 40 CFR Part 60, Appendix A.
QA/QC Practices and

Criteria Regularly scheduled audits and preventative

mainten ance will be performed on the flow meters and differential pressure transmitters. Included in source test protocol

Monitoring Frequency Flow rates and differential pressures will be monitored continuously Annual

Data Collection

Procedure 15

- minute, 1

- hour and 3

- hour averages will be calculated using the mill’s PI data historian and programmed Environmental Reporting System Source test reports submitted to Montana DEQ.

Averaging Period Block three

- hour averages In accordance with EPA Method 5OP2589

- 07 E

- 2 Date of Decision : 07/08/11

Ef fective Date : 08/09/11 EU012 No. 2 Lime Kiln

- PM and PM 10

Applicable Regulations, Emission Limits, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM 10 266 lbs/day

11.08 lbs/hr Wet Venturi Scrubber

Current Monitoring Requirements: Continuous Paramet ric Monitoring of wet scrubber liquid flow rates and venturi differential pressure is required in accordance with 40 CFR 63 Subpart MM should the kiln be operated in the future.

CAM Monitoring

Indicator No. 1 Indicator No. 2 Parametric Monitoring Syste m (PMS) Source Testing Measurement Approach Monitor wet scrubber liquid flow rates and venturi differential pressure Indicator Range Action level will be any block 3

- hour average scrubber liquid flow or venturi differential pressure outside of the targe t ranges established for MACT II compliance in accordance with 40 CFR 63

, Subpart MM Not Applicable

Corrective Action Audible alarm sounds continuously until operations personnel respond to identify, correct and document any problem. Not Applicable

Per formance Criteria Collection of Representative

Data Scrubber liquid flow meters and differential pressure transmitters will be installed prior to future operation of the

kiln. A source test is a direct measurement of the particulate emissions. Testing equipment and protocols, calibration methods and frequencies, and analytical methods comply with 40 CFR 60 Appendix A.

QA/QC Practices and Criteria Regularly scheduled audits and preventative maintenance will be performed on the flow meters and

differen tial pressure transmitters. Included in source test protocol

Monitoring Frequency Flow rates and differential pressures will be monitored continuously Annual

Data Collection Procedure 15

- minute, 1

- hour and 3

- hour averages will be calculated using the mill’s PI data historian and programmed Environmental Reporting System Source test reports submitted to Montana DEQ.

Averaging Period Block three

- hour averages In accordance with EPA Method 5OP2589

- 07 E

- 3 Date of Decision : 07/08/11

Ef fective Date : 08/09/11 EU013 No. 3 Lime Kiln

– PM and PM 10

Applicable Regulations, Emission Limits, and Monitoring Requirements

4 Pollutant Emission Limit Control Technology

PM and PM 10 359 lbs/day

14.96 lbs/hour Wet Venturi Scrubber

Current Monitoring Requirements: Continuous Parametric Monitoring of wet scrubber liquid flow rates a nd venturi differential pressure in accorda nce with 40 CFR 63 Subpart MM.

CAM Monitoring

Indicator No. 1 Indicator No. 2 Parametric Monitoring System (PMS) Source Testing Measurement Approach Monitor wet scrubber liquid flow rates and

venturi differen tial pressure Indicator Range Action level will be any block 3

- hour average scrubber liquid flow or venturi differential pressure outside of the target ranges established for MACT II compliance in accordance with 40

CFR 63

, Subpart MM Not Applicable

Co rrective Action Audible alarm sounds continuously until operations personnel respond to identify, correct and document any problem. Not Applicable

Performance Criteria Collection of Representative

Data Scrubber liquid flow meters and differential

pres sure transmitters meeting the requirements of 40 CFR 63, Subpart MM are currently

installed

. A source test is a direct measurement of the particulate emissions. Testing equipment and protocols, calibration methods and frequencies, and analytical methods comply with 40 CFR 60 Appendix A.
QA/QC Practices and Criteria Regularly scheduled audits and preventative maintenance will be performed on the flow meters and differential pressure transmitters. Included in source test protocol

Monitoring Frequency Fl ow rates and differential pressures will be monitored continuously Annual

Data Collection Procedure 15

- minute, 1

- hour and 3

- hour averages will be calculated using the mill’s PI data historian and programmed Environmental Reporting System Source test rep orts submitted to Montana DEQ.

Averaging Period Block three

- hour averages In accordance with EPA Method 5OP2589

- 07 E

- 4 Date of Decision : 07/08/11

Ef fective Date : 08/09/11 EU014

– No. 4 Lime Kiln

– PM and PM 10

Applicable Regulations, Emission Limits, and Monitoring Requirements

40 CFR 60

, Subpart BB

– Standards of Performance for Kraft Pulp Mills

Pollutant Emission Limit Control Technology

PM and PM 10 204.0 lbs/day

8.50 lbs/hour Wet Venturi Scrubber

PM 0.067 gr/dscf corrected to 10% O 2 ( S ubpart BB) Wet Venturi Scrubber

Current Monitoring Requirements: Continuous Parametric Monitoring of wet scrubber liquid flow rates and venturi differential pressure in accordance with 40 CFR 63

, Subpart MM.

CAM Monitoring

Indicator No. 1 Indicator No. 2 Parametric Monitoring System (PMS) Source Testing Measurement Approach Monitor wet scrubber liquid flow rates and venturi differential pressure Source testing for total particulate matter and PM 10 in

accordance with MAQP #2589

- 1 3 Indicator Range Action level will be any block 3

- hour average scrubber liquid flow or venturi di fferential pressure outside of the target ranges established for MACT II compliance in accordance with 40 CFR 63

, Subpart

MM Not Applicable

Corrective Action Audible alarm sounds until operations personnel respond to identify, correct and document any

pr oblem. Not Applicable

Performance Criteria Collection of Representative

Data Scrubber liquid flow meters and differential pressure transmitters meeting the requirements of 40 CFR 63 Subpart MM are currently installed. A source test is a direct measur ement of the particulate emissions. Testing equipment and protocols, calibration methods and frequencies, and analytical methods comply with 40 CFR 60 Appendix A.
QA/QC Practices and

Criteria Regularly scheduled audits and preventative maintenance is pe rformed on the flow meters and differential pressure transmitters. Included in source test protocol

Monitoring Frequency Flow rates and differential pressures are monitored continuously. Annual

Data Collection Procedure 15

- minute, 1

- hour and 3

- hour av erages are calculated using the mill’s PI data historian and programmed Environmental Reporting System Source test reports submitted to Montana DEQ.

Averaging Period Block three

- hour averages In accordance with EPA Method 5OP2589

- 07 E

- 5 Date of Decision : 07/08/11

Ef fective Date : 08/09/11 EU002 No. 4 Recovery Boiler

– P M and PM 10

Applicable Regulations, Emission Limits, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM 10 1253 lbs/day

52.21 lbs/hour Dry Electrostatic Precipitator

Monitoring Requirements: Continuous Opacity Monitori ng System (COMS), Annual Source Testing for Particulate Matter

CAM Monitoring

Indicator No. 1 Indicator No. 2 Opacity Source Testing Measurement Approach Monitor stack opacity using COMS. Indicator Range Action level will be any 1

- hour block averag e opacity of 20% or greater Not Applicable

Corrective Action Audible alarm sounds continuously until operations personnel respond to identify, correct and document any problem. Not Applicable

Performance Criteria

Collection of Representative Data Th e monitoring shall be continuous collecting a reading every 10 seconds to calculate and record each

6

- minute average 6

- minute averages are then used to

calculate a block 1

- hour average opacity A source test is a direct measurement of the particulate emis sions. Testing equipment and protocols, calibration methods and frequencies, and analytical methods comply with 40 CFR 60 Appendix A.
QA/QC Practices and

Criteria Daily zero/span checks, quarterly audits, and annual zero calibrations performed to ensure proper operation Included in source test protocol

Monitoring Frequency Measured continuously, sampled @ 10

- sec intervals. Annual

Data Collection Procedure Six

- minute opacity averages calculated by CEMS Data Acquisition System, 1

- hour block averages ca lculated

and recorded via the mill’s PI data historian Source test reports submitted to Montana DEQ.

Averaging Period One hour In accordance with EPA Method 5OP2589

- 07 E

- 6 Date of Decision : 07/08/11

Ef fective Date : 08/09/11 EU003 No. 5 Recovery Boiler

– PM and PM 10

Note: The No. 5 Recovery Boiler CAM Plan is only applicable when this unit is used for chemical recovery. It is not applicable when the unit is fired solely on natural gas.

Applicable Regulations, Emission Limits, and Monitoring Requirements

40 CFR 60

, Subpart BB

– Standards of Performance for Kraft P ulp Mills

Pollutant Emission Limit Control Technology

PM and PM 10 633.6 lbs/day

26.4 lbs/hour Dry Electrostatic Precipitator

PM 0.044 gr/dscf corrected to 8% O 2 Dry Electrostatic Precipitator

Monitoring Requirements: Continuous Opacity Monitoring Sy stem (COMS), Annual Source Testing for Particulate Matter

CAM Monitoring

Indicator No. 1 Indicator No. 2 Opacity Source Testing Measurement Approach Monitor stack opacity using COMS. Indicator Range Action level will be any 1

- hour block average opac ity of 20% or greater Not Applicable

Corrective Action Audible alarm sounds continuously until operations personnel respond to identify, correct and document any problem. Not Applicable

Performance Criteria

Collection of Representative Data The moni toring shall be continuous collecting a reading every 10 seconds to calculate and record each

6

- minute average. 6

- minute averages will then be used

to calculate a block 1

- hour average opacity. A source test is a direct measurement of the particulate emiss ions. Testing equipment and protocols, calibration methods and frequencies, and analytical methods comply with 40 CFR 60 Appendix A.
QA/QC Practices and

Criteria Daily zero/span checks, quarterly audits, and annual zero calibrations performed to ensure proper operation Included in source test protocol

Monitoring Frequency Measured continuously, sampled @ 10

- sec intervals. Annual

Data Collection Procedure Six

- minute opacity averages calculated by CEMS Data Acquisition System, 1

- hour block aver ages calculated

and recorded via the mill’s PI data historian Source test reports submitted to Montana DEQ.

Averaging Period One hour In accordance with EPA Method 5OP2589

- 07 E

- 7 Date of Decision : 07/08/11

Ef fective Date : 08/09/11 EU016 No. 4 Smelt Dissolving Tank PM and PM 10

Applicable Regulations, Emission Limit s, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM 10 607 lbs/day

25.29 lbs/hour Wet Venturi Scrubber

Current Monitoring Requirements: Continuous Parametric Monitoring of wet scrubber liquid flow rates and venturi diffe rential pressure in accordance with 40 CFR 63

, Subpart MM

CAM Monitoring

Indicator No. 1 Indicator No. 2 Parametric Monitoring System (PMS) Source Testing Measurement Approach Monitor wet scrubber liquid flow rates and venturi differential pressure Indicator Range Action level will be any block 3

- hour average scrubber liquid flow or venturi differential pressure outside of the target ranges established for MACT II compliance in accordance with 40 CFR 63 Subpart MM Not Applicable

Corrective Action A udible alarm sounds until operations personnel respond to identify, correct and document any problem. Not Applicable

Performance Criteria

Collection of Representative Data Scrubber liquid flow meters and differential pressure transmitters meeting the re quirements of 40 CFR 63 Subpart MM are currently installed. A source test is a direct measurement of the particulate emissions. Testing equipment and protocols, calibration methods and frequencies, and analytical methods comply with 40 CFR 60 Appendix A.
QA/QC Practices and

Criteria Regularly scheduled audits and preventative maintenance is performed on the flow meters and differential pressure transmitters. Included in source test protocol

Monitoring Frequency Flow rates and differential pressure s are monitored continuously. Annual

Data Collection Procedure 15

- minute, 1

- hour and 3

- hour averages are calculated using the mill’s PI data historian and programmed Environmental Reporting System Source test reports submitted to Montana DEQ.

Avera ging Period Block three

- hour averages In accordance with EPA Method 5OP2589

- 07 E

- 8 Date of Decision : 07/08/11

Ef fective Date : 08/09/11 EU017 No. 5 Smelt Dissolving Tank PM and PM 10

Applicable Regulations, Emission Limits, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM 10 120 lbs/d ay 5.0 lbs/hour Wet Scrubber

Monitoring Requirements: Continuous Parametric Monitoring of wet scrubber liquid flow rates and venturi differential pressure in

accordance with 40 CFR 63

, Subpart MM

CAM Monitoring

Indicator No. 1 Indicator No. 2

Paramet ric Monitoring System (PMS) Source Testing Measurement Approach Monitor wet scrubber liquid flow rates and venturi differential pressure Indicator Range Action level will be any block 3

- hour average scrubber liquid flow or venturi differential pressure outside of the target ranges established for MACT II compliance in accordance with 40 CFR 63 Subpart MM Not Applicable

Corrective Action Audible alarm sounds until operations personnel respond to identify, correct and document any problem. Not Applicabl e

Performance Criteria

Collection of Representative Data Scrubber alternative CMS as approved by the department will be installed prior to firing Black Liquor in this boiler. A source test is a direct measurement of the particulate emissions. Testing e quipment and protocols, calibration methods and frequencies, and analytical methods comply with 40 CFR 60 Appendix A.
QA/QC Practices and

Criteria Regularly scheduled audits and preventative maintenance is performed on the flow meters and differential pr essure transmitters. Included in source test protocol

Monitoring Frequency Flow rates and differential pressures are monitored continuously. Annual

Data Collection Procedure 15

- minute, 1

- hour and 3

- hour averages are calculated using the mill’ s PI data historian and programmed Environmental Reporting System Source test reports submitted to Montana DEQ.

Averaging Period Block three

- hour averages In accordance with EPA Method 5OP2589

- 07 E

- 9 Date of Decision : 07/08/11

Ef fective Date : 08/09/11 EU021 Multi Fuel Boiler PM

Requirements of this section shall be come applicable 180 days after the effective date of the Operating Permit #OP2589

- 06 (ARM 17.8.1508(4))

.

Applicable Regulations, Emission Limits, and Monitoring Requirements

40 CFR 60

, Subpart D

Pollutant Emission Limit Control Technology

PM 0.1 lb/MMBT U 1249lbs/day

52.04lbs/hour Two (2) parallel Wet Venturi Scrubber

Current Monitoring Requirements: Semi

- Annual Source Testing for Particulate Matter

CAM Monitoring

Indicator No. 1 Indicator No. 2 Scrubber Liquid Flow and

Venturi Differential Pressure Source Testing Measurement Approach Monitor scrubber liquid flow and differential pressure (D/P) at least once every 15 minutes. Indicator Range Action level will be any block 3

- hour average scrubber liquid flow or, block 3

- hour average venturi differe ntial pressure less of less than the target value determined in

accordance with procedures approved by the Department. Not Applicable

Corrective Action Audible alarm sounds until operations personnel respond to identify, correct and document any problem. Not Applicable

Performance Criteria

Collection of Representative Data Scrubber liquid flow meters and differential pressure transmitters meeting the requirements of 40 CFR 63

, Subpart MM will be installed. A source test is a direct measurement of the particulate emissions. Testing equipment and protocols, calibration methods and frequencies, and analytical methods comply with 40 CFR 60 Appendix A.
QA/QC Practices and

Criteria Preventative Maintenance and calibrations of the Scrubber Liquid Flow and Differential Pressure monitors will be performed in accordance with mill standard procedures Included in source test protocol

Monitoring Frequency Measured at least once every 15 minutes and averaged

over a block 3

- hour period. Semi

- Annual

Data Collection Procedure Scrubbing Liquid Flow and Differential Pressure will

be recorded via the mill’s PI data historian Source test reports submitted to Montana DEQ.

Averaging Period Block 3

- hour Period In accordance with EPA Method 5OP2589

- 07 F

- 1 Date of Decision : 07/08/11

Effective Date : 08/09/11 APPENDIX F AMBIEN T AIR MONITORING PLAN

– State

- Only

1. This ambient air monitoring plan is required by Air Quality Permit # OP2589

- 06 , which applies to

M2Green ’s Kraft pulp mill operation located approximately 10 miles northwest of Missoula, Montana. The Department may m odify the requirements of this monitoring plan. All requirements of this plan are considered state

- only enforceable conditions of the permit.

2

. M2Green shall operate and maintain two air monitoring sites in the vicinity of the mill and

facilities. The exact locations of the monitoring sites must be approved by the Department and meet all the siting requirements contained in the Montana Quality Assurance Manual, including revisions; the EPA Quality Assurance Manual, including revisions; and 40 Code of Fe deral Regulations (CFR) Part 58; or any other requirements specified by the Department.

3

. Within 30 days prior to any changes of the location of the ambient monitors, M2Green shall submit a topographic map to the Department identifying UTM coordinates, a ir monitoring site locations in relation to the facility, and the general area present.

4

. M2Green shall continue air monitoring for at least 2 years after installation of the monitor described in Section 2 above. The Department will review the air monit oring data and the Department will determine if continued monitoring or additional monitoring is warranted. The Department may require continued air monitoring to track long

- term impacts of emissions from the facility or require additional ambient air mon itoring or analyses if any changes take place in regard to quality and/or quantity of emissions or the area of impact from the emissions.

5

. M2Green shall monitor the following parameters at the sites and frequencies described below:

AIRS # and UTM

S ite Name Coordinates Code & Parameter Frequency

30

- 063

- 0034 Zone 11 42402 H 2 S 1 Continuous

Moccasin N 520 3200 61101 Wind Speed and Direction Continuous

Lane #1A E 719 000 61106 Standard Deviation of Wind Continuous Direction (sigma theta)

30

- 063

- 0022 Zone 11 42402 H 2 S Continuous

Site #2A N 520 8155

E 712 395

1 H 2 S = hydrogen sulfide.

6

. Data recovery for all parameters shall be at least 80% computed on a quarterly and annual basis. The Department may require continued monitoring if this conditio n is not met. (Data Recovery = (Number of data points collected in evaluation period)/(number of scheduled data points in evaluation period)*(100%))

7

. Any ambient air monitoring changes proposed by M2Green must be approved, in writing, by the Department

.

8

. M2Green shall utilize air monitoring and Quality Assurance (QA) procedures that are equal to or exceed the requirements described in the Montana Quality Assurance Manual, including revisions; the EPA Quality Assurance Manual, including revisions; 40 CFR Parts 50 and 58; and any other requirements specified by the Department.OP2589

- 07 F

- 2 Date of Decision : 07/08/11

Effective Date : 08/09/11 9

. M2Green shall submit two hard copies of quarterly data reports within 45 days after the end of the calendar quarter and two hard copies of the annual data report within 90 day s after the end of the calendar year.

10

. The quarterly data submittals shall consist of a hard copy narrative data summary and a digital submittal of all data points in AIRS batch code format. The electronic data must be submitted to the Air Monitoring Section as digital text files readable by an office PC with a Windows operating system.

The narrative data hard copy summary must be submitted to the Air Compliance Section and

shall include:

a. A hard copy of the individual data points,

b. The first a nd second highest hourly concentrations for H 2 S at each site,

c. The quarterly and monthly wind roses,

d. A summary of the data completeness,

e. A summary of the reasons for missing data,

f. A precision data summary,

g. A summary of any ambient air st andard exceedances, and

h. QA/QC information such as zero/span/precision, calibration, audit forms, and standards

certifications.

1 1

. The annual data report shall consist of a narrative data summary. The narrative data hard copy summary must be submitt ed to the Air Compliance Section and shall include:

a. A topographic map of appropriate scale with UTM coordinates and a true north arrow showing the air monitoring site locations in relation to the mill and facilities and the general area,

b. The year ’s ten highest hourly concentrations for H 2 S at each site,

c. The annual wind rose,

d. A summary of any ambient air standard exceedances, and

e. An annual summary of data completeness.

12

. All records compiled in accordance with this Attachment must be maintained by M2Green as a permanent business record for at least 5 years following the date of the measurement, must be available at the plant site for inspection by the Department, and must be submitted to the Department upon request (ARM 17.8.749).

13

. The Department may audit (or may require M2Green to contract with an independent firm to audit) the air monitoring network, the laboratory performing associated analysis, and any data handling procedures at unspecified times.OP2589

- 07 F

- 3 Date of Decision : 07/08/11

Effective Date : 08/09/11 14

. The hard copy reports s hould be sent to:

Department of Environmental Quality Attention: Air Compliance Section Supervisor

15

. The electronic data from the quarterly monitoring shall be sent to:

Department of Environmental Quality Attention: Air Monitoring Section Superv isor