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 #OP2589-07

Dear Mr. Spizzo:

The Department of Environmental Quality has prepared the enclosed Final Operating Permit #OP2589-

07, for M2Green, located in Missoula, Montana. Please review the cover page of the attached permit for 

information pertaining to the action taking place on Permit #OP2589-07.

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 Management 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 Marxer, Facility Contact Person
OP2589-07 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 OP2589-07

Issued to: M2Green Redevelopment, LLC

P.O. Box 4707

14377 Pulp Mill Road

Missoula, MT 59806-4707

Final 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

Administrative Amendment Application Received: June 10, 2011

AFS Number: 030-063-0006A

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, Chapter 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

Montana 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. FACILITY-WIDE GENERAL.................................................................................................................7

B. MILL-WIDE PERMIT CONDITIONS ...................................................................................................12

SECTION IV. PERMIT CONDITIONS - PULP, CHIP DOCK AND RECYCLED FIBER 

DEPARTMENT........................................................................................................................................14

A. SAWDUST HANDLING, CHIP HANDLING, BIO-MASS CONVEYING, HOG FUEL HANDLING .............14

B. WASHING.........................................................................................................................................18

C. CYCLONES .......................................................................................................................................20

D. MICRO-PULSAIRE BAGHOUSE .........................................................................................................22

E. STORAGE PILES................................................................................................................................23

SECTION V. PERMIT CONDITIONS - POWER, RECOVERY, AND RECAUSTICIZING 

DEPARTMENT........................................................................................................................................24

A. NO. 4 RECOVERY BOILER................................................................................................................24

B. NO. 5 RECOVERY BOILER................................................................................................................29

C. NO. 4 SMELT DISSOLVING TANK.....................................................................................................34

D. NO. 5 SMELT DISSOLVING TANK.....................................................................................................36

E. MULTI-FUEL BOILER .......................................................................................................................38

F. LIME KILNS......................................................................................................................................44

G. LIME SLAKERS.................................................................................................................................50

H. CONDENSATE COLLECTION (40 CFR 63, SUBPART S) ....................................................................53

I. LOW VOLUME, HIGH CONCENTRATION (LVHC) AND HIGH VOLUME, LOW CONCENTRATION 

(HVLC) NON-CONDENSABLE GASES (NCG) (40 CFR 63, SUBPART S) .........................................55

J. STEAM STRIPPER .............................................................................................................................57

K. THERMAL OXIDIZER........................................................................................................................59

L. NATURAL GAS BOILERS ..................................................................................................................62

M. MISCELLANEOUS TANKS/VENT.......................................................................................................63

N. SODA ASH SYSTEM..........................................................................................................................64

SECTION VI. PERMIT CONDITIONS - PAPER MILL DEPARTMENT, ENVIRONMENTAL 

AND TECHNICAL DEPARTMENT, ENGINEERING AND MAINTENANCE DEPARTMENT 66

A. PAPER MACHINES ............................................................................................................................66

B. EU130 – EFFLUENT TREATMENT SYSTEM ......................................................................................68

C. EU120 – ROADS, UNPAVED.............................................................................................................69

D. LIQUID FUEL HANDLING .................................................................................................................70

E. EU152 – CFC RECYCLING...............................................................................................................71

SECTION VII. NON-APPLICABLE REQUIREMENTS...................................................................73

FACILITY-WIDE .......................................................................................................................................73

EMISSION UNITS ......................................................................................................................................73

SECTION VIII. GENERAL PERMIT CONDITIONS........................................................................74

A. COMPLIANCE REQUIREMENTS.........................................................................................................74

B. CERTIFICATION REQUIREMENTS .....................................................................................................74

C. PERMIT SHIELD................................................................................................................................75

D. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS...............................................76

E. PROMPT DEVIATION REPORTING.....................................................................................................77

F. EMERGENCY PROVISIONS................................................................................................................77

G. INSPECTION AND ENTRY..................................................................................................................78

H. FEE PAYMENT..................................................................................................................................78
OP2589-07 iii Date of Decision: 07/08/11

 Effective Date: 08/09/11

I. MINOR PERMIT MODIFICATIONS .....................................................................................................79

J. CHANGES NOT REQUIRING PERMIT REVISION ................................................................................79

K. SIGNIFICANT PERMIT MODIFICATIONS............................................................................................80

L. REOPENING FOR CAUSE...................................................................................................................80

M. PERMIT EXPIRATION AND RENEWAL...............................................................................................81

N. SEVERABILITY CLAUSE ...................................................................................................................81

O. TRANSFER OR ASSIGNMENT OF OWNERSHIP...................................................................................82

P. EMISSIONS TRADING, MARKETABLE PERMITS, ECONOMIC INCENTIVES........................................82

Q. NO PROPERTY RIGHTS CONVEYED..................................................................................................82

R. TESTING REQUIREMENTS ................................................................................................................82

S. SOURCE TESTING PROTOCOL ..........................................................................................................82

T. MALFUNCTIONS...............................................................................................................................82

U. CIRCUMVENTION .............................................................................................................................82

V. MOTOR VEHICLES ...........................................................................................................................82

W. ANNUAL EMISSIONS INVENTORY ....................................................................................................83

X. OPEN BURNING................................................................................................................................83

Y. MONTANA AIR QUALITY PERMITS..................................................................................................83

Z. NATIONAL EMISSION STANDARD FOR ASBESTOS ...........................................................................84

AA. ASBESTOS ........................................................................................................................................84

BB. STRATOSPHERIC OZONE PROTECTION – SERVICING OF MOTOR VEHICLE AIR CONDITIONERS .....84

CC. STRATOSPHERIC OZONE PROTECTION – RECYCLING AND EMISSION REDUCTIONS .......................84

DD. EMERGENCY EPISODE PLAN............................................................................................................85

EE. DEFINITIONS ....................................................................................................................................85

APPENDICES...........................................................................................................................................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 – STATE-ONLY ......................................... F-1
OP2589-07 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 provided 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, Missoula, MT

Responsible Official: Mark Spizzo Phone: (618) 465-7985

Facility Contact Person: Neal Marxer Phone: (406) 626-4451 (ext 848)

Primary SIC Code: 2631

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

Description 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 postconsumer paper sources on the recycling fiber line. Other major processes include raw materials 

handling, steam 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) the 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 limits 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)

EU026h 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 Reject 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 Conveyor 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 Cyclone
OP2589-07 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 Scrubber

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 Scrubbers

EU024 No. 1 Power Boiler

EU101 Ash Handling

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

EU102d 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 

EU102l 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/Practice

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 Liquor 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 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

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

EU110m 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

EU127b 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 Recausticizer 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 Vent
OP2589-07 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 Machine 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 Exhaust

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 Machine 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 Pit 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 Tanks
OP2589-07 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 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

ENGINEERING AND MAINTENANCE DEPARTMENT

EU120 Roads, Unpaved Reasonable Precautions

EU111 Liquid Fuel Handling Reasonable Precautions

EU152 CFC Recycling
OP2589-07 7 Date of Decision: 07/08/11

 Effective Date: 08/09/11

SECTION III. PERMIT CONDITIONS - FACILITY 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/Parameter 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 Opacity 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 Matter 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 * P0.67

or

E = 55 * P0.11- 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 Emissions, 

Petroleum Products

65,000-Gallon Capacity -------

A.13 ARM 17.8.324 Hydrocarbon Emissions, 

Petroleum Products

Oil-effluent Water Separator -------

A.14 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 FossilFuel-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 Kraft, Soda, Sulfite, 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 emission 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 periods 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 “as 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 monitored 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 from 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 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 any stationary 

source shall not exhibit an opacity of 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 precautions 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 control emissions of airborne particulate matter. Such 

emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 

20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this 

permit.

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 excess 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 * P0.67

For process weight rates in excess of 30 tons per hour: E = 55.0 * P0.11– 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 specified 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 submerged 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 absolute 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 with 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 greater 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 Department 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 requirements 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 equipment 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 92 

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 

(40 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 ARM 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 Steam 

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 

requirements 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 may 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 must 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 

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 information and 

belief formed after reasonable inquiry, the statements 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 Section 

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, or 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 

certification 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 Conditions 

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

SO2 Facility Wide 5,000 lb/day Calculate SO2

Source Emission

Daily Monthly

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

B.11, 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

H2S Ambient Air 

Monitoring

(State-Only)

Appendix F Appendix F Appendix F

Conditions

B.1. Total sulfur dioxide (SO2) 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-Only Requirement).

a. At least two analyzers to measure hydrogen sulfide (H2S).

b. At least one wind system. 

c. Sampling sites, data reporting, and parameters to be monitored will be specified by the 

Department. 

Compliance Demonstration

B.4. M2Green shall calculate the daily SO2 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 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 produced) 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).

B.6. M2Green shall operate and maintain the ambient air monitoring program in accordance with 

Appendix F of this permit to monitor compliance with Section III.B.3 (ARM 17.8.204, StateOnly 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 SO2 emissions (in pounds per day) from 

the facility (ARM 17.8.1212).

B.8. M2Green shall 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 SO2 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 

sulfur 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-Only Requirement).

Reporting

B.11. M2Green shall submit a monthly report to the Department 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 SO2 emissions value for the month. 

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 SO2 emissions during 

the period, with all instances of deviations from any permit requirements identified (ARM 

17.8.1212).

B.13. 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 CONDITIONS - 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 Receipts 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.23, A.24, 

A.25

Opacity 20% Method 9 As Required 

by the 

Department

and Section 

III.A.1

Semi-annual

No. 1, 2, and 3 Truck 

Dump Usage

Ongoing Semi-annual

A.2, A.15, 

A.20, 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

Sawdust Handled

PM

PM10

(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

PM10

0.18 lb/ton

0.065 lb/ton

A.5, A.17, 

A.23, A.24, 

A.25

Hog Fuel Handled

PM

PM10

1.0 lb/ton

0.36 lb/ton

A.6, A.17, 

A.23, A.24, 

A.25

Fines – Chip Screen Handled

PM

PM10

0.27 lb/ton

0.09 lb/ton

A.7, A.17, 

A.23, A.24, 

A.25

Fines – Sawdust Screen Handled

PM

PM10

0.75 lb/ton

0.27 lb/ton

A.8, A.17, 

A.23, A.24, 

A.25

Screened Chips to Kamyr Pile

PM

PM10

0.045 lb/ton

0.001 lb/ton

A.9, A.17, 

A.23, A.24, 

A.25

Screened Chips to Batch Pile

PM

PM10

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

PM10

0.09 lb/ton

0.005 lb/ton

A.11, A.18, 

A.21, A.24, 

A.25

Chip Screen & Sawdust Screen 

Fines to Hog Fuel Pile

Operation of 

Target Plate and 

Bunker to Control 

Fugitives

Recordkeeping As Necessary Semi-annual

A.12, A.19, 

A.20, A.24, 

A.25

Quantity of Sawdust Overs Weightometer on 

Sawdust Overs Belt

Maintain & Operate Operate 

During Belt 

Operations

Semi-annual
OP2589-07 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) shall 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 sawdust handled for total particulate and 0.27 lb/ton of 

sawdust handled for PM10 (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: PM10 (total tons) = {(Qty 

Sawdust overs)*(0.065*[1-0.25])/2000+(Qty Sawdust receipts-Qty Sawdust 

overs)*(0.36*[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 restarting 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 PM10 (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 PM10 (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 screen 

handled for total particulate and 0.09 lb/ton (controlled) of fines sent to hog fuel from chip screen 

handled for PM10 (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 fuel from sawdust screen 

handled for total particulate and 0.27 lb/ton (controlled) of fines sent to hog fuel from sawdust 

screen handled for PM10 (M2Green emission estimate) (ARM 17.8.1201(10)).

A.8. M2Green shall be limited to 0.045 lb/ton of screened chips to Kamyr pile handled for total 

particulate and 0.001 lb/ton of screened chips to Kamyr pile handled for PM10 (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 total 

particulate and 0.001 lb/ton of screened chips to batch pile handled for PM10 (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 lb/ton of screened sawdust overs to chip pile handled for PM10 (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)).

Compliance 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 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).

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 shall 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 Source 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 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.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 compliance 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 upon 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.22. M2Green shall maintain, on site, records of the quantity of sawdust overs and sawdust receipts 

and submit calculations to the Department upon request (ARM 17.8.1212).

A.23. All 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

A.24. The semiannual monitoring report shall provide a summary of results of the last source testing 

that was performed (ARM 17.8.1212):

A.25. 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 – No.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

Reporting 

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 washers, 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 

Monitoring 

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 emissions from the brown stock washers, 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 hood 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

PM10

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

PM10

26.4 lb/day

1.1 lb/hr

C.6, C.10, 

C.12, C.14, 

C.15

Sawdust Overs Cyclone

TSP

26.4 lb/day

1.1 lb/hr

C.7, C.10, 

C.12, C.14, 

C.15

Sawdust Overs Cyclone

PM10

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

Semi-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. PM10 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. PM10 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. PM10 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 Cyclones, 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 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).

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. PM10 sampling methods are specified by 40 CFR Part 51, Appendix M. 

Total particulate results may be used as a surrogate for PM10 if the impinger analysis ("backhalf") 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 25th day of each month, M2Green shall total 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 applicable 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

& PM10

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 cause 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 baghouse shall be limited to 22.8 lb/day and 0.95 

lb/hr (ARM 17.8.1201(10)). 

D.3. PM10 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 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.D.1. 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).

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. PM10 sampling methods are 

specified by 40 CFR Part 51, Appendix M. Total particulate results may be used as a surrogate 

for PM10 if the impinger analysis ("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 

accordance 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 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 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 Handling & 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 Demonstration

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 certification 

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 Compliance Demonstration

Method Frequency

Reporting 

Requirements

A.1, A.13, 

A.24, A.33, 

A.36

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% O2 

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.35, 

A.36

PM10 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.25, A.35, 

A.36

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.16, 

A.27, A.35, 

A.36

Total Reduced Sulfur CEM Operate and Maintain Ongoing Semi-annual

A.7, A.17, 

A.18, A.26, 

A.28, A.33, 

A.36

TSP 928 lb/Day –

Monthly Average

COM Data & 

Correlation Equations

Monthly Monthly

A.8, A.19, 

A.29, A.35, 

A.36

Correlation Equations Proposed Changes Request Department 

Approval

As 

Necessary

Semi-annual

A.9, A.18, 

A.20, A.26, 

A.34, A.36

Opacity 20% COM Ongoing Monthly

A.10, A.21, 

A.30, A.34, 

A.35, A.36

Opacity COM Operate and Maintain Ongoing Semi-annual

EER Reports As 

Necessary

Quarterly

A.11, A.22, 

A.31, A.35, 

A.36

Particulate Emissions Operate and Maintain 

ESP

Recordkeeping As 

Necessary

Semi-annual

A.12, A.23, 

A.32, A.35, 

A.36

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/dscf) corrected to 8% Oxygen (O2) 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. PM10 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 per 

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 (COMS) shall be operated and maintained on the No. 4 

Recovery Boiler (ARM 17.8.1201(10)).

A.11. M2Green shall operate and maintain an electrostatic precipitator (ESP) on the No. 4 Recovery 

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 

Monitoring (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 17.8.1213).

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. PM10 sampling methods are specified by 40 CFR Part 51, 

Appendix M. Total particulate results may be used as a surrogate for PM10 if the impinger 

analysis ("back-half") is included. M2Green shall test the No. 4 Recovery Boiler for total 

particulate and PM10 at 90% or greater of maximum rated 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 below 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. Monitoring compliance with the Section V.A.5 shall be determined by EPA source sampling 

methods 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 approved by 

the Department (ARM 17.8.1213).

A.16. The TRS CEM is not required to conform 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.17. Monthly emissions shall be determined by continuous opacity 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.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.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 reason to believe that COMS data is not accurate 

or when COMS data is unavailable (ARM 17.8.321(15)).

A.21. The COMS are required to conform to federal specifications. The COMS are required to provide 

a daily (mill day) average opacity reading to monitor compliance with Section V.A.10 (ARM 

17.8.749 and ARM 17.8.1213).

A.22. 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 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).

A.23. M2Green shall monitor compliance with Section V.A.12 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

A.24. The record of the daily black liquor firing rate for the No. 4 Recovery Boiler shall be maintained 

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

A.25. 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.26. 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.27. M2Green shall operate and maintain the TRS CEM and records shall be submitted to the 

Department upon request (ARM 17.8.1212).

A.28. The opacity monitors required to monitor compliance with SectionV.A.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 between opacity and particulate emissions. 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).

A.29. M2Green shall maintain records of all supporting 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.A.19.

A.30. The COMS shall be operated and maintained and records shall be submitted to the Department 

upon request to monitor compliance with the opacity limitation (ARM 17.8.1212).

A.31. M2Green shall maintain records required by Section V.A.22 on site and submit the information to 

the Department upon request (ARM 17.8.1212).

A.32. 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.33. 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.34. 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 emissions. 
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 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.

A.35. 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.36. 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 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.35, B.38

Black Liquor Firing 

Rate

Daily Rate Maintain Log Daily Monthly

B.2, B.15, B.16, 

B.26, B.27, B.37, 

B.38

TSP 0.044gr/dscf 

corrected to 8% O2

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.37, B.38

PM10 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.37, B.38

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.35, B.37, 

B.38

Total Reduced 

Sulfur

≤ 5 ppm corrected to 

8% O2,

12-hr Average

CEM Ongoing Monthly

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

B.36, B.37, B.38

Total Reduced 

Sulfur

CEM Operate and Maintain Ongoing Semi-annual

EER Reports As Necessary Quarterly

B.7, B.18, B.29, 

B.35, B.38

TSP 384 lb/Day – Monthly 

Average

COM Data & 

Correlation Equations

Monthly Monthly

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

B.37, B.38

Correlation 

Equations

Proposed Changes Request Department 

Approval

As Necessary Semi-annual

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

B.35, B.38

Opacity 20% COM

Method 9

Ongoing Monthly

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

B.37, B.38

Opacity COM Performance 

Specification 1 in 40 

CFR Part 60, 

Appendix B

Ongoing Semi-annual

B.11, B.22, B.32, 

B.37, B.38

Particulate 

Emissions

Operate and Maintain 

ESP

Recordkeeping As Necessary Semi-annual

B.12, B.23, B.33, 

B.36, B.37, B.38

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.34, 

B.37, B.38

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% O2 (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. PM10 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 No. 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 atmosphere 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 17.8.321).

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 ESP 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 notification 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. M2Green 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. PM10 sampling 

methods are specified by 40 CFR Part 51, Appendix M or total particulate results may be used as a 

surrogate for PM10 if the impinger analysis ("back-half") is included. M2Green shall test the No. 5 

Recovery Boiler for total particulate and PM10 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, Appendix 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, then 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 installed, 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 60, 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 believe 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 set 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 according 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 Montana 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 supporting 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.33. M2Green shall maintain records in accordance with 40 CFR 60, Subpart BB (ARM 17.8.340 and 

40 CFR 60, Subpart BB).

B.34. 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

B.35. 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 of 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 calculated grain 

loading (gr/dscf), air flow (dscfm), total particulate (lb/hour), and the 24-hour average 

opacity. M2Green shall report percent O2 and grain loading (gr/dscf) corrected for O2.

e. M2Green shall provide a summary of opacities from the No. 5 Recovery 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.36. Quarterly, M2Green shall submit excess emission reports for the CEM and 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 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 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.37. 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.

B.38. 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 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

Reporting 

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

PM10 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 

Emissions 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. PM10 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 

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

C.6. 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.C.1. Each observation period shall be a minimum of 6 minutes unless 
OP2589-07 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 shall be accomplished by EPA source sampling methods specified in 40 CFR 

Part 60, Appendix A. PM10 sampling methods are specified by 40 CFR Part 51, Appendix M. 

Total particulate results may be used as a surrogate for PM10 if the impinger analysis ("backhalf") 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 Appendix 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 Department 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 20% 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.16, 

D.17

PM10 120 lb/Day

5.00 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 

Report)

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 particulate 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. PM10 emissions from the No. 5 Smelt Dissolving Tank shall not exceed 120 lb/day and 5.00 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. 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 EF 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 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).

D.8. Annually, monitoring 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. PM10

sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may 

be used as a surrogate for PM10 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 maintained 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 compliance 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 with 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 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).

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 results 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 Boiler

EU021 – Multi-fuel Boiler

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

E.1, E.21, E.35, 

E.48, E.49

Opacity 20% Method 9 As Required by 

the Department

and Section 

III.A.1

Semi-annual

E.2, E.22, E.36, 

E.46, E.49

Steam 

Production

Daily Production Maintain Log Daily Monthly

E.3, E.23, E.37, 

E.48, E.49

Dewatered 

Sludge 

Consumption

21,900 ton/yr Maintain a 

Production Log 

Daily Logging Semi-annual

E.4, E.24, E.38, 

E.48, E.49

Dewatered 

Sludge

≤ 0.4% Sulfur Content Sulfur Analysis Annually Semi-annual

E.5, E.25, 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

Thoroughly Blended w/ 

Existing Hog Fuel

Recordkeeping As Necessary Semi-annual

E.7, E.26, E.40, 

E.48, E.49

pH of 

Scrubber 

Water

pH Maintained > 7 pH check Weekly Semi-annual

E.8, E.24, E.37, 

E.38, E.48, E.49

SO2 from 

combustion of 

primary 

clarifier sludge

5.70 lb/hr Dewatered sludge 

consumption/sulfur 

content

Daily/

Annually

Semi-annual

E.9, E.27, E.35, 

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.27, E.35, 

E.48, E.49

PM10 0.1 lb/MMBtu

52.04 lb/hr

1,249 lb/Day

40 CFR Part 51, 

Appendix M

Annually Semi-annual

E.11, E.28, E.41, 

E.47, E.48, E.49

SO2 0.80 lb/MMBtu

429.6 lb/hr Firing Liquid 

Fossil Fuel or Liquid Fossil 

Fuel & Wood Residue

CEMs Ongoing Quarterly

E.12, E.28, E.30, 

E.35, E.41, E.47, 

E.48, E.49

NOx 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

SO2 CEM 40 CFR 60 Appendix 

B Specification 2

Ongoing Semi-annual

E.14, E.28, E.41, 

E.48, E.49

NOx CEM 40 CFR 60 Appendix 

B Specification 2

Ongoing Semi-annual

E.15, E.29, E.41, 

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

SO2 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-annual
OP2589-07 39 Date of Decision: 07/08/11

 Effective Date: 08/09/11

E.17, E.31, E.42, 

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.32, E.43, 

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 Ongoing Semi-annual

E.19, E.33, E.44, 

E.48, E.49

Multi-fuel 

Boiler

Operate and Maintain two wet 

venturi scrubbers, in parallel

Recordkeeping Weekly Semi-annual

E.20, E.34, E.45, 

E.48, E.49

CAM Plan CAM Plan Appendix E CAM Plan Appendix 

E

Ongoing Semi-annual

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 hour 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 sludge 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 SO2 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 British thermal units (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. PM10 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 (NO2) 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. NO2 emissions from the 

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

consecutive hours. (ARM 17.8.340 and 40 CFR 60, Subpart D).
OP2589-07 40 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 fired on oil (ARM 17.8.1201(10)).

E.14. A nitrogen oxides CEM is required by federal regulation 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 Boiler 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 notification 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 17.8.340 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 and maintain two wet venturi scrubbers, operated in parallel, on the Multifuel 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.20. 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

E.21. 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 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, whichever is a shorter period of time (ARM 

17.8.105 and ARM 17.8.1213).

E.22. 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.23. M2Green shall maintain a log of the consumption of dewatered sludge by the Multi-fuel Boiler to 

monitor compliance with Section V.E.3 (ARM 17.8.1213).

E.24. 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.25. M2Green shall document whenever dewatered sludge used as fuel for the Multi-fuel Boiler 

originated 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.26. M2Green shall conduct weekly pH checks on the scrubber to monitor compliance with Section 

V.E.7 (ARM 17.8.1213).

E.27. 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. PM10

sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may 

be used as a surrogate for PM10 if the impinger analysis ("back-half") is included. M2Green shall 

test the Multi-fuel Boiler for total particulate and PM10 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.28. 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 daily calibration drift test is

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 dioxide 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 is 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.30. As required by the Department and Section III.A.1, M2Green shall conduct Method 7 and 

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

E.31. 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.32. M2Green shall maintain a log of the amount of waste plastic that is transported to the hog fuel 

pile on a daily basis. By the 25th 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, weekly, scrubber 

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

E.34. M2Green shall monitor compliance with Section V.E.20 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.35. 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 42 Date of Decision: 07/08/11

 Effective Date: 08/09/11

E.36. 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.37. M2Green shall maintain records of the daily consumption of dewatered sludge off the press, 

including records of sludge plant flow rates and sludge solids 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 maintain the records required by Section V.E.25 on site and submit the 

information to the Department upon request (ARM 17.8.1212).

E.40. 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.41. 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.42. M2Green shall maintain records in accordance with 40 CFR 60, Subpart D (ARM 17.8.340 and 

40 CFR 60, Subpart D).

E.43. The log of the waste plastic as required by Section V.E.32 shall be maintained on site and 

submitted to the Department upon request (ARM 17.8.1212).

E.44. M2Green shall maintain records required by Section V.E.33 on site and submit the information to 

the Department upon request (ARM 17.8.1212).

E.45. 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.46. 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 the Multi-fuel Boiler; and

b. The 3-hour averages for SO2 and NOx (as lb/MMBtu) as specified by federal regulations 

for the Multi-fuel Boiler.

E.47. Quarterly, M2Green shall submit excess emission reports for NOx and SO2 continuous emission 

monitors required 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 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.

E.48. The semiannual monitoring report shall provide (ARM 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 maximum 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.42

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.33, F.41, 

F.42

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.33, F.41, 

F.42

No. 1 Lime Kiln TSP 0.064 gr/dscf 

Corrected to 

10% O2 

288 lb/Day

12.0 lb/hr

40 CFR Part 60, 

Appendix A & 

40 CFR Part 51, 

Appendix M

Once every two 

years

Semi-annual

F.4, F.25, 

F.33, F.41, 

F.42

No. 1 Lime Kiln PM10 288 lb/Day

12.0 lb/hr

F.5, F.25, 

F.33, F.41, 

F.42

No. 1 Lime Kiln Total 

Sulfate

259 lb/Day

10.79 lb/hr

F.6, F.25, 

F.28, F.33, 

F.35, F.39, 

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.41, 

F.42

No. 2 Lime Kiln TSP 0.064 gr/dscf 

Corrected to 

10% O2

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.33, F.41, 

F.42

No. 2 Lime Kiln PM10 266 lb/Day

11.08 lb/hr

F.9, F.25, 

F.33, F.41, 

F.42

No. 2 Lime Kiln Total 

Sulfate

239 lb/Day

9.96 lb/hr

F.10, F.25,

F.28, F.33, 

F.35, F.39, 

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.33, 

F.41, F.42

No. 3 Lime Kiln TSP 0.064 gr/dscf 

Corrected to 

10% O2

359 lb/Day

14.96 lb/hr

40 CFR Part 60, 

Appendix A & 

40 CFR Part 51, 

Appendix M

Once every two 

years

Semi-annual

F.12, F.25, 

F.33, F.41, 

F.42

No. 3 Lime Kiln PM10 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/hr
OP2589-07 45 Date of Decision: 07/08/11

 Effective Date: 08/09/11

F.14, F.25,

F.28, F.33, 

F.35, F.39, 

F.42

No. 3 Lime Kiln Total 

Reduced 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.42

No. 4 Lime Kiln TSP 0.064 gr/dscf 

Corrected to 

10% O2

204.0 lb/Day

8.50 lb/hr

40 CFR Part 60, 

Appendix A & 

40 CFR Part 51, 

Appendix M & 

40 CFR Part 60, 

Subpart BB

Once every two 

years

Semi-annual

F.16, F.26, 

F.33, F.41, 

F.42

No. 4 Lime Kiln PM10 204.0 lb/Day

8.50 lb/hr

F.17, F.26, 

F.33, F.41, 

F.42

No. 4 Lime Kiln Total 

Sulfate

204.0 lb/Day

8.50 lb/hr

F.18, F.26, 

F.35, F.39, 

F.42

No. 4 Lime Kiln Total 

Reduced Sulfur

≤8.0 ppm 12-hr 

Average

CEM Ongoing w/ 12-

hr Averages

Monthly

F.19, F.29, 

F.35, F.41, 

F.42

TRS – No. 1, 2, & 3 

Lime Kilns

CEM by State 

Permit

Operate and 

Maintain

Ongoing Semi-annual

F.20, F.30, 

F.36, F.41, 

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 Reports As Necessary Quarterly

F.22, F.27, 

F.34, F.41, 

F.42

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.41, 

F.42

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 consecutive 

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% O2 (ARM 17.8.342 and 40 CFR 63, Subpart MM) and, in no case, shall exceed 

288 lb/day and 12.0 lb/hr (ARM 17.8.1201(10)). 
OP2589-07 46 Date of Decision: 07/08/11

 Effective Date: 08/09/11

F.4. PM10 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% O2 (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. PM10 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 the 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% O2 (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. PM10 emissions from the No. 3 Lime Kiln shall not exceed 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 exceed 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 O2 (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. PM10 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 204.0 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% O2, 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 reporting, 

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 limited 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 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.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 two 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. PM10 sampling methods are specified by 40 

CFR Part 51, Appendix M, including back-half particulate. Total particulate results may be used 

as a surrogate for PM10 if the impinger analysis ("back-half") is included (ARM 17.8.1213).

F.26. Once every two years, monitoring compliance with the Section V.F.15 through F.17 standards 

shall be accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix 

A and Subpart BB. PM10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total 

particulate results may be used as a surrogate for PM10 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, 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 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 Sections 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 approved 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 required 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 daily 

calibration drift test is 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, Subpart BB (ARM 17.8.340 and 

40 CFR 60, Subpart BB).

F.32. 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.33. 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.34. 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.35. 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.36. M2Green shall maintain the records for the CEMs on site and submit them to the Department in 

accordance with 40 CFR Part 60, Appendix B, Specification 5 (ARM 17.8.1212).

F.37. M2Green shall maintain records in accordance with 40 CFR 60, Subpart BB (ARM 17.8.340 and 

40 CFR 60, Subpart BB).

F.38. 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

F.39. 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 report 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 adopted.

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 information shall be stated in the report. 

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

Department.

F.41. The semiannual monitoring report shall provide a summary of results of the last source testing 

that was performed (ARM 17.8.1212).

F.42. 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. Lime 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 PM10 110 lb/day

4.58 lb/hr

G.5, G.13, 

G.15, G.17, 

G.18

No. 2 Lime Slaker TSP 146 lb/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 PM10 146 lb/day

6.08 lb/hr

G.7, G.13, 

G.15, G.17, 

G.18

No. 3 Lime Slaker 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.13, 

G.15, G.17, 

G.18

No. 3 Lime Slaker PM10 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. PM10 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 Slaker shall not exceed 146 lb/day 

and 6.08 lb/hr (ARM 17.8.752).

G.6. PM10 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. PM10 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 

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).

G.12. Annually, monitoring compliance with the above Section V.G.3 and G.4 standards shall be 

accomplished by EPA source sampling methods specified in 40 CFR Part 60, Appendix A. PM10

sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate results may 

be used as a surrogate for PM10 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 Part 60, Appendix A. PM10 sampling methods are specified by 40 

CFR Part 51, Appendix M. Total particulate results may be used as a surrogate for PM10 if the 

impinger analysis ("back-half") is included (ARM 17.8.1213).

G.14. M2Green shall monitor compliance 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 activities to the wet 

scrubbers and baghouse. The records must include, but are not limited to, the date, time, and action(s) 

taken for repair and maintenance (ARM 17.8.1213).

Recordkeeping

G.15. 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 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 – Condensate 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 Condensate)

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 

Condenser)

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 

Condensate

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-annual

(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 63.446(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) on a 60-day rolling average (ARM 17.8.342 

and 40 CFR 63.446(c)(3)(d)). 

Compliance Demonstration
OP2589-07 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 (ARM 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 produced) 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 inspect the closed drain system’s integrity at least once each calendar 

month for leaks to monitor 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 years 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 subsequent 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 submitted 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, 

equipment 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. The 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 

statement 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 Gases (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 Condenser 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

EU154c - Steam 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 Vent 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 

HVLC-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 integrity 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 within 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 demonstrations 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 monitoring 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 compliance 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 

Average

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 events)

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, concentration, 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 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 92 percent (by weight) of methanol per oven-dried ton pulp criteria (ARM 17.8.342 

and 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 semi-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 monitor compliance with Section V.J.1

(ARM 17.8.1213).

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 direct 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. M2Green

shall determine the methanol treatment on a 60-day rolling average to monitor compliance with 
OP2589-07 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 the following parameters for methanol removal 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 condensate) 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 treatment 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 by 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 Scrubber 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 Offgas and Combined 

LVHC NCG and 

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.17, 

K.18

Particulate Matter 0.10 gr/dscf 

Corrected to 10% 

O2

Method 5 As Required by the 

Department and 

Section III.A.1

Semi-annual

Conditions

K.1. LVHC-NCG and HVLC-NCG shall be routed to the Thermal Oxidizer for combustion of 

hazardous air pollutants and oxidation of reduced sulfur compounds. If the Thermal Oxidizer is 

unavailable, combustion of the LVHC-NCG in the No. 3 Lime 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 Thermal 

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 noncondensable 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 venting, from the combined LVHC-NCG, HVLC-NCG, and steam 

stripper off-gas, 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 Thermal 

Oxidizer, 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 authorize to be discharged into the atmosphere from the Thermal 

Oxidizer, any particulate matter emissions in excess of 0.10 gr/dscf corrected to 10% O2 (ARM 

17.8.752).

Compliance Demonstration

K.7. M2Green shall document, on a 15-minute basis, all instances that 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 Oxidizer to monitor compliance with 

Section V.K.1 (ARM 17.8.1213).

K.8. Annually, M2Green shall audit the Thermal Oxidizer 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 basis (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. These 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 submit 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 the 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 required 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 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 61 Date of Decision: 07/08/11

 Effective Date: 08/09/11

Reporting

K.17. 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. The lowest daily average Thermal Oxidizer temperature and lowest thermal residence 

time during the period.

K.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 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 Compliance 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 Power 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 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

L.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

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. Miscellaneous 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 Demonstration

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 Tanks/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 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

M.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

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

EU040– 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-annual

N.2, N.5, N.8,

N.9, N.10

PM/PM10 Controlled with a 

bin vent dust 

collector

Recordkeeping As Necessary Semi-annual

N.3, N.6, N.7,

N.9, N.10

PM/PM10 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/PM10 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/PM10 emissions from the soda ash storage silo and associated pneumatic 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 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).

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 date, 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, Appendix 

A. PM10 sampling methods are specified by 40 CFR Part 51, Appendix M. Total particulate 

results may be used as a surrogate for PM10 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 Machine 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 ADP/ 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 consecutive 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 mill, 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 reading 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 25th

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 rolling 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 and 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 submitted 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 (ARM 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 summary 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 required 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) Pollutant/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 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).

Recordkeeping

B.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

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 

statement 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 control 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 shall 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 compliance 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 Compliance 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 emissions 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 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

D.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

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 Refrigeration 

Equipment

No Venting CFCs and 

HCFCs

Compliance 

in 

Accordance 

w/ 40 CFR 

Part 82

As 

Necessary

Semi-annual

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 Recycling 

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-Enforceable Only).

E.2. Recycling equipment manufactured after November 15, 1993, must be tested by an EPAapproved 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-Enforceable 

Only).

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; EPAEnforceable Only).

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-Enforceable Only).

E.5. M2Green shall comply with the mandatory recycling technician certification (40 CFR 82.161; 

EPA-Enforceable Only).

Compliance Demonstration

E.6. M2Green shall monitor compliance in accordance with 40 CFR Part 82 (40 CFR Part 82; EPAEnforceable Only).

Recordkeeping

E.7. M2Green 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).

Reporting
OP2589-07 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 applicable 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 permit 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 which 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, Subpart 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.

Emission 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 requirements 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 conditions 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 permit 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 appropriate, 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 Department 

(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 required 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 information 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 applicable 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 term 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, consistent 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 Department, 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-federally 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 an 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 Montana Clean Air Act, Title 75, 

Chapter 2, MCA; and
OP2589-07 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 reasonably 

available control technology (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 submitting 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 is 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 will 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, Recordkeeping, 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 conditions 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. Support 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 reports 

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 original 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 monitoring 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 for 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 Program §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 limitations:

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 deviation 

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 reporting 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).

Prompt 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 technologybased 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 reasonable 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 properly 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 the 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 emergency 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 following:

a. Enter the premises where a source required to obtain a permit is located or emissionsrelated 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 must 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 authorized 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 shall 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, Chapter 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 assessment is appealed pursuant to ARM 17.8.511. If any 
OP2589-07 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 immediately 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 under 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 require 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 emissions 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 the 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 enforceability 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 notice 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 terms 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 the 

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 affected 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, supplementation 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 following 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 promulgation of the applicable requirement. No 

reopening is required under ARM 17.8.1228(1)(a) if the effective date of the applicable 
OP2589-07 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 conditions 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 

emission 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 

conditions 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 Permit 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, public 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 17.8.1205(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 denied.

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 existing 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 due 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 to 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 permit 

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 permit 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, Emission 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 annual 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 Department 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 as 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 sources 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 Air 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 changed 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 major 

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 quality 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. Emission 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 making 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 

increase 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 event 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 Provisions 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 performs 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 appliances 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 equipment 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 defined 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 Priority 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

APPENDICES
OP2589-07 A-1 Date of Decision: 07/08/11 

Effective Date: 08/09/11

APPENDIX A INSIGNIFICANT 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 emissions 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 Subchapter 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 

specified 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 Evaporator 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 Building 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

IEU27 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 Fugitives 
OP2589-07 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) Identifies 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 source;

(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) Allows for a change in 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 determined 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 promulgated 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) Any 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 approved or promulgated by the 

administrator through rule making under Title I of the FCAA;

(b) Any 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 Parts C and D;

(c) Any standard or other requirement under Sec. 7411 of the FCAA, including Sec. 7411(d);

(d) Any 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;
OP2589-07 B-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) Any standard or other requirement 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) Any national ambient air quality standard or increment or visibility requirement under Part 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 burning permit issued by 

the Department under Subchapter 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 pollutant 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" means 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 pursuant 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 air 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 hazardous 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 operating permit:

(a) Any 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 plan 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) Any term, condition or other requirement contained in any air quality preconstruction permit 

issued by the Department under Subchapters 7, 8, 9 and 10 of this 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 

subchapter, 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) Any 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 limited 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 major 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 individual 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 facilities 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 representative 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 ranking 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 concerned, 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

NOx oxides of nitrogen

NO2 nitrogen dioxide

NSPS New Source Performance Standard

O2 oxygen

OCC Old Corrugated Container

ODP Oven Dried Pulp

ODT Oven Dried Ton

ORSAT Name brand of the analyzer

Pb lead

PM particulate matter

PM10 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

SO2 sulfur dioxide

SOx oxides of sulfur

tpy tons per year

TRS Total Reduced Sulfur

U.S.C. United States Code

VE visible emissions

VOC volatile organic compound
OP2589-07 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 Compliance 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. 15th Street, Suite 3200

Helena, MT 59626

Permit Modifications:

Montana Department of Environmental 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, CO 80202-1129
OP2589-07 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 facility 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 M2Green 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

 Effective Date: 08/09/11 

APPENDIX E COMPLIANCE ASSURANCE MONITORING (CAM) PLAN

EU011 No. 1 Lime Kiln – PM and PM10

Applicable Regulations, Emission Limits, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM10 288 lbs/day

12.0 lbs/hr

Wet Venturi Scrubber

Current Monitoring Requirements: Continuous Parametric 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 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 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 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 Part 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 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 5 
OP2589-07 E-2 Date of Decision: 07/08/11

 Effective Date: 08/09/11 

EU012 No. 2 Lime Kiln -PM and PM10

Applicable Regulations, Emission Limits, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM10 266 lbs/day

11.08 lbs/hr

Wet Venturi Scrubber

Current Monitoring Requirements: Continuous Parametric 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 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 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 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 

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 5 
OP2589-07 E-3 Date of Decision: 07/08/11

 Effective Date: 08/09/11 

EU013 No. 3 Lime Kiln – PM and PM10

Applicable Regulations, Emission Limits, and Monitoring Requirements

4Pollutant Emission Limit Control Technology

PM and PM10 359 lbs/day

14.96 lbs/hour

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

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 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 

pressure 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 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 5 
OP2589-07 E-4 Date of Decision: 07/08/11

 Effective Date: 08/09/11 

EU014 – No. 4 Lime Kiln – PM and PM10

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 PM10 204.0 lbs/day

8.50 lbs/hour

Wet Venturi Scrubber

PM 0.067 gr/dscf corrected to 10% O2 (Subpart 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 PM10 in 

accordance with MAQP #2589-13

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 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 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 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 5 
OP2589-07 E-5 Date of Decision: 07/08/11

 Effective Date: 08/09/11 

EU002 No. 4 Recovery Boiler – PM and PM10

Applicable Regulations, Emission Limits, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM10 1253 lbs/day

52.21 lbs/hour

Dry Electrostatic Precipitator

Monitoring Requirements: Continuous Opacity Monitoring 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 average 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

The 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 emissions. 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 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 5 
OP2589-07 E-6 Date of Decision: 07/08/11

 Effective Date: 08/09/11 

EU003 No. 5 Recovery Boiler – PM and PM10

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 Pulp Mills

Pollutant Emission Limit Control Technology

PM and PM10 633.6 lbs/day

26.4 lbs/hour

Dry Electrostatic Precipitator

PM 0.044 gr/dscf corrected to 8% O2 Dry Electrostatic Precipitator

Monitoring Requirements: Continuous Opacity Monitoring 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 average 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

The monitoring 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 emissions. 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 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 5 
OP2589-07 E-7 Date of Decision: 07/08/11

 Effective Date: 08/09/11 

EU016 No. 4 Smelt Dissolving Tank PM and PM10

Applicable Regulations, Emission Limits, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM10 607 lbs/day

25.29 lbs/hour

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

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 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 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 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 5 
OP2589-07 E-8 Date of Decision: 07/08/11

 Effective Date: 08/09/11 

EU017 No. 5 Smelt Dissolving Tank PM and PM10

Applicable Regulations, Emission Limits, and Monitoring Requirements

Pollutant Emission Limit Control Technology

PM and PM10 120 lbs/day

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

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 Audible alarm sounds until operations personnel 

respond to identify, correct and document any problem. 

Not Applicable

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 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 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 5 
OP2589-07 E-9 Date of Decision: 07/08/11

 Effective Date: 08/09/11 

EU021 Multi Fuel Boiler PM

Requirements of this section shall become 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/MMBTU

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 differential 

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 5 
OP2589-07 F-1 Date of Decision: 07/08/11

Effective Date: 08/09/11 

APPENDIX F AMBIENT 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 modify 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 Federal 

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, air 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 monitoring 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 monitoring 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

Site Name Coordinates Code & Parameter Frequency

30-063-0034 Zone 11 42402 H2S

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 H2S Continuous

Site #2A N 520 8155

E 712 395

1 H2S = 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 condition 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 days 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 and second highest hourly concentrations for H2S 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 standard exceedances, and 

h. QA/QC information such as zero/span/precision, calibration, audit forms, and standards 

certifications.

11. The annual data report shall consist of a narrative data summary. The narrative data hard copy 

summary must be submitted 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 H2S 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 should 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 Supervisor