August 28,2006 

Peter S. Courtney, P.E., P. G. 

Air Protection Branch 

Environmental Protection Division 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 

RE: Application for Exemption to Install, Operate and Maintain BART 

Pursuant to 40 CFR 51.303 

Dear Mr. Courtney: 

Section 40 CFR 5 1.308 requires each state to develop a State Implementation Plan 

("SIP") designed to address regional haze in mandatory Class I areas defined by the 

federal Clean Air Act. One element of the SIP involves the installation, operation and 

maintenance of Best Available Retrofit Technology ("BART") on emission units 

constructed between August 7, 1962 and August 7, 1977 if their emissions of sulfur 

dioxide ("SOT), nitrogen dioxide ("NO:) andor volatile organic compounds ("VOC) 

exceed 250 tons per year, referred to as "BART eligible sources", if these sources cause 

or contribute to Visibility Impairment. To determine if a BART eligible source will 

become subject to BART involves an analysis of the regional haze impacts on Class I 

areas within 300 kilometers of the sources emissions of the three pollutants mentioned 

above. This analysis demonstrates that the impact of the BART eligible sources is less 

than 0.5 deciviews at all four of the Federal Class I areas within 300 kilometers. 

Rayonier Performance Fibers LLC Jesup Mill has three BART eligible emission units: 

No. 5 recovery boiler, No. 5 smelt tank and No. 3 bark and oil boiler, the wastewsater 

treatment system, C-Mill (digesters, brownstock washers and bleach plant), and E 

evaporators. However the wastewater treatment system, C-mill (digesters, brownstock 

washers and bleach plant), and the D-evaporators do not emit visibility impairing 

pollutants (NO, SOa or PMlo) and were not included in the modeling analysis. To 

determine if these BART eligible sources should become subject to BART a modeling 

malysis of impacts from their emissions on nearby Class I areas was conducted. Section 

of EPA's guidance to the states on the preparation of Regional Haze SIPS, found at 

Appendix Y to 40 CFR Part 5 1 provides the process for this analysis. Essentially a 

threshold is established, a modeling protocol developed using EPA's CALPUFF model 

and the modeling is performed and compared to the threshold. The State then 

determines whether the emission unit is subject to BART. 

The Guidance recommends 0.5 deciviews as the threshold. The Regional Planning 

Organization (VISTAS for Georgia), EPA, Federal Land Managers and the states have 

developed a protocol for this demonstration involving the use of the CALPUFF model 

4470 Savannah Highway * P.O. Box 2070 @ Jesup, GA 31598-2070 

Telephone (912) 427-5000 
Application for Exemption to B 

yonier Performance Fibers LLC, 

August 24,2006 

Page 2 of 3 

using certain default options, given meteorology and the worst case normal operating day 

in the period 2002 to 2004. 

On April 27,2006, Weston Solutions, Inc. submitted the Modeling Protocol for the Jesup 

Mill BART exemption application to the State of Georgia. The Modeling Protocol was 

also submitted to representatives of the Federal Land Managers of Federal Class I areas 

within 300 kilometers via the Air Protection Branch of the Environmental Protection 

Division. On June 26,2006, comments were received from the State of Georgia and the 

various Federal Land Managers in a letter from Peter S. Courtney to David Rogers of 

Rayonier 

In response to the June 26 2006 comments received from the Air Branch, the modeling 

report includes the following: (1) All Class I areas within 300 kilometers were modeled; 

(2) Appropriate Class I receptor sets were obtained fi-om the National Park Service; (3) 

The settings used in each of the F system modules are listed in the report; (4) 

BPIP files addressing GEP stack been previously sent to CffiPD; (5) All 

Class I areas modeled are >SO km, therefore no downwash was used; (6) Emission 

calculations and PMlo speciation are in Appendix A of the modeling report; and 

(7) Modeling was conducted accordi TAS protocol, alternative methods were 

not used. All of the comments on thls mng Protocol were addressed in the final 

modeling. 

This analysis demonstrzltes that the impact of the eligible sources is less than 0.5 

deciviews at all four of the Federal Class I areas within 300 kilom Attached is a 

final report of the Analysis resulting from the Modeling Protocol. enclosed is a CD 

of the modeling input files. 

As requested by the Division, copies of this submittal with the three attachments have 

the four Federal Land ers as listed below and Brenda Johnson at 

. It is understood that to meet the Reasonable r Progress 

the regional haze rule, controls in addition to could be required. 

However, based on this analysis Rayonier ce Fibers LLC requests notification 

11 is not subject to ad 
Application for Exemption to BART 

Rayonier Performance Fibers LLC, Jesup Mll 

August 24,2006 

Page 3 of 3 

If you have questions regarding this application please contact David Rogers at (912)427- 

5424, email: david.rogers@ravonier.com or David Tudor (904)277-1452, email: 

david.tudor@,rayonier.com. Ifthere is a specific modeling question you may contact 

Kevin Eldridge of Weston Solutions, Inc. at (9 l9)424-2222, email: 

kevin.eldrid~e@,westonsolutions. com 

David Pbgers 

Manager, Environmental Operations 

Rayonier, Jesup Mill 

Cc: 

For For 

Wolf Island National Wildlife Refbge Okenfenokee National Wildlife Refbge 

Allyne Askins George Constantino 

Wolf Island National Wildlife Refbge Okenfenokee National Wildlife Refbge 

1000 Business Center Drive, Suite 10 Rt 2, Box 3330 

Savannah, GA 3 1405-1365 Folkston, GA 3 1507-9653 

For For 

Cape Romaine National Wildlife Refuge St Marks National Wildlife Refuge 

Donny Browning James Burnett 

Cape Romaine National Wildlife Refuge St Marks National Wildlife Refbge 

5801 highway 17 North Post Office Box 68 

Awendaw, SC 29426-5908 St Marks, 32355-0068 

For EPA 

Brenda Johnson 

EPA Region IV 

61 Forsyth Street, SW 

Atlanta, GA 30303-8960