August 28,2006

Peter S. Courtney, P.E., P.G. Air ProtectionBranch Environmental Protection Division 4244 InternationalParkway, 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 stateto develop a StateImplementation Plan ("SIP") designed to address regional haze in mandatory Class I areas defined by the federal Clean Air Act. One element ofthe SIP involves the installation, operation and maintenance of Best Available Retrofit Technology ("BART") on emission units constructed between August 7, 1962 and August 7, 1977if their emissions of sulfur dioxide ("SOT), nitrogen dioxide ("NO:) andorvolatile organic compounds ("VOC) exceed 250 tons per year, referred to as "BART eligible sources", if these sources cause

or contributeto Visibility Impairment. To determine if a BART eligible source will become subject to BART involves an analysis ofthe regional haze impacts on Class I areas within 300 kilometers of the sources emissions of the three pollutants mentioned above. This analysis demonstratesthat the impact of the BART eligible sources is less than 0.5 deciviews at all four ofthe 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. Howeverthe wastewatertreatment 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 subjectto BART a modeling malysis of impacts from their emissions on nearby Class I areaswas conducted. Section ofEPA's guidance to the states on the preparation ofRegional Haze SIPS,found at Appendix Y to 40 CFR Part 5 1provides the process for this analysis. Essentially 

### a threshold is established, a modeling protocol developedusing EPA's CALPUFF model and the modeling is performed and comparedto the threshold. The Statethen determines whether the emission unit is subjectto 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 ofthe CALPUFF model

4470 Savannah Highway 

### * P.O. Box 2070

@ Jesup, GA 31598-2070 Telephone (912) 427-5000Application for Exemption to B yonier PerformanceFibersLLC, 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 applicationto the Stateof Georgia. The Modeling Protocol was also submitted to representativesof theFederal Land Managers ofFederal Class I areas within 300 kilometers via the 

### Air Protection Branch ofthe Environmental Protection Division. On June 26,2006, comments were received from the Stateof 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-omthe 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 calculationsand PMlospeciation are in Appendix A ofthe modeling report; and (7) Modeling was conducted accordi TAS protocol, alternative methods were not used. All ofthe comments on thls mng Protocol were addressed in the final modeling.

This analysis demonstrzltesthat the impact ofthe eligible sources is less than 

### 0.5 deciviews at allfour ofthe Federal Class I areas within 300 kilom Attached is a final report ofthe Analysis resulting fromthe Modeling Protocol. enclosed is a CD ofthe modeling input files.

As requested by the Division, copies ofthis submittal with the three attachments have the four Federal Land ers as listed below and Brenda Johnson at



### . It is understoodthat to meet the Reasonable r Progress the regional haze rule, controls in additionto couldbe required. However, based on this analysis Rayonier ce FibersLLC requests notification 11is not subjectto adApplication for Exemption to BART Rayonier PerformanceFibers LLC, Jesup Mll August 24,2006 Page 3 of 3



### Ifyou have questions regarding this application please contactDavid 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 ofWeston Solutions, Inc. at (9l9)424-2222, email: 

### kevin.eldrid~e@,westonsolutions. 

### com

David Pbgers Manager, Environmental Operations Rayonier, Jesup Mill

Cc: For For WolfIsland National Wildlife Refbge Okenfenokee National Wildlife Refbge

Allyne Askins George Constantino WolfIsland National Wildlife Refbge Okenfenokee National Wildlife Refbge 1000Business CenterDrive, Suite 10 Rt 2, 

### Box 3330 Savannah, GA 3 1405-1365 Folkston, GA 3 1507-9653

For For Cape RomaineNational Wildlife Refuge St 

### Marks National Wildlife Refuge

Donny Browning James Burnett Cape Romaine National Wildlife Refuge StMarks National Wildlife Refbge 5801 highway 17North Post Office Box 68 Awendaw, SC 29426-5908 StMarks, 32355-0068

For EPA Brenda Johnson EPA Region 

### IV 61 Forsyth Street, SW Atlanta, GA 30303-8960